ELISABETH WATERS: No.
MR. DOLAN: Have you ever practiced Wicca?
ELISABETH WATERS: No.
MR. DOLAN: Have you ever practiced black magic?
ELISABETH WATERS: No.
MR. DOLAN: Have you ever practiced paganism?
ELISABETH WATERS: I have attended some pagan rituals, and I was active for a while in the Dark Moon Circle. I was sort of tagging after Marion while she was doing research for Mists of Avalon.
MR. DOLAN: Did Moira Breen ever indicate to you that she felt that she had been the victim of satanic ritual abuse?
ELISABETH WATERS: Could you give me a time frame?
MR. DOLAN: Ever.
ELISABETH WATERS: Yes.
MR. DOLAN: When?
ELISABETH WATERS: After all of the investigation with Kenny.
MR. DOLAN: After or during?
ELISABETH WATERS: After the investigation with Kenny started.
MR. DOLAN: Can you give me an approximate time frame when you had this discussion with Moira?
ELISABETH WATERS: I think it was while he was in the hospital, with the CPS in Laguna Hills.
MR. DOLAN: Give me a month and year, please?
ELISABETH WATERS: I don’t remember.
MR. DOLAN: Can you give me a year, please?
ELISABETH WATERS: I think it would be 1990.
MR. DOLAN: Do you recall whether it was winter, spring, summer or fall?
ELISABETH WATERS: Not too many seasons in Southern California.
MR. DOLAN: As we know these things in the East Coast, I guess.
ELISABETH WATERS: I really don’t remember, I’m sorry.
MR. DOLAN: Were there lights on palm trees? Could you please tell me what Moira Breen told you about her belief that she had been a victim of satanic ritual abuse?
ELISABETH WATERS: She said that some men in white robes tied her up and hung her on the wall and poured hot coffee on her and spilled, I think, spilled hot wax on her skin and killed a baby in front of her and killed a grown-up in front of her and gave her something to eat and told her—something to eat—some funny meat and told her it was her baby brother, and she has never had a baby brother. She said a lot of stuff, and none of it made sense.
MR. DOLAN: Did she tell you whether she had been sexually assaulted by any of those people during the satanic ritual abuse?
ELISABETH WATERS: Not that I recall.
MR. DOLAN: Did she tell you where she believed the satanic ritual abuse had occurred?
ELISABETH WATERS: No.
MR. DOLAN: Did you ever come to learn from any source where she believed the satanic ritual occurred?
ELISABETH WATERS: No.
MR. DOLAN: Have you ever read any letters addressed to Marion Zimmer Bradley from Moira Breen regarding the satanic ritual abuse?
ELISABETH WATERS: I think so. There have been so many letters. It’s hard to remember them all.
MR. DOLAN: Do you open all Marion Zimmer Bradley’s mail?
ELISABETH WATERS: Yes.
MR. DOLAN: How long have you been doing that?
ELISABETH WATERS: Well, I started working for her full-time in 1986, and I was working for her part-time before that.
MR. DOLAN: Have you been opening her mail full-time since 1986?
ELISABETH WATERS: Yes.
MR. DOLAN: Do you read all of her mail?
ELISABETH WATERS: If it’s a personal letter from somebody she knows, I will just look at the top and open the envelope enough to see if it’s personal, and then I will just toss it on to her.
MR. DOLAN: Have you read Moira’s letters to Marion Zimmer Bradley?
ELISABETH WATERS: Some of them. I did not routinely read everything Moira wrote to Marion because that was mother-daughter correspondence, not business correspondence.
MR. DOLAN: Did you ever ask Marion about any of these allegations of satanic ritual abuse?
ELISABETH WATERS: I don’t remember. I might have told her that Moira was saying this stuff.
MR. BURESH: I don’t want you to speculate about what you might have done. You’re fine. For Mr. Dolan’s sake, if you want to try and jog your memory and pause and think about it, but please don’t say what you might have done.
MR. DOLAN: Do you have any recollection whatsoever? I am entitled to know that. It doesn’t have to be crystal clear.
ELISABETH WATERS: Actually, no, I don’t recall discussing it with Marion.
MR. DOLAN: Have you ever discussed the topic of satanic ritual abuse with Marion?
ELISABETH WATERS: As regards to real people or as regards to her books?
MR. DOLAN: Start with real people?
ELISABETH WATERS: With real people, no.
MR. DOLAN: Has she written any books on satanic ritual abuse?
MR. BURESH: Wait a minute. Any books in which that topic comes up? You said a book on that subject.
MR. DOLAN: Has she ever written any books where that topic is discussed or incorporated into the theme?
ELISABETH WATERS: Yes, it’s in some of her occult novels.
MR. DOLAN: What are the names of those novels?
ELISABETH WATERS: Dark Satanic, The Inheritor, actually The Inheritor—well, sort of, Witch Hill. That’s all I can think of at the minute.
MR. DOLAN: Do any of those novels involve the satanic ritual abuse of a young girl?
ELISABETH WATERS: No.
MR. DOLAN: Do any of them involve a young heroine who was abused by satanists?
ELISABETH WATERS: No.
MR. DOLAN: Do any of them involve a young woman?
ELISABETH WATERS: There is a character in The Inheritor named Emily who is rather loosely based on Moira, in that she was a music student, and a very talented one. And there is a character in the book named Simon who is dating Emily’s older sister, and he was an adapt, I guess, a white adapt, and then he was in a car accident and injured his hand. And he was a piano player, and this upset him very much, and he was willing to do just about anything to get the use of his hand back, so he could go back to playing the piano. He hypnotized Emily. He was teaching her to play the harpsichord and that was part of the teaching. He took her to, what sounds like a sort of pseudo-Rosicrucian ritual where she just sat there. She was their token virgin and was sitting under the rose, whatever that means. And that was all he did to Emily. What he did later in the book was try to sacrifice a child who was mentally defective and was one of the older sister’s patients. The older sister was a therapist. And the good guys came in and told him this was a really bad idea, and he decided not to do it, and then smashed his hand completely so that he would never be attempted to do this again, so he sort of repented and returned to the light.
MR. DOLAN: Do you know when this was written?
MS. DURRELL: Excuse me just a second. What book was this?
ELISABETH WATERS: The Inheritor.
MR. DOLAN: The Inheritor.
ELISABETH WATERS: Sometime in the 1980’s.
MR. DOLAN: Before Ken Smith–
ELISABETH WATERS: Yes.
MR. DOLAN:—had been identified as being molested?
ELISABETH WATERS: Yes.
MR. DOLAN: And before Moira had told you about the satanic ritual abuse?
ELISABETH WATERS: Yes.
MR. DOLAN: Do you know where Marion got her research on the satanic ritual abuse?
ELISABETH WATERS: She read the Golden Bough. She read the books on the order of the—I think it’s called The Order of the Golden Dawn. She’s read Alisdair Crowle’s work, and then I think they made a lot of it up. After all, she was writing fiction.
MR. DOLAN: Do you know if there was ever any satanic rituals performed at Greyhaven?
ELISABETH WATERS: I don’t know. I don’t go to Greyhaven very often. I haven’t been there in years.
MR. DOLAN: Is your answer that you don’t know if it was ever practiced at Greyhaven?
ELISABETH WATERS: To the best of my knowledge, none of the people at Greyhaven are Satanists.
MR. DOLAN: The question is, do you know whether satanic rituals were ever performed at Greyhaven?
ELISABETH WATERS: No.
MR. DOLAN: You brought up an interesting issue of—and I was going to do it later on. What documents did you review in preparation for your deposition today?
ELISABETH WATERS: The police report. I glanced through those things from Moira.
MR. DOLAN: Don’t look to him to help you out. He’s going to remain remarkably silent throughout this part of it.
MR. BURESH: I’m happy to—I’ll tell you what I showed you. Maybe now is the time to break simply because we seem to be running out of mental steam.
MR. DOLAN: Okay.
MR. BURESH: She knows what she reviewed.
MR. DOLAN: I just want to ask one short series of questions before we break, if we can.
MR. BURESH: Well–
MR. DOLAN: Did you keep diaries through most of the time between 1979 and 1989?
ELISABETH WATERS: No.
MR. DOLAN: When did you start keeping a personal diary?
ELISABETH WATERS: I don’t keep a personal diary.
MR. DOLAN: There were some diary entries that were turned over to the police?
ELISABETH WATERS: That was a police report that I wrote specifically for Officer Harris.
MR. DOLAN: So those things that you were reporting, writing down starting on 12, October ’89 roughly, were done specifically to be handed over to the police?
ELISABETH WATERS: Yes.
MR. DOLAN: Do you keep—did you keep any personal journals whatsoever between 1979 and 1989?
ELISABETH WATERS: No.
MR. DOLAN: Did you keep any items like the things that were on the computer and turned over to Officer Harris, just little mental thoughts, on the computer between 1979 and 1989?
ELISABETH WATERS: No.
MR. DOLAN: Did you turn over to Officer Harris all of your thoughts and notes that pertained to the molestation of Ken Smith?
ELISABETH WATERS: Yes.
MR. BURESH: Well, just so I’m clear on the question. Written or recorded thoughts and notes?
MR. DOLAN: Right, right.
ELISABETH WATERS: Yes.
MR. DOLAN: Have you, other than the items that you turned over to Officer Harris, have you, in your possession, any documents that you would have authored that relate to the molestation of Ken Smith other than what you have turned over to me by your attorneys?
ELISABETH WATERS: No.
MR. DOLAN: We can break now and come back. (Whereupon, the lunch recess was taken.)
A F T E R N O O N S E S S I O N
MR. DOLAN: Can you give me the last question and answer, please. We were talking about your diaries. Never mind. Or lack there of.
ELISABETH WATERS: One clarification in what I was reading in preparing for the deposition, when I said “the police report,” I meant my portion of the police report.
MR. DOLAN: Okay. That’s those documents that you gave to the police?
ELISABETH WATERS: Yes, not the entire report.
MR. DOLAN: Let me ask a question before we delve further. There was a $57,000 loan following the divorce of Walter Breen and Marion Zimmer Bradley, if I remember correctly, that was part of the marital dissolution. Do you recall anything pertaining to that?
ELISABETH WATERS: I imagine that would be this was–
MR. BURESH: If you’re imagining then—I don’t want you to imagine.
ELISABETH WATERS: I’m not imagining.
MR. BURESH: All right.
ELISABETH WATERS: Are you talking about a loan where Marion owed the money to Walter?
MR. DOLAN: Yes, and it was to be paid in three equal payments through the time period 1993?
ELISABETH WATERS: Yes, she bought out his half of the house.
MR. DOLAN: Do you know if that loan was ever paid off?
ELISABETH WATERS: Yes, of course it was.
MR. DOLAN: The only reason I ask is I never saw satisfaction of the loan in the papers that were provided to me, but I saw documentation pertaining to the loan.
ELISABETH WATERS: Oh, I see. We don’t have all the papers. Heavens know where they all got to. It would be on file at the courthouse.
MR. DOLAN: Is that part of the settlement agreement between the lawsuit with Patrick and Marion Zimmer Bradley regarding the houses at all?
MR. BURESH: If you know.
MR. DOLAN: If you know.
ELISABETH WATERS: I mean, the—wait a minute. We’re talking about Marion buying out Walter’s interest in Prince Street, aren’t we?
MR. DOLAN: Correct.
ELISABETH WATERS: That had nothing to do with anything with Patrick. That was part of the divorce.
MR. DOLAN: To your knowledge though, this $57,000 was paid to Walter before his death?
ELISABETH WATERS: Oh, yes.
MR. DOLAN: What year did Walter die?
ELISABETH WATERS: 1993.
MR. DOLAN: Do you know of any documentation that exists that would verify the payment of that loan?
ELISABETH WATERS: There is on file. In the courthouse, there should be the—whatever they call it. What do they call it when they finally transfer?
MR. DOLAN: A quitclaim deed, or something like that?
ELISABETH WATERS: Reconveyance. Because I remember Walter lost—that’s right, Walter lost the papers, and we had to go through hoops to get that reconveyance done.
MR. BURESH: Let me just ask a question on this subject. Mr. Dolan has characterized this as a loan. To your knowledge was there a loan involved?
ELISABETH WATERS: Define“loan”.
MR. DOLAN: Well, I believe you indicated it was a loan, actually, not myself. I just said there was $57,000. She said there was a loan between Walter and—on the house which had to do with her buying the interest of the house?
ELISABETH WATERS: I think it would probably be more accurately characterized as “a mortgage,” since it was secured by the property. It was an exchange for his half of the house.
MR. DOLAN: Do you recall drafting the papers for that mortgage, loan, whatever, do you recall?
ELISABETH WATERS: I remember Camille LeGrand did it.
MR. DOLAN: The reason I am asking is I have, in the documents that you provided to me, an interspousal transfer deed dated 1990. There was also a document that was the loan agreement which called for payments past the 1990 period that the interspousal transfer was entered. I was wondering if there were any documents which closed that loop and show that it actually had been paid. That’s—I’ll show you these documents so that you’re not relying on my representations. Do you have the note? What date do you have on the quitclaim deed there?
ELISABETH WATERS: September 17th, 1985. Oh, this is the other property. This October 17th, 1985, is the 3031 Fulton property.
MR. DOLAN: Okay. But looking at the February 9, 1990, document for the interspousal transfer deed, can you tell me which property that relates to?
ELISABETH WATERS: That would be 2221 Prince.
MR. DOLAN: And that part of the deed was conveyed in 1990, correct?
ELISABETH WATERS: Yes.
MR. DOLAN: Was that the deed that you were talking about there was some difficulty in filing, or is there another deed?
ELISABETH WATERS: There may be another deed. There were so many of them. I just remember there was one where Walter was supposed to have the papers, and Walter lost the papers.
MR. DOLAN: There was a note secured by a deed of trust that was provided to me that I’ll show you now, which is—we can mark as Plaintiff’s 1 to this deposition. (Whereupon, Plaintiff’s Exhibit No. 1 was marked for identification.)
ELISABETH WATERS: I think what happened was that this one was paid off early, but I would have to go back to the bank to get checks or canceled checks or copies of checks or whatever.
MR. DOLAN: Do you know when Walter Breen died in 1993?
ELISABETH WATERS: April, toward the end of April.
MR. DOLAN: Do y
ou know if any documentation exists that shows that note, Plaintiff’s Exhibit 1, was satisfied?
ELISABETH WATERS: There must be some somewhere.
MR. DOLAN: Okay. Do you know if the note was paid directly to Walter, was it paid to somebody who had power of attorney, or was it paid to his estate; do you recall?
ELISABETH WATERS: Well, it can’t have been paid to his estate because it was paid before he died. To the best of my memory, and I can not swear absolutely to the truthfulness of this, what tended to happen is that Marion and Walter, if they were lending each other money, would write up a note, and as soon as the money came in they would pay it off, so this was probably paid off way early, and, therefore, would have been—let’s see, when was Walter arrested in ’91?
MR. DOLAN: He appears to have been arrested in—according to the police reports here, roughly in August of 1991.
ELISABETH WATERS: That sounds right. So if it was paid off before then, it would have been paid directly to Walter. After he was arrested, he gave his power of attorney to his son, Patrick.
MR. BURESH: Are you talking about the Los Angeles arrest?
ELISABETH WATERS: Yes, one that put him in jail and prevented him from managing his own affairs.
MR. DOLAN: Did you ever hold power of attorney for Walter after his arrest in Los Angeles County?
ELISABETH WATERS: I never held power of attorney for Walter at all.
MR. DOLAN: Were you ever an owner of the property in which Walter Breen resided?
ELISABETH WATERS: Which one?
MR. DOLAN: Are you an owner of any of the properties either on Prince Street or Fulton Street?
ELISABETH WATERS: At present—wait a minute. Let’s get a time period here. Are you asking if I was an owner of 3031 Fulton or 2221 Prince?
MR. DOLAN: Let me ask you this question: Prior to 1989, were you an owner on any of the properties, either 2221 Prince Street or Fulton Street?
ELISABETH WATERS: I was a part owner of 3031 Fulton.
MR. DOLAN: And that’s where Walter Breen was residing?
ELISABETH WATERS: Yes.
MR. DOLAN: And what time were you a part owner of 3031 Fulton Street?
ELISABETH WATERS: From the time we purchased it until, I believe, the summer of 1990.
MR. DOLAN: When did you purchase it?
ELISABETH WATERS: It was just on here. October 17th, 1985.
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