DECLARATION UNDER PENALTY OF PERJURY PURSUANT TO 28 USCA 1746

I, Kathryn Whitehead, declare and state as follows:

I was taken to a residential facility in Montana because of a number of issues I was struggling with. I was doing poorly in school, cutting classes, and had run away, but the real catalyst was a suicide attempt. I was 13 years old and had been placed in a psychiatric hospital. The cost was too great and after my mom consulted an educational consultant it was decided that the best place for me was a residential facility in called Mission Mountain School in Montana that claimed to have the ability to treat such issues as depression. It was only later that I would come to find out that the staff at this facility were unqualified to deal with mental illness. Of the 3 men who founded the program, who also involved themselves in day to day oversight and ran the group therapy, only one was a mental health counselor of some sort, another one was a licensed drug and alcohol counselor, but the most involved one, called himself "the headmaster," who held a masters in ecology and had no mental health degree whatsoever. None of the other staff were educated or trained in mental health, as far as I know.

The program that I was sent to called itself a therapeutic boarding school, rather than a residential treatment facility, although there wasn't much in the way of education. There was one teacher who taught both History and Science, English was taught by the headmaster's wife, and I had to teach myself Algebra. I was taught very little and struggled afterwards to catch up on what I had not been taught.

The program was structured very much as a hierarchy to establish the authority and control of the program staff. From the moment I set foot at the school, I experienced a general stripping of my identity. All of my clothes were thrown away, my hair was chopped off, my music was taken away, and all contact with my friends and family (including my parents) was prohibited. Calls with parents would later be allowed after 3 months but they were monitored to prevent any type of what was called "school bashing" and "manipulation," which essentially meant any complaints about the school and attempts to be taken home. My mother was also told to watch out for me trying to get her to take me out of the program and was told that I would try to be manipulative.

I was immediately thrown into day-to-day requirements of chores, exercise, and labor. This wasn't like what a lot of healthy teenagers are required to do, this was forced labor and exercise, and I was exhausted all the time. The essential premise of this facility was that the better disciplined a kid was, and the more endurance they demonstrated in work and exercise, the healthier they were, mentally and emotionally. The assumption was that in our perpetually exhausted state we would be too tired to hide our feelings and have no other choice but to purge emotional burdens. Invasively and with no choice we would have to write out a very detailed account of our life, sexual and drug history, which we would later have to reveal to our parents, to assure them we were in the right place. The aims were to force us to reveal explicitly and in great detail what got us to the program and to teach us to hold each other accountable to the program and ourselves which were determined to be one in the same.

The reality was not so simple. Being accountable to the program essentially meant that I was required to be absolutely unquestioning and was forced to subscribe to whatever the staff determined was true, unless I chose to actually tell my truth and suffer the consequences of punishment in the form of work, exercise or humiliation and a downgrade in status that would prevent me from going home. If the staff believed you were an addict, you were expected to admit to being an addict, and if you didn't you were told you were in denial. I was told I was an addict/alcoholic because I drank for the purpose of getting drunk a few times, although I never drank regularly and I had never done drugs. My close friend was deemed a sex addict because she was very feminine and kind of sensual in her demeanor, although she had never had sex. When this friend did not wholeheartedly accept the label of "sex addict," she was forced to pick up about 6 rocks, each the size of a large mango, and then was forced to carry them with her at all times for several months, naming them issues like sexual abuse, sex addiction, etc. Until she conceded to staff that each issue was true, and detailed why she felt that way, and cried about it, what the staff called "processing," she was forced to carry these rocks as "metaphors of her burden." She often had bruising along her spine from the weight.

We were also often told by staff that we had food addictions because, according to staff, we were using food to stuff and hide our emotions. While I was there, all but one girl was on a food plan, which meant that each portion was strictly measured and we were forbidden from eating less or more of any food than what was specified on the food plan. Despite not having an eating disorder or being overweight , I was on a restricted calorie meal plan and was often hungry. ***Taking extra pieces of fruit and the like was called stealing and was considered an indication of using food to hide emotions, an indication of what they called resistance to the program, punishable by work crew or exercise or had to be dealt with in group, where you had to name the problem that issue you were trying to hide, denying the existence of this problem was not an option.

Daily exercises, in the morning and evening were required of all kids in the program, with few days of complete rest. In the spring, summer and fall, a large percentage of kids would become physically ill from the amount of biking we did and the fact that we were not allowed to stop regularly to go to the bathroom, urinary tract infections were not uncommon. I recall on one particular lengthy, mostly uphill, 50 mile bike ride I was exhausted. I was simply worn out. but I also understood the rules. If I were to stop, I had to have a very good reason to give that involved either a memory of painful abuse or some type of confession. Simply, I wanted to stop to rest, and I broke down crying. A therapy group was called on the side of the highway. I made something up about having emotions about sexual abuse. Keep in mind I had never been sexually abused. We learned over time that the only way to avoid punishment was to confess to some hidden problem or secret, whether or not it was true.

There were a lot of times when the staff would arbitrarily decide that too many kids were withholding the truth, especially if it appeared the older students were not doing their job putting newer students in line by pointing out ways they were not following the program or ways they sensed they were being dishonest in our group meetings. We were then told that we were being resistant and manipulative, and that this behavior warranted being punished, what they called "consequences." As a consequence, we would be "placed on intervention" and forced to do more exercise or heavy labor. This involved work such as digging tree stumps, ice picking, rock picking, fence building and other grounds-keeping for hours on end. Once we were on an intervention for 2 months that involved fence building and picking daisies everyday. This sounds a lot easier than it was. Our hands would be blistered, backs aching from hours of leaning over. During intervention periods, we did nothing else beyond work and group therapy. The school would be placed on lock down, what little education we did have was interrupted and our normally scheduled bi-monthly calls with parents (if we had been there more than a few months) and mail flow were stopped.

Individual punishments were administered too. Once I was placed on intervention for speaking of running away. For over a week I was forced to dig a hole in the ground and pick rocks out of it with a rock pick for anywhere between 8 -10 hours each day, with no breaks except for during meal times and chores. I was also dropped off 25 miles from the school and was forced to hike back with 2 secondary staff biking along side me, my not-yet-broken-in feet were covered in blisters double the size of quarters and I could barely walk for day afterwards. As I understand, this was easy compared to what later kids had to go through. A good friend of mine who attended this program a little later that I did was placed on an intervention out alone in the woods for months in the winter, left alone to dig out tree stumps everyday by herself.

To someone who wasn't there, the level of constant fear and its effects are difficult to convey. Two of the three male founding staff were domineering, would yell, tease and mock us. Some kids were excluded from this, those who were the staff favorites, and a select few were picked on constantly. I was somewhere in the middle and managed to skate by after I learned how to act and what to say to avoid being humiliated and singled out, but I was constantly terrified of the staff or other students pointing out that I was being in any way resistant, as they had at the beginning and did the others on a daily basis. I felt completely powerless to speak freely, and I was vulnerable to each and every whim of those who were in total control over to determine whether or not I would ever be deemed healthy enough to return home. It became common knowledge, frequently pointed out by the founders, that if we did not follow this program we would end up in jail, insane or dead.

I was sent to this program because I had been feeling suicidal, so there were issues that I really had wanted and needed to deal with-issues that preoccupied me and that I knew I needed to figure out. I had made a point to mention these true issues to staff, but they were dismissed, presumably because they were not allegations of abuse or addiction and did not fit the program model. I expect that most or all of us knew we needed help. I went to the program voluntarily and did not have to be escorted, like some students. I wanted to be healthy and wanted desperately to have a relationship with my family. The facility made it clear that if I did not follow their program this would not be possible. Being completely isolated, with virtually no contact with the outside world, I lacked any reference point, any way of deciphering the legitimacy of what the staff told me about myself and what I had to do to get better. I was desperate to be close to my family and because of that desperation and general lack of choice in the matter, part of me came to believe that all of my struggles were generally self-created, either because I was not dealing with abuses talking or crying about them, or not being honest with myself, and that this was supposed to be simply resolvable by following 'the program'. I was told over and over that the program was the answer to my problems and if it wasn't working it was because I was doing something wrong and not being honest with myself and trusting the part of me that was crazy and sick, which of course was also the part of me that doubted the program.

Never once did I see a psychiatrist or receive formal psychotherapy for my depression. I remained generally depressed and found myself feeling suicidal at various points during my stay. I never told anyone about feeling suicidal because at that point I had already begun to believe that I was being manipulative or that they would say that I was not being honest with myself and make me stay longer, or send me to similar, but longer program I had heard worse things about in Utah.

I left the facility when I was 15 years old, after 18 months in the program. The staff said I was ready to "graduate", I guess my time was. More than anything I remember being terrified that I would be told I was not ready to go. When I was released from the program, the after-care plan was simply a laundry list of behaviors to be avoided and ways to prevent them like AA meetings or talking about my struggles with someone. I left believing I ought to be able to follow these simple guidelines to prevent myself from having any more problems, but found that much of my feelings of depression were still present and meetings hadn't helped. I felt like a failure, a raw nerve, frequently suffering from anxiety and nightmares of being sent back to the program. These feelings lasted for a long time, up until a few years ago. I found it difficult to function as the same struggles I had prior to being sent away returned. Concentrating in school proved nearly impossible and I dropped of high school a year after leaving the residential program. After that I continued to experience serious difficulties: developing and recovering from a drug problem, and several suicide attempts and hospitalizations. I would later come to be diagnosed with ADD, but not until 8 years after I had left the residential program I attended in my teens.

Had I been sent to a facility with qualified staff who could have provided me with skilled assessment and treatment for the 18 months that I was living in this residential program, I believe many of my future problems could have been averted, from diagnosing my ADD to treating my depression. I also believe my problems would not have been exacerbated in the way they were by the punishing treatment and pseudotherapeutic "interventions" I experienced at this facility. I likely would have had a much easier time transitioning into school if I had been educated by qualified teachers, I also believe that any opportunity that I could have had to truly become close to my family was squandered with this experience. They were permitted to visit a few times while I was at the school, but because there was a lack of regular family involvement and the same issues that existed between us before were very much present afterwards. My problems continued for many years until eventually I began to recognize ways to empower myself, and found a qualified psychiatrist who was able to diagnose me properly and help me get the treatment I needed and deserved so many years ago.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 25, 2005

Kathryn Whitehead [NAME OF DECLARANT] SPECIAL NOTE: STATUTE DOES NOT REQUIRE NOTARY]