When I ran out of Bikram's hotel room in a hurry so as "not be late for class" I'd hoped he would think of me as a person who didnt sleep around. I sssumed that would work for me not against me, alwasy thought it was only the Jane interference that caused the problems...But in recognizing the same thinsg said, teh said behaviors towards me (and I am a door mat compared to Sara Baughn I know which is another reason I never expected anyone to believe me)and frankly never would have believed Bikram to be such an idiot-truly must be a moron to do this to so many people-or so full of hate I have trouble believing he was physically violent but would believe Sara's story when I think about the amount of pain and suffering that I KNOW has gone on-all so needlessly.....But anyway... Go Sara. Full support.
http://www.pdf-archive.com/2013/03/19/lawsuit/lawsuit.pdf
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RELATIONSHIPS 11. CIVIL CONSPIRACY 12. DEFAMATION [CALIFORNIA CIVIL CODE
§ 44] 13. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 14. NEGLIGENT
INFLICTION OF EMOTIONAL DISTRESS 15. NEGLIGENCE 16. NEGLIGENT
SUPERVISION AND HIRING 17. UNLAWFUL NON-COMPETE AGREEMENT [BUSINESS AND
PROFESSIONS CODE § 16600 ET SEQ.] 18. CLAIM FOR DECLARATORY AND
INJUNCTIVE RELIEF
REQUEST FOR JURY TRIAL AMOUNT IN CONTROVERSY EXCEEDS $25,000
Plaintiff SARAH BAUGHN complains against Defendants BIKRAM CHOUDHURY,
BIKRAM’S YOGA COLLEGE OF INDIA, L.P., and DOES 1-25as follows. NATURE OF
THE ACTION 1. This is a sex-based discrimination and sexual harassment
case where Plaintiff
is being discriminated against as a woman, because she did not and will
not submit to Defendant Bikram Choudhury’s repeated demands for sex, and
because she successfully fought him off when he sexually assaulted her.
As a result, Plaintiff was punished and threatened, including with
implicit economic reprisals if she were to discuss or report the sexual
assault, and was not permitted to reach the highest levels of her
profession. 2. To this very day, Defendant Bikram Choudhury and others
have engaged in a
campaign of civil conspiracy, unfair competition, and tortious
interference that began when Plaintiff was denied her rightful,
judge-determined title as International Champion in 2008 because she
refused Mr. Choudhury’s demand to have sex with him. This conspiracy
continues to the present when she has been prevented from teaching
seminars or advanced classes because of her past and continuing refusal
to have sex with her guru. Other people who have either submitted to Mr.
-2COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF
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Choudhury’s sexual advances or provided him with women for sex have been
permitted to teach such classes. 3. As a direct consequence of these
unlawful acts, Plaintiff has suffered
economic, consequential, and other damages, all to her detriment.
Defendants’ actions forced Plaintiff to hire attorneys and file suit and
she, therefore, has incurred substantial attorneys’ fees and costs.
PARTIES 4. Plaintiff SARAH BAUGHN (hereinafter, “Sarah,” “Sarah Baughn”
or
“Plaintiff”) was a resident of San Francisco, California in the County
of San Francisco or Vista, California in the County of San Diego at all
times material to this complaint. Sarah Baughn is a young woman who is
fully qualified and certified by Defendants Bikram Choudhury
(hereinafter, “Choudhury” or “Defendant Choudhury”) and Bikram’s Yoga
College of India, L.P. (hereinafter, “Yoga College.”) to teach “Bikram
Yoga” which is a type of Hatha Yoga practiced in rooms heated to 105
degrees Fahrenheit. 5. Defendant Choudhury is an individual and a
resident of Beverly Hills,
California in the County of Los Angeles at all times material to this
complaint. 6. Defendant Rajashree Choudhury is an individual and a
resident of Beverly
Hills, California in the County of Los Angeles at all times material to
this complaint. 7. Defendant Yoga College was a California Limited
Partnership (California
Secretary of State No. 200223100010) and operated in the City and County
of Los Angeles at all times material to this complaint. Plaintiff is
informed and believed that Defendant Choudhury treats the corporation as
his “alter ego” rather than as a separate entity, and that upholding
the corporate entity and allowing Choudhury to escape personal liability
for its actions would sanction a fraud or promote an injustice. 8. The
true names and capacities, whether individual, corporate, associate or
otherwise, of Defendants Does 1 through 50, are unknown to Plaintiff,
who therefore sues said Defendants by such fictitious names. Plaintiff
will amend this Complaint by inserting the true names and capacities of
each such Defendant, with appropriate charging allegations, when they
are -3COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF
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ascertained. Plaintiff is informed and believes and thereon alleges that
each of the Defendants designated herein as a “Doe” is responsible in
some manner for the injuries suffered by Plaintiff and for damages
proximately caused by the conduct of each such Defendant as herein
alleged. 9. Plaintiff is informed and believes and thereon alleges that
at all times material
to this Complaint, Defendant and each of the defendants fictitiously
named in this Complaint, in addition to acting for himself, herself or
itself, and on his, her or its own behalf individually, is and was
acting as the agent, servant, employee and representative of, and with
the knowledge, consent and permission of, and in conspiracy with each
and all of the defendants and within the course, scope and authority of
that agency, service, employment, representation and conspiracy.
Plaintiff further alleges on information and belief that the acts of
each of the defendants were fully ratified by each and all of the
defendants. Specifically, and without limitation, Plaintiff alleges on
information and belief that the actions, failures to act, breaches,
conspiracy and misrepresentations alleged herein and attributed to one
or more of the specific defendants were approved, ratified and done with
the cooperation and knowledge of each and all of the defendants. 10.
The allegations of this Complaint stated on information and belief are
likely
to have evidentiary support after a reasonable opportunity for further
investigation and discovery. VENUE 11. Venue is proper because Defendant
Yoga College is a limited partnership
that is doing business, or has done business during the times related
herein, in the City and County of Los Angeles. 12. Defendant Bikram
Choudhury, individually and as a managing agent of
Defendant Yoga College, committed acts causing harm to Plaintiff
primarily in the State of California. CONTINUING VIOLATIONS 13. The
wrongful acts and omissions giving rise to the Defendants’ liability in
this action commenced in our about Spring 2005 and have been and are
“continuing” in nature as of the date of filing this Complaint.
Plaintiff reserves the right to amend this Complaint as new and
additional facts and claims arise or become known to Plaintiff.
-4COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF
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