$033100

 

SUMMONS mmuseomr
JUDICIAL) ?Wm
TO DEFENDANT: - CONFORMED 00:.
(AVISO AL DEMANDADO): sup
SEE ATTACHMENTA HERETO 
JUN ?1  .2113
YOU ARE BEING SUED BY PLAINTIFF: 1 - .
(LO ESTA DEMANDANDO EL DEMANDANTE): 
MINAKSHI JAFA-BODDEN BY 1 try mm. 

 

 






om Salt-Hen: Center your county law library. or the Mouse nearest you. It you cannot pay tho 1111119 fee. ask



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relorrat oervtoo. It you cannot attord attorney. you may torfraatagat services tram anenpro?t legal services program. Youcanloeate
uresenenpre?t groups atthe Colltornto Legal Services Web the California Courts Onttna Sett-t-tetp Corner


continuum

None 30 DIAS DE CALENDARIO dospu?s do cue to ontreguen esta drawn papalea logatos para prosoan rospuasto poroscr?o on asto
code yhoeorquo soentregm una copio aldamondonto. Una aorta a una Homeric SU raspuosto poresaite trons qua ester
onrermetetegeteonecto sideseo qooproceson woose ante eerto. 58qu um unfmlon'o qua ustedpueda warpemsu rospuoslo.
demeanosdo Commie Wm?gov). ante
quolo quoo'omas coma. Slnomrodopogorlo wore doprasontadon.pldoafsecrotarto dolocorto
ow to do an Ionnulorfo do oxenddn dopago do wales. 81 no presents su mspuoato a tlompo. puodo pordor a! case lo code 10
poor: quirarsu sueldo. dirtan Mono: sin moo advonouda.

Heyorrosroqrriatoslegalos. Simoonoeoo mahogado, puodo?amaraun sorvioiodo
mm a abogados. Sine puedo pager a an obogado. osposrblo qua complo can too women: para locales groan?? do an
program do amides locales sin ?nes do loom. Puedo onoontrorostos gums sin {Enos do (were on or smo we do Carltomlo Legal Sande?.
on at Centre do Ayudo do too Cortes do Calibrate. Muscular-tango? poniendoso on morocco con to aorta or
cologfodo obogadoolocotos. AVlso:Porloy, Ia cone tlonodoredro oredamartaswotosylos oosroaexontosporlmpenerun grovamen sabre
doredrodv?. Honoquo
pogarolyravomonda Io oortoontoa doqualo cartopuada chameleon.

The name and address of the court to: ?crtsa 110%

(51 nombre ydlroccr?n do a aorta as): LOS ANGELES SUP COURT
111 NORTHHIILSTREET 
LOS 90012 at:

The name. address. and telephone number of plaintiffs attorney. or ptainti? without an attorney. ls:

 

 

 

 

   

We 13 2M3 5A. cm?ar cm by MW mom .Depmy
(Fm?u   

(matador 1 Munro)
(Forproof ofsorvioe ofthis summons. use Proof of Service of Summons (form 
(Para pnrobo do ontroga do osta citation use 9! fonnulario Proof of Service of Summons. 
NOTICE 1'0 THE PERSON SERVED: You are served
1. C: as an individual defendant.
2. as the person sued under the ?ctitious name of (specify):

 

 

3. El on beharrorrspacw):

 

 

 

 

under: co? 416.10 (corporation) J- GOP 416.60 (minor)
cop 416.20 corporatton) CCP418.70(consarvatao)
416.40 (association or partnership) CCP 416.90 (authorized person)
other (specify):
4.1: byparsonat da?voryon (data): 
?hcgucmm SUMMONS 

sun-100 our.? 1.30061

ATTACHMENT A
NOTICE TO DEFENDANT:

BIKRAM CHOUDHURY, individually and as President of Bikram Choudhury Yoga
Inc., Chairman and CEO of Bikram?s Yoga College of India, LR, and as Presrdent of
Bile-am, Inc., RAJASHREE CHOUDHURY, individually and as President of USA
YOGA FEDERATION, Vice President of YOGA COLLEGE OF INDIA,

I LP. and as Vice President ofLBikram Inc., YOGA COLLEGE OF INDIA
L.P.. BIKRAM USA YOGA FEDERATION, BIKRAM CHOUDHURY YOGA,
INC., PETRA STARKE, individually and as President of Bikram?s Yoga College of
India, and DOES 1 through 25, inclusive,

 

 

 

 

 

 

 

 

 

 

 

 

A 05! Evaluator. WW 

CONFORMED 

4loo REDWOOD . .

OAKLAND. CA. 94619 5" 

mmuo: 415-2154! 15 FAXND: 415-358-5588
manusst MINAKSHI JAFA-BODDEN . 11 IN to
summon COURT or: ef?o?nng?mos  
WW I - v?  :elt-r?
melanomas: {88 NORTH mu. smear ii?" .
ANGELES CA 0 .. 
WW ST F. 
CASE NAME: 
JAFA-BODDEN V. BIKRAM CHOUDHURY ET AL
CIVIL CASE COVER SHEET mama? i 
unmd ?mm Decimals: Case Designation a a 1   4 
(Amount (Amount Counter .iolnder
demanded demandedls Filed with ?retappeerancebydefendent 
exceeds 525.000) $25,000 or less) (Col. Rules of Court. rule 3.402) cm
items 1-6 below must be ted see instructions on 2).
1. Check one box below for the case type that best describes this case:

Auto Tort Contact Compiex Civil Litigation
mm) mamm?m) (CaLMeeofcoun. alien 3M)
Uninsured motoriet(46) Cl mam mueceonsloe) I: AntilleTrerie realization (ea)

ommunorwo I: outerwear? (09) Construction deiect (10)

DarnegeMrongfui Death) Tort m? ?We (13) Mass tort (40)

Asbestos (04) Cl Otheramtmotm?) saauluesnunauonlzal

Prelim-limit (24) Real Property [3 
I: lnsuranceco daimsa?singimmlhe
(23) 00mm (14) 

Non-Pm (Other) Tort Wmliiui WWI (33) 

Mm We?. who? pm? (07) '3 Other real property (26) Enforcement oi' Judgment

(08) Unlawful Detelner Enforcement oijudgmenl (20)

Dolemellon (13) Con?rm-Ia! (31) Mioceiianeoue Civil Compinlnt
Fraud (18) 1: Residential (32) RICO (27)
meanders! property(19) Dates (38) champranllnolmedmmz)
Protesstonai negligence (25) Judicial Review mammalian
em (35) (m Partnership and corporate governance 


Wrongful melon (as) we: oi mandate (02) emu?)

Olilarempioyment (15) Other uddalrevlew
2. This case is is not complex under rule 3.400 of the Rules of Court. ii tile case is complex. merit the

factors requiring exceptional ludloial management:

a. CI Large number of separately represented parties d. [3 Large number of witnesses

b. I: Extensive motion practice raising dif?cult or novel e. Coordination with related actions pending in one or more courts
issues that will be time-consuming to resolve in other counties. states. or countries. or in lederel court

c. Substantial amount ofdocurnentery evidence r. Substantial postjudgrnent Judicial supervision

Remedies sought apply): all] monetary b.l:l nonmonetery: declaral 
Number of causes of action (specify):

'l'hiscase ls lsooi eciessactlonsuit.
tileend semenotlceoileiated ca 

JUNE 112012 I
V.MINNARD 
WORM CRAWFORPARTY)
noncs

- must tile this cover sheet with the ?rst paper tiled in the action or pmceedMi claims cases or cases ?ed
under the Probate Code. Family Code. or Welfare and institutions Code). (Cal. Rules of Court. rule 3.220.) Failure to ?le may result

in sanctions.
0 Filetiliscovereheetinaddilion to enycoverstleet required bylocal 
0 ll this case is complex under rule 3.400 et seq. ol' the California Rules of Court. you must serve copy oi this cover sheet on all

 
 
 
   
 
   



 

 

 

 

 

other parties to the action or proceeding.
0 Unless this is collections case under nrle 3.740 or a complex case. this cover sheet will be used for statistical purposes on . 1 a
CIVIL CASE COVER sneer M?wm?mem nmno?m

Clo-Ole  1. error; mm

 

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more: Fax no. roam
amalgam


SUPERIOR COURT OF CALIFORNIA. COUNTY OF LOS ANGELES

 

 

.

 

menu:

 

 

STIPULATION - EARLY ORGANIZATIONAL MEETING

 

 

 

 

This stipulation is intended to encourage cooperation among the parties at an early stage in
the iitigatlon and to assist the parties in efficient case resolution.

The parties agree that:

1. The parties commit  conduct an initial conference (in-person or via teleconference or via
videoconference) within 15 days from the date this stipulation is signed. to discuss and consider
whether there can be agreement on the following:

a. 
amendment as of ?ght. or if the Court would allow leave to amend. could an amended
complaint resolve most or all of the issues a demurrer might otherwise raise? if so. the parties
pleading issues sothatademurrerneed only raise issues theycannot
resolve. is the issue that the defendant seeks to raise-amenable to resolution on demurrer. or
would some other type of motion be preferable? Could a voluntary targeted exchange of
documents or information by any party cure an uncertainty in the pleadings?

b. Initial mutual exchanges of documents at the 'core' of the litigation. (For example. in an
employment case. the employment records. personnel tile and documents relating to the

police r890?. medical records. and repair or maintenance records could be considered


c. Exchange of names and contact information olwitnesses:

d. Any insurance agreement that may be available to satisfy part or all of a judgment. or to
indemnity or reimburse for payments made to satisfy a judgment;

e. Exchange of any other information that might be helpful to facilitate understanding. handling.
or resolution of the case in a manner that preserves objections or privileges by agreement:

f. Controllingissuesefiawthat. ifreseived efliciencyand economyin other 
phases efthecase. Also. when and hewsuchissuescanbepresented totheCeurt;

9. Whether or when the case should be scheduled with a settlement officer. what discovery or
court ruling on legal issues is reasonably required to make settlement discussions 
and whether the parties wish to use a sitting judge or a private mediator or other options as

 

STIPULATION-EARLY ORGANIZATIONAL MEETING mm:

 

 

 

 

 

 

discussed In the fAItemative' Dispute Resolution (ADR) Information Package' served with tire
complaint: .

h. Computation of damages. Including documents not privileged or protected from disclosure. on
which such computation Is based;

I. Whether the case is suitable for the Expedited Jury Trial procedures (see information at
under 'Clvr?l' and then under 'Generei Information').

2. The beextended

to for the complaint. and for the cross-
(HISBITDATE) (MIME)

complaint. which is comprised of the 30 days to respond under Government Code 68616(b).

and the 30 days permitted by Code of Civ? Procedure section 1054(a). good cause having

beenfound bythecivl SupervisingJudgeduetolhecase managementbene?tsprovidedby

this S?ptla?on.

3. The parties will prepare a Joint report titled 'Joint Status Report Pursuant to initial Conference
and Earty Organizational Meeting Stipulation. and If desired. a proposed order summarizing
results oftheirrneetend oonferand advisingthe Courtofanyway Itmayassistthe parties'
ef?clentconductorresolution ofthemse. Thepartlesshail attachiheJoIntStatus Reportto
the Case Management Conference statement. and tile the documents when the CMC
statement is due.

4. References to 'days' mean calendar days. unless otherwise noted. If the date for performing
any act pursuant to this stipulation falls on a Saturday. Sunday or Court holiday. then the time
forpertormingthatactshaii beexlendedtothe nextCourtday

 

 

 

 

 

 

 

 

The following parties stipulate:
Date:

(TYPE OR PRINT NAME) (ATTORNEY FOR PLAINTIFF)
Date:
. 
WPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT)
Date:

(TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT)
Date: . .
. 
(TYPE 0R PRINT NAME) (ATTORNEY FOR DEFENDANT)
Dale:
II 
(TYPE OR PRINT NAME) (ATTORNEY FOR 
Date: .

(TYPE 0R NAME) (ATTORNEY FOR 
Date:

(TYPE OR PRINT NAME) (ATTORNEY FOR 

 

 

 

snpuumou - EARLY MEETING Mm

.

 

 

 

 

 

 

 

 

rm Mi
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Wild: FAXNO. Md):

SUPERIOR COURT OF CAUFORNIA, COUNTY OF LOS ANGELES 
CWMESS:
We: 

I 
STIPULATION - DISCOVERY RESOLUTION

 

 

This stipulation is intended to provide a fast and informal resolution of discovery issues
through limited paperwork and an Informal conference with the Court to aid in the
resolution of the issues.

The parties agree that:

1.

Prior to the discovery cut-off in this action. no discovery motion shall be ?led or heard unless
the moving party first makes a written request for an inforrnai Discovery Conference pursuant
to the terms of this stipulation.

At the infonnai Discovery
and determine whether it
party from making a record at the
orally or in writing.

Following a reasonable and good faith attempt at an informal resolution of each issue to be
presented. a party may request an informal Discovery Conference pursuant to the following

procedures:

a. The party requesting the informal Discovery Conference will:

File a Request for informal Discovery Conference with the clerk's office on the
approved form (copy attached) and deliver a courtesy. conformed copy to the
assigned department;

include a brief summary of the dispute and specify the relief requested: and

Conference the Court will consider the dispute presented by parties
can be resolved informally. Nothing set forth herein will preclude a
conclusion of an informal Discovery Conference. either

Serve the opposing party pursuant to any authorized or agreed method of service
that ensures that the opposing party receives the Request for informal Discovery
Conference no later than the next court day following the ?ling.

b. Any Answer to a Request for informal Discovery Conference must:
i. Also be filed on the approved form (copy attached);

ii. include a brief summary of why the requested relief should be denied;

 

LACIVON


STIPULATION - DISCOVERY RESOLUTION a:

 

 

serum anus-e

 

 

 

 

ill. Be filed within two (2) court days of receipt of the Request; and

iv. Be served on the opposing party pursuant to any authorized or agreed upon
method of service that ensures that the opposing party receives the Answer no
later than the next court day following the filing.

c. No other pleadings. including but not limited to exhibits. declarations. or attachments. will
be accepted.

d. If the Court has not granted or denied the Request for inforrnei Discovery Conference
within ten (10) days following the filing of the Request. then it shall be deemed to have
been denied. If the Court acts on the Request. the parties will be noti?ed whether the
Request for informal Discovery Conference has been granted or denied and. if granted.
the date and time of the lnfonnai Discovery Conference. which must be We twenty (20)
days of the ?ling of the Request for Informal Discovery Conference.

e. if the conference is not held within twenty (20) claw of the filing of the Request for
informal Discovery Conference. unless extended by agreement of the parties and the
Court. then the Request for the informal Discovery Conference shall be deemed to have
been denied at that time.

. if the Court has denied a conference or one of the time deadlines above has expired
without the Court having acted or the inforrnai Discovery Conference is concluded without
resolving the dispute. then a party may ?le a discovery motion to address unresolved issues.

. The parties hereby further agree that the time for making a motion to compel or other
discovery motion is toiled from the date of ?ling of the Request for informal Discovery
Conference until his request is denied or deemed denied or twenty (20) days after the
filing of theRequest for lnfonnal DiscoveryConference. whichever is earlier. unless extended

by Order of the Court. .

it is the understanding and intent of the parties that this stipulation shell. for each discovery
dispute to which it applies. constitute a writing memorializing a later date to Which
the propounding for demanding or requesting] party and the responding party have agreed in
writing.? within the meaning of Code Civil Procedure sections 2031.320lc). and
2033.290tc).

. Nothing herein will preclude any party from applying ex parts for appropriate relief. including
an order shortening time for a motion to be heard concerning discovery. .

. Any party may terminate this stipulation by giving twenty-one (21) days notice of intent to
terminate the stipulation.

. References to 'days" mean calendar days. unless otherwise noted. if the date for performing
any act pursuant to this stipulation falls on a Saturday. Sunday or Court holiday. then the time
for that act shall be extended to the next Court day.

 

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The following parties stipulate:

 

 

 

 

 

 

 

 

 

Date:

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Data:


Date:

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Data: W1)

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Data:

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Date:

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Date:

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES



 

 



 



DEFENDANT:

 

INFORMAL DISCOVERY CONFERENCE
We! to the Discovery Resolution Stipulation of the parties)

 

 



 

 

1. This document relates to:
Request for Informal Discovery Conference
El Answer to Request for Infonnal Discovery Conference
2. DeadlineforCourttodecldeon Request

an we 
3. Deadline for Court to hold Informal Discovery Conference:



4. For a Request for Informal Discovery Conference, describe the nature of the
discovery dispute, Including the facts and legal arguments at issue. For an Answer to
Request for Informal Discovery Conference. describe why the Court should deny

museums-?mama
museum

the requested discovery. Including the facts and legal arguments at Issue.

 

Momma)
uccmmomr

INFORMAL DISCOVERY CONFERENCE
(pusuanttc lheDiscoveryReeciufion Stipulationoflheparliee)

 

 



WHO:
Bills;me

 

 

FM NO. (W):

 

SUPERIOR COURT OF CALIFORNIA, COUNTY OF L08 ANGELES


 

m:

 





 

 

 

811PULATION AND ORDER - MOTIONS IN UMINE

 

 

This stipulation ls intended to provide fast and informal resolution of evidentlary
issues through diligent efforts to define and discuss such issues and limit paperwork.

The parties agree that:

1. At least days before the final status conference. each party will provide all other
parties with a list containing a one paragraph explanation of each proposed motion in
iimine. Each one paragraph explanation must identify the substance of a single proposed

motion in iimine and the grounds for the proposed motion.

2. The parties thereafter will meet and confer. either in person or via teleconference or
videoconference. concerning all proposed motions in iimine. in that meet and confer. the

parties will determine:

a. Whether the parties can stipulate to any of the proposed motions. if the parties so
stipulate, they may tile a stipulation and proposed order with the Court.

b. Whether any of the proposed motions can be briefed and submitted by means of a
short joint statement of issues. For each motion which can be addressed by a short
joint statement of tame. a short joint statement of issues must be filed with the Court
10 days prior to the ?nal status conference. Each side?s portion of the short joint
statement of issues may not exceed three pages. The parties will meet and confer to
agree on a date and manner for exchanging the parties' respective portions of the
short joint statement of issues and the process for tiling the short joint statement of

issues.

3. All proposed motions in iimine that are not either the subject of a stipulation or briefed via
a short joint statement of issues will be briefed and ?led in accordance with the California

Rules of Court and the Los Angeles Superior Court Rules.

 

snpuunou AND omen-uonous LIMINE mm

LASCWMI

 

 

 

 

 

 

The following parties 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 



Data:

(TYPE OR PRINT NAME) (ATTORNEY FOR PLAINTIFF)

(TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT)
a 

(TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT)
Data: 
(TYPE OR PRINT NAME) (ATTORNEY FOR DEFENDANT)
Date:

(TYPE OR PRINT NAME) (ATTORNEY FOR I
Dale: .

(TYPE OR. PRINT NAME) (ATTORNEY FOR I
Date:
.
(TYPE OR PRINT NAME) (ATTORNEY FOR I
THE COURT 80 ORDERS.
Date:
mew. amass
?mm STTPULATION AND ORDER - MOTIONS IN LIMINE a,

INSIKU HANDLING V11: 
The following c?tical provisions of the Chapter Three Rules. as applicable in the Centml District, are summarized for your assistance.
gang-non . 
The Chapta?l?hrce Rules were e?eetive January 1, 1994. They apply to all general civil cases.
4W

CHALLENGE TO when

 


is dayaofthe?rst appearance.

Sl? ARDS
Calendaring followingtimcstandarda:
of?lingandproofofaervice shailbe ?lcdwithin90dayaof?ling.

CROSS-COMPLAINTS: Without leave of court ?rst being obtained, no cross-complaint may be ?led by any party a?er their
answa'is?ied. 
?lingdate.


complaint alternative 
.

AL ST C0


motionainlinline,b? 









This 8 not a complete delineation of the Chapter Three Rules, and adherence only to the above provisions is therefore
not a guarantee against the imposition of sanctions under Trial Court Delay Reduction. Carethl reading and
compliance with the actual Chapter Rules is absolutely imperative

LACNOOH 190 (Rev. 01/12) NOTICE OF CASE ASSIGNMENT - mom 2
wow 

Ferocious! UNLIMITED CIVIL CASE

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SHORT TITLE:

JAFA-BODDEN V. CHOUDHUFIY ET AL

CASE NUMBER

 

 

 

CIVIL CASE COVER SHEET ADDENDUM AND

STATEMENT OF LOCATION
(CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION)

 

 

This form is required pursuant to Local Rule 2.0 in all new civil case ?lings in the Los Angeles Superior Court.

 

 

Item I. Check the types of hearing and ?ll in the estimated length of hearing expected for this case:
JURY YES CLASS CI YES LIMITED DYES TIME ESTIMATED FOR TRIAL

DAYS

 

Item ll. Indicate the correct district and courthouse location (4 steps - If you checked ?Limited Case", skip to Item Ill, Pg. 4):

Step 1: After ?rst completing the Civil Case Cover Sheet form. ?nd the main Civil Case Cover Sheet heading for your
case in the left margin below, and, to the right in Column A. the Civil Case Cover Sheet case type you selected.

Step 2: Check _o_ne Superior Court type of action in Column below which best describes the nature of this case.

Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have
checked. For any exception to the court location, see Local Rule 2.0.

1. Class actions must be ?led in the Stanley Mosk Courthouse. central district.
2. May be ?led in central (other county, or no bodily injury/property damage).
3. Location where cause of action arose.

4. Location where bodily injury. death or dama occurred.

5. Location where performance required or de endant resides.

 

 

Applicable Reasons for Choosing Courthouse Location (see Column below)

 

 

6.
7.
8.
9.

Location of property or permanently garaged vehicle.
Location wherepetltioner resides. .

Location wherein defendant/res ondent functions wholly.
Location where one or more of

. parties reside.
10. Location of Labor CommISSIoner 0 Ice

Step 4: Fill in the information requested on page 4 in Item complete Item IV. Sign the declaration.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Casamverslieet . . Typeiof; tion"  . . . 
:?3.C?tescry N05, . -.
Auto (22) El A7100 Motor Vehicle - Personal Injury/Property Damage/Wrongful Death 1., 2.. 4
?5 

Uninsured Motorist (46) El A7110 Personal Injury/Property Damage/Wrongful Death Uninsured Motorist 1.. 2.. 4.
El A6070 Asbestos Prope Dame 2.
Asbestos (04) 
E. A7221 Asbestos - Personal Death
a 0
g' 2 Product Liability (24) El A7260 Product Liability (not asbestos or toxiclenvironmentalA7210 Medical Malpractice- Physicians Surgeons 1..
Medical Malpractice (45)
A7240 Other Professional Health Care Malpractice 1..

i: I-
0
El A7250 Premises Liability and fall) 1
Other ..
Personal injury El A7230 Intentional Bodily injury/PropeIty Damage/Wrongful Death 1?
5 3 propeny Damage assault, vandalism. etc.)
El A7270 Intentional ln?iction of Emotional Distress 1"
El A7220 Other Personal Injury/Property Damage/Wrongful Death 1" 4'
LACIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASC Approved 03.04 AND STATEMENT OF LOCATION Page 1 of4

 at

 

 

SHORT TITLE:

JAFA-BODDEN V. CHOUDHURY ET AL

CASE NUMBER

 

 

Non-Personal Injury] Property
Damage! Wrongful Death Tort

Employment

Contract

Real Property

Unlawful Detainer

 

   

  
  

    
      

     

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A. msh'ee TypiiofAbtion I 
?11272} . 9811999)  ri?i-ig?i 
Business Tort (07) El A6029 Other CommerciallBusiness Tort (not fraud/breach of contract) 1., 3.
Civil Rights (08) A6005 Civil Rightleiscrimination 1.. 2.. 3
Defamation (13) El A6010 Defamation (slander/libel) 1.. 2.. 3
Fraud (16) El A6013 Fraud (no contract) 1.. 2.. 3
El A6017 Legal Malpractice 1.. 2., 3.
Professional Negligence (25)
El A6050 Other Professional Malpractice (not medical or legal) 1.. 2.. 3.
Other (35) El A6025 Other Non-Personal Injury/Property Damage tort 2..3.
Wrongful Termination (36) la A6037 Wrongful Termination 1.. 2.. 3.
El A6024 Other Employment Complaint Case 1.. 2., 3.
Other Employment (15)
Labor Commissioner Appeals
El A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful 2 5
eviction) 
Breach Warran
(06) A6008 ContracWVarranty Breach -Seller Plaintiff (no fraud/negligence) 2" 5'
(not insurance) El A6019 Negligent Breach of ContractIWarranty (no fraud) 1" 2" 5?
El A6028 Other Breach of Contract/Warranty (not fraud or negligence) 1" 2" 5'
El A6002 Collections Case-Seller Plaintiff 2.. 5.. 6.
Collections (09)
El A6012 Other Promissory Note/Collections Case 2.. 5.
Insurance Coverage (18) El A6015 Insurance Coverage (not complex) 1.. 2.. 5., 8.
El A6009 Contractual Fraud 1.. 2.. 3., 5.
Other Contract (37) A6031 Tortious Interference 1.. 2.. 3.. 5.
El A6027 Other Contract Dispute(not 1.. 2.. 3.. 8.



 

 

 

 

Eminent Domain/Inverse .
Condemnation (14) El A7300 EmmentDomaln/Condemnation Number of parcels 2.
Wrongful Eviction (33) El A6023 Wrongful Eviction Case 2.. 6.
El A6018 Mortgage Foreclosure 2.,
Other Real Property (26) El A6032 Quiet Title 2..
El A6060 Other Real Property (not eminent domain. landlord/tenant. foreclosure) 2.. 6.

 

 

 

1

 

 

 

 

 

 

I

 

 

Unlawful Detainer-Commercial

41

 

4?1

 

#14?

 

 

 

 

 

(31) El A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2., 6.

un'awm' Beggir'Residen?a' El A6020 Unlawful Defamer-Residential (not drugs or wrongful eviction) 2.. 6.
Unlawful Detainer-

Post_Foreclosure (34) El A6020F Unlawful Detainer?Post-Foreclosure 2., 6.

Unlawful Detainer-Drugs (38) El A6022 Unlawful Detainer-Drugs 2.. 6.



 

 

 

LACIV 109 (Rev. 03l11)
LASC Approved 03-04

CIVIL CASE COVER SHEET ADDENDUM

AND STATEMENT OF LOCATION

Local Rule 2.0

Page 2 of 4

 Mt.

 

 

SHORT TITLE:

JAFA-BODDEN V. CHOUDHURY ET AL

CASE NUMBER

 

 

Judicial Review

 

 

 

     

  

 

 

 

 

 

 

 

 

iivain?ti. ,0 9 vs?  
. Check onlyjone): . .  
Asset Forfeiture (05) El A6108 Asset Forfeiture Case 2.. 6.
Petition re Arbitration (11) I: A6115 Petition to CompellConiirmNacate Arbitration 2.. 5.
CI A6151 Writ - Administrative Mandamus 2.. 8.
Writ of Mandate (02) El A6152 Writ - Mandamus on Limited Court Case Matter 2.
El A6153 Writ - Other Limited Court Case Review 2.
Other Judicial Review (39) El A6150 Other Writ [Judicial Review 2.. 8.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Antitrusth rade Regulation (03) El A6003 Antitrusth rade Regulation 1.. 2.. 8
1?3
.3.) Construction Defect (10) El A6007 Construction Defect 1.. 2.. 3
3
. .
?Wm? Mass El A6006 Claims Involving Mass Tort 1.. 2., 


2. Securities Litigation (28) A6035 Securities Litigation Case 1.. 2.. 8
i=6
Toxic Tort -

Environmenm (30) El A6036 Toxic Tort/Envrronmental 1.. 2.. 3.. 8.

2 Insurance Coverage Claims .
D- mm Complex Case (41) El A6014 Insurance Coverage/Subrogatlon (complex case only) 1.. 2.. 5.. 8.
A6141 Sister State Judgment 2.. 9.
El A6160 Abstract of Judgment 2.. 6.
5, Enforcement El A6107 Confession of Judgment (non-domestic relations) 2.. 9.
5 3 0? JUdgmem (20) A6140 Administrative Agency Award (not unpaid taxes) 2.. 8.
IE '3 A6114 Petition/Certi?cate for Entry of Judgment on Unpaid Tax 2.. 8.
El A6112 Other Enforcement of Judgment Case 2.. 8., 9.
8 RICO (27) El A6033 Racketeering (RICO) Case 1.. 2.. 8.
3 
l:l A6030 Declaratory Relief Only 1.. 2., 6.
8 Other Complain?; El A6040 Injunctive Relief Only (not domesticlharassment) 2.. 8.
3 (N?tsp??'?ed Am?) (42) El A6011 Other Commercial Complaint Case (non-tortlnon-complex) 1.. 2.. 8.
l:l A6000 Other Civil Complaint (non-tortlnon-complex) 1.. 2.. a.


Partnership Corporation .
Governance (21) El A6113 and Corporate Governance Case 2.. 8.
a El A6121 Civil Harassment 2.. 3.. 9.

3 Cl A6123 Workplace Harassment 2omer Pemions El A6 derlDependent Adult Abuse Case 2 3 9
(Not Speci?ed Above) El A6190 Election Contest 2.
(43) El A6110 Petition for Change of Name 2.. 7.
El A6170 Petition for Relief from Late Claim Law 2.. 3.. 4.. 8.
A6100 Other Civil Petition 2.. 9.
LACIV 109 (Rev. 03/11) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.0
LASC Approved 03-04 AND STATEMENT OF LOCATION Page 3 of 4

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Carla V. Minnard, Esq. (CSB No. l760l5) 
THE MINNARD LAW FIRM 
4100 REDWOOD ROAD, #145 SUPER Reogsm?? -
OAKLAND, CA 94619 
(415) 2154115 Telephone JUN .313
(415) 358-5588 Facsimile -
carlaminnardcawmnet JoImA.Clarke Execuilm

Bv?zgaiwn .
my Flore!

Attorneys for Plainti??
MINAKSHI JAFA-BODDEN

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF LOS ANGELES

L.P., BIKRAM INC., USA YOGA
FEDERATION, BIKRAM CHOUDHURY
YOGA, INC., PETRA STARKE, individually
and as President of Bikram?s Yoga College of
India. and DOES 1 through 25, inclusive,

UNRUH CIVIL RIGHTS ACT 
CIVIL CODE ?511

. UNFAIR COMPETITION BUS.
PROF. CODE ?l7200 ET. 

. TORTIOUS INTERFERENCE WITH
BUSINESS RELATIONSHIPS

. DEFAMATION

9. INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS

JAFA-BODDEN, Case No
PlaintiffCOMPLAINT FOR DAMAGES
. 1. GENDER DISCRIMINATION
BIKRAM CHOUDHURY, IndIVIdually and 
as President of Bikram Choudhury Yoga Inc., 3 2. SEXUAL HARASSMENT
Chairman and CEO of Bikram?s Yoga
Giggle of India, LIE, and as President of 3' RETALIATION
1, Inc., RAJA HREE CHOUDHUR 
individually and as President of USA YOGA 4' FAILURE To PREVENT 
FEDERATION, Vice President of CORRECT DISCRIMINATION
YOGA COLLEGE OF INDIA,
LP. and as Vice President o?Bl?kram Inc., I AND HARASSMENT
BIKRAM YOGA COLLEGE OF INDIA 5. SEXBASED DISCRIMINATION 



Defendants.


3


3





COMPLAINT FOR DAMAGES
- I

 






 

 

10.

ll.
12.

13.
14.

15.

16.

17.

18.

19.
20.

21.

22.

23.

NEGLIGENT INFLICTION OF
EMOTIONAL DISTRESS
NEGLIGENCE

NEGLIGENT HIRING, RETENTION
SUPERVISION

ASSAULT

WRONGFUL TERMINATION IN
VIOLATION OF PUBLIC POLICY
BREACH OF CONTRACT
BREACH OF THE COVENANT OF
GOOD FAITH FAIR DEALING
FAILURE TO FURNISH WAGE 
HOUR STAEMENTS [California
Labor Code 226]

FAILURE TO PAY EARNED
WAGES UPON TERMINATION OF
EMPLOYMENT LABOR
CODE 201, 202, 203]
CONVERSION

FAILURE TO MAINTAIN
ACCURATE PAYROLL RECORDS
LABOR CODE 226]
RETALIATORY DISCHARGE 
LABOR CODE 98.6 et. seq]
VIOLATION OF THE BANE ACT
CIVIL CODE 52.1]
VIOLATION OF THE RALPH ACT
CIVIL CODE 51.7]

24. SEXUAL HARASSMENT IN

VIOLATION OF THE UNRUH

COMPLAINT FOR DAMAGES

-2

 






 

CIVIL RIGHTS ACT CIVIL
CODE 51.9]
25. CIVIL CONSPIRACY

 

 

 

Plaintiff MINAKSHI JAFA-BODDEN complains against Defendants BIKRAM
CHOUDHURY, RAJASHREE CHOUDHURY, YOGA COLLEGE OF INDIA
L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY YOGA, INC.,
PETRA STARKE, and DOES 1 through 25 as follows:

PARTIES

1. Plaintiff MINAKSHI JAFA-BODDEN (hereina?er, ?Jafa-
Bodden,? or ?Plaintiff?) was a resident of Beverly Hills, California in the County of Los
Angeles at all times material to this complaint. Plaintiff holds advanced degrees in Legal
Studies and Law including a Bachelor of Law Degree from University of Birmingham at
Edgbaston, England and St. Aldates College, Oxford, England. Plaintiff served as Head of
Legal and International Affairs for Bikram?s Yoga College of India and performed services for
Bikrarn Choudhury, Rajashree Choudhury and all of the listed entity defendants 
YOGA COLLEGE OF INDIA L.P., BIKRAM INC., USA YOGA FEDERATION, and
BIKRAM CHOUDHURY YOGA, INC., collectively referred to as ?Bikram entities? or ?entity
defendants?) from Spring, 2011 to March 1, 2013, when she was abruptly and unlawfully
terminated. At all times herein relevant, each of the Bikram entities employed more than 5
employees within the State of California.

2. Defendant Bikram Choudhury (hereafter ?Choudhury?) is an individual
and a resident of Beverly Hills, California in the County of Los Angeles at all times material to
this complaint.

3. Defendant Raj ashree Choudhury is an individual and a resident of
Beverly Hills, California in the County of Los Angeles at all times material to this complaint.

4. Defendant Petra Starke (herea?er ?Starke?) is a resident of the State of

COMPLAINT FOR DAMAGES
- 3

 






 

 

   

California and is employed in the County of Los Angeles by a Bikram entity.

5. Defendant YOGA COLLEGE OF INDIA was a California
Limited Partnership and operated in the City and County of Los Angeles at all times material to
this complaint.

6. Defendant BIKRAM INC. is a Delaware Corporation doing business in
the State of California, County of Los Angeles.

7. Defendant BIKRAM CHOUDHURY YOGA, INC. is a California
Corporation doing business in the State of California.

8. Defendant USA YOGA FEDERATION is a non-pro?t organization and
entity doing business in the State of California which entity is founded and led by Defendant
Rajashree Choudhury.

9. The true names and capacities, whether individual, corporate, associate
or otherwise, of Defendants Does 1 through 25, are unknown to Plaintiff, who therefore sues
said Defendants by such ?ctitious names. Plaintiff will amend this Complaint by inserting the
true names and capacities of each such Defendant, with appropriate charging allegations, when
they are 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.

10. Plaintiff is informed and believes and thereon alleges that at all times
material to this Complaint, Defendant and each of the defendants ?ctitiously 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 ratified by each and all of the defendants. Speci?cally,

COMPLAINT FOR DAMAGES
- 4

 






 

 

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 speci?c defendants were approved, rati?ed and done with the cooperation and knowledge
of each and all of the defendants.

11. The allegations of this Complaint stated on information and belief are
likely to have evidentiary support a?er a reasonable opportunity for further investigation and
discovery.

MILE

12. Venue is proper in Los Angeles County because the Bikram entity
Defendants conduct business in this county, or have done business during the times related
herein, in the City and County of Los Angeles. Defendant Bikram Choudhury, individually
and as a managing agent of the Bikram entity defendants, committed acts causing harm to
Plaintiff primarily in the State of California. Defendant Rajashree Choudhury, individually and
as a managing agent of the Bikram entity defendants, committed acts causing harm to Plaintiff
primarily in the State of Califomia. Defendant Petra Starke as an employee and managing
agent of the Bikram entity defendants, committed acts causing harm to Plaintiff primarily in the
State of California.

EXHAUSTION OF ADMINISTRATIVE REMEDIES

1th

13. On or about June 1 2013, plaintiff ?led a charge of discrimination, retaliation

and harassment with the Department of Fair Employment and Housing On or

2013, plaintiff received a Notice of Case Closure, together with a Right-To-

about June 1
Sue Notice, a copy of which is attached hereto as Exhibit A.
SUMMARY OF FACTS CLAIMS
14. In or about Spring of 201 1, Plaintiff was induced to leave her job in India to

come to Los Angeles and work for Defendant Bikram Choudhury and the Bikram entities.

COMPLAINT FOR DAMAGES
- 5

 






 

 

15. She was offered and accepted a three-year contract with a starting annual salary
of $125,000.00. (Exhibit hereto is a true and correct copy of Bikram Choudhury?s August
30. 2011 offer letter).

16. In March 2011, Plaintiff relocated her home and her young daughter from
Delhi, India in to Los Angeles, California to serve as Head of Legal and International Affairs
for Bikram Choudhury and the Bikram entities.

17. Despite the promise and contract to pay a starting annual salary of $125,000.00,
Defendants failed to pay Plaintiff as agreed.

18. From almost the beginning of her employment Plaintiff was subject to severe,
ongoing, pervasive and offensive conduct by Defendant Bikram Choudhury. Such conduct
included, among other things:

- Bikram Choudhury repeatedly referring to women, including female employees
and others as ?bitches,? ?fucking bitches,? ?fat bitches? and ?stupid bitches;?

- Bikram Choudhury repeatedly made offensive and vulgar sexual gestures
including placing his ?ngers in a circle and inserting the ?ngers of his other hand into them,
simulating intercourse; licking his ?ngers, sticking his ?ngers in the air and licking them,
simulating oral sex;

- Bikram Choudhury repeatedly made disparaging remarks about single mothers,
including myself, and stated to a co-worker ?make sure we don?t hire single women with kids
in the future;?

- Bikram Choudhury created a hyper-sexualized, offensive and degrading
environment for women by, among other things, demanding that female staffers brush his hair
and give him massages. Plaintiff was often required to conduct business meetings with Bikram
Choudhury while he was receiving such massages. Plaintiff was on a number of occasions
required to meet Bikram Choudhury in his hotel room typically at night. During one such
meeting, Bikram Choudhury climbed into bed, and patted the bedspread next to him (indicating

COMPLAINT FOR DAMAGES
- 6

 






 

 

to Plaintiff to come and sit/lie down next to him in the bed). Plaintiff moved away from
Choudhury and the bed and went and sat at a desk to conduct a telephone conference.

- Bikram Choudhury frequently leered at female staffers and others, and o?en
stared at and remarked on their physical attributes, including stating such offensive comments
as ?that bitch is too skinny,? or to Plaintiffs assistant ?you look good sweetheart but what
shall we do about her [gesturing to Plaintiff] she is still too fat.?

- Bikram Choudhury made outrageous and offensive comments about
homosexuals, including is caused by gays, it is the truth,? and ?but these flleng
asshole guys love me, they love Bikram;?

- Bikram Choudhury made outrageous and offensive comments about African
Americans, including ?these blacks just don?t get my yoga;? He also targeted A?ican
American studio owners and students, treating them differently than non-A?ican American
owners/students.

- Bikram Choudhury made outrageous and offensive comments about Jewish
people, including saying Hitler had the right idea, but that he ?was just not efficient enough. If
he was more ef?cient, all these fucking Jews would be f1nished;?

- Bikram Choudhury frequently brought his mistress to the workplace and
?aunted her, despite the fact that he knew this made me extremely uncomfortable given my
close relationship with his wife, Rajashree Choudhury. Bikram Choudhury pressured Plaintiff
into secretly purchasing a property in Hawaii for his mistress.

0 Bikram Choudhury repeatedly to female yoga studio owners as ?bitches;? and
referred to one particular female studio owner in Los Angeles as ?that fucking stupid Korean
bitch;?

Bikram Choudhury often would call for young women yoga students/trainees to
be brought up to his hotel room. When Plaintiff objected to this practice out of concern for the
safety and security of the young women, she was retaliated against and pushed out of Bikram

Choudhury?s ?inner circle.? One such example of Bikram Choudhury?s predatory and illegal

COMPLAINT FOR DAMAGES
- 7

 






 

 

behavior took place during the Spring 2012 Teacher Training in Los Angeles at the Radisson
Hotel. One young female trainee asked for permission to go home because she felt intimidated
and shocked by the sexually charged atmosphere. One of Bikram?s senior staffers re?ised to let
her leave, telling her that she must FIRST go to Bikram?s hotel room that night and talk to him.
Once Plaintiff learned of this, she immediately instructed staff that this was not permissible or
appropriate and that it must never happen again.

- Bikram Choudhury also permitted and encouraged his male ?iends from
overseas to treat his female staff and students as if they were chattels there for his and his
friend?s enjoyment, sexual grati?cation and pleasure.

- Bikram Choudhury also pressured

The foregoing is just a sample of Defendant Bikram Choudhury?s improper, illegal,
wrongful conduct, and not an exhaustive list.

19. Plaintiff attempted to investigate an incident that was reported by a female
student seeking readmission to the Fall 2012 Teacher Training, which involved her claim that
she had been raped at an earlier Training (Plaintiff believes Spring 2012) and had been sent
home. Plaintiff was told to stay out of it and not investigate.

20. Plaintiff also attempted to investigate the mistreatment of another female student
trainee at the Fall 2012 Teacher Training by a friend of Bikram Choudhury?s and another male
trainee. During that investigation, Plaintiff withheld the male trainee?s teaching certi?cate
pending the outcome of the investigation. When Bikram Choudhury found out that Plaintiff
was investigating the incident and had withheld the male trainees? certi?cate, Bikram angrily
demanded that Plaintiff stop her investigation and give him his certi?cate, stating ?those boys
didn?t do nothing to that stupid girl.?

21. Another female staffer reported to Plaintiff that a female trainee in Acapulco
reported that Bikram had done something ?of a sexual nature? to her during that training.
Thereafter, Plaintiff was later told that it was ?resolved? and that it was ?best? if she ?not look

into it any ?rrther.?

COMPLAINT FOR DAMAGES
- 8

 






 

 

 

22. When former CEO Mark Sacks was ?red, all of his duties were pushed onto
Plaintiff, with no additional compensation or assistance.

23. Plaintiff also was treated in an offensive and threatening way by Bikram
Choudhury?s driver, Sando Panday. As but one example of this, when Plaintiff instructed
Panday that the temperature in the yoga room must not exceed 105 degree Fahrenheit (which
had reached 120 degrees on numerous occasions which caused complaints and created a
dangerous and unsafe condition for those in the room), Panday screamed at Plaintiff ?Bikram
said to tell you to mind your own ?icking business.? Plaintiff complained about this attack to
Rajashree Choudhury and to another individual. Nothing was done, and Plaintiff was further
marginalized and retaliated against for daring to question Bikram Choudhury.

24. In or about February, 2012, Bikram Choudhury?s conduct, harassment,
discrimination and retaliation escalated, and Bikram threatened to have Plaintiff put in jail
because he was apparently displeased with the way she handled an endorsement deal (which he
later then complimented Plaintiff on, saying it was a great business deal for him and requested
repeatedly that Plaintiff ?put the water deal back together.?

25. In Summer 2012, when Plaintiff explained to Bikram Choudhury that he was
compelled by a Court to present himself for a deposition, he yelled at her and berated her
stating am famous. Famous people don?t do fucking depositions? and he referred to
Plaintiff?s lawyer in that case as ?that ?icking bitch.?

26. In or about November, 2012, Defendant Petra Starke ?rst began appearing and
getting involved in the Bikram entities business dealings and attending business meetings.
Plaintiff questioned whether this was not a con?ict of interest and potentially illegal conduct
given that Ms. Starke was then employed by the US. Government as White House Counsel.
Plaintiffs concerns were ignored.

27. Plaintiff believes, and on that basis alleges, that Defendant Petra Starke was
engaged in the business and business dealings of Bikram Choudhury and the Bikram entities at

the same time she was employed by the US. Government as Counsel to the White House.

COMPLAINT FOR DAMAGES
- 9

 






 

 

 

(o 

Numerous documents and records, including telephone records and electronic communications,
show this involvement. Plaintiff believed that this was ethically improper and possibly
criminal conduct and expressed her concerns to Defendants but those concerns were ignored.

28. Defendant Bikram Choudhury also engaged in physically intimidating and
threatening conduct, including pointing his ?nger in the shape of a gun and demonstrating like
he was shooting Plaintiff.

29. Defendant Rajashree Choudhury (an Of?cer of various Bikram Entity
Defendants named herein) knew that much of this abusive, illegal, threatening, harassing and
discriminatory conduct was taking place but she did nothing to prevent or curtail it. She also
knew that young female yoga trainees and students were potential victims of her husband
Bikram Choudhury and endangered by his presence, and in fact discussed that very subject
with Plaintiff, but she did nothing whatsoever to prevent or restrain her husband.

30. During the course of coordinating the defense of Bikram Choudhury and the
Bikram entities in other lawsuits, Plaintiff kept Bikram Choudhury up to date on the litigation
and status. At one such time, when Plaintiff informed Bikram Choudhury that a witness had
testi?ed in a manner that was unhelp?il to him and was ?against? him, Bikram demanded that
Plaintiff contact the witness and intimated that she should be pressured to keep quiet. When
Plaintiff refused, Bikram became angry and further retaliated against Plaintiff.

31. Defendant Bikram Choudhury also made threatening statements about a Federal
Court Judge who issued a ruling that was unfavorable to Bikram Choudhury and the Bikram
entities. Defendant Bikram Choudhury made references to having the Judge ?taken out? and
?removed,? and Bikram Choudhury stated in the presence of witnesses including
Rajashree Choudhury and Petra Starke that he would ?handle [the Judge] his own way.?

32. Defendant Bikram Choudhury also directed Plaintiff to begin a smear campaign
against a male studio owner that he was involved in a lawsuit with. Bikram Choudhury told
Plaintiff that she needed to accuse that studio owner of sexual misconduct, including being a

?rapis Plaintiff refused and the retaliation against her continued to escalate.

COMPLAINT FOR DAMAGES
- 10

 






 

 



33. When Plaintiff told Bikram Choudhury that certain of his ?marketing? materials
likely constituted false advertising, she was further retaliated against.

34. At or about the end of 2012, in or about November, Plaintiff complained to
Rajashree Choudhury that Bikram Choudhury was becoming more and more abusive.
Defendant Rajashree Choudhury stated that Bikram was telling people that Plaintiff was
?having an affair? with one of the attorneys she had retained to do work defending Bikram and
the Bikram entities.

35. Also at or near the end of 2012, Plaintiff became increasingly vocal about the
fact that she was not being paid as agreed upon despite the fact that she had been working for
almost 2 years.

36. All of the retaliation, harassment and discrimination against Plaintiff came to a
head on March 2013, when she was terminated. The afternoon of March 2013, Plaintiff
was told by Bikram that she could not go home early that day (she normally went and picked
her daughter up from school which Bikram knew). At approximately 6:00 pm, Plaintiff was
summoned to Bikram Choudhury?s of?ce by Defendant Petra Starke. During that meeting,
Plaintiff was told ?we have decided to terminate you immediately,? and ?we will withdraw
your green card sponsorship.? She was then told that she could either resign immediately, or be
?red. During this ?meeting? Bikram Choudhury accused Plaintiff of having a sexual
relationship with one of the attorneys hired to defend Bikram and the Bikram entities (Robert
Gilchrest), and Bikram made a sexual gesture stating ?iat Plaintiff and ?Bob? were ?closer than
husband and wife.? Plaintiff stated that she did not want to resign. Plaintiff was again told
that if she did not resign immediately, right then, she would be terminated and that it ?would be
very bad for her.? The entire environment was extremely hostile and threatening, and Plaintiff
feared for her own safety as well as the safety of her daughter. She was then ordered to go to
her ?room? and type her resignation letter. Plaintiff stated that she would hand write it, which

she did, handing it to Petra Starke.

COMPLAINT FOR DAMAGES
- 11

 




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37. Shortly after she was terminated/forced to resign, Defendants evicted Plaintiff
from her home and repossessed her car without her knowledge or permission.

38. The Bikram entity defendants, and individual defendants knew or should have
known about Bikram Choudhury?s propensity to engage in discriminatory and harassing
conduct against women. In fact, the subject of the risk posed to young girls by Bikram
Choudhury was speci?cally discussed with and known to his wife, Defendant Raj ashree
Choudhury. Defendant Rajashree Choudhury asked Plaintiff to keep Bikram Choudhury away
?om a yoga competition being held in New York in 2013 (as well as in prior years) because of
a concern for the safety and well being of the young girls if Bikram Choudhury were permitted
to be around them.

39. Defendants Petra Starke and Raj ashree Choudhury engaged in a civil conspiracy
with Bikram Choudhury and others to keep Bikram Choudhury?s illegal conduct from being
discovered and in an effort to retaliate against anyone who attempted to speak up against it or
bring it to light. Defendant Bikram Choudhury and other defendants have engaged in a
campaign of civil conspiracy that began when Plaintiff objected to illegal conduct and when
Plaintiff attempted to uncover the truth of various allegations of sexual misconduct leveled
against Bikram Choudhury.

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 ?le suit and she, therefore, has incurred and will continue to incur substantial
attorneys fees and costs.

FIRST CAUSE OF ACTION

(GENDER DISCRIMINATION - Against Defendants YOGA
COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION,
BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25 

40. The allegations set forth in paragraphs 1 through 39 above are re-alleged and

incorporated herein by reference as if fully set forth.

COMPLAINT FOR DAMAGES
- 12

 






 

(M 

41. Plaintiff is and was, at all time material herein, a female and therefore protected
under California?s Fair Employment and Housing Act, California Government Code, ?12940 et
seq. Plaintiff exhausted her administrative remedies and obtained a Right-To-Sue letter as
required by the EHA.

42.
the requirements of the FEHA, and had a duty under the FEHA not to discriminate against

Defendants, at all material times herein, were Plaintiff?s employers subject to

plaintiff based on her gender.
43. Defendants know that Plaintiff is female but, in violation of FEHA,
discriminated against plaintiff and harassed her by subjecting her and her female co-workers to
hostile and offensive comments and conduct, treating her unfavorany and adversely compared
to similarly situated male employees, and by denying her pay and bene?ts as promised.
44. Defendants? acts in discriminating against plaintiff based on her gender was
wanton, willful, intentional, malicious, oppressive and betrayed a reckless disregard for the
rights and sensibilities of plaintiff, thus entitling plaintiff to an award of punitive damages.
45. As a direct and proximate result of defendants? discrimination against plaintiff
based on gender, plaintiff has sustained and continues to sustain injury in the form of loss of
pay and bene?t, emotional distress, humiliation, embarrassment and mental anguish, all to her
damages in an amount to be established at trial, but exceeding, in any event, the minimum
amount needed to qualify for assignment to the Unlimited Jurisdiction calendar of this Court.

SECOND CAUSE OF ACTION
(SEXUAL HARASSMENT Against Defendants BIKRAM CHOUDHURY, 

YOGA COLLEGE OF INDIA, L.P., BIKRAM IN C., USA YOGA FEDERATION,
BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)

46. The allegations set forth in paragraphs 1 through 45 above are re-alleged and
incorporated herein by reference as if fully set forth.

47. Plaintiff is and was, at all time material herein, a woman and therefore protected
under California?s Fair Employment and Housing Act, California Government Code, ?12940 et

seq. Plaintiff exhausted her administrative remedies and obtained a Right-To-Sue letter as

COMPLAINT FOR DAMAGES
- l3

 

 



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performance, failing to pay her wages due and, eventually, forcing her to resign or be
terminated as set forth more fully hereinabove.

54. Defendants? acts in retaliating against plaintiff for objecting to illegal,
discriminatory and harassing conduct were wanton, willful, intentional, malicious, oppressive
and betrayed a reckless disregard for the rights and sensibilities of plaintiff, thus entitling
plaintiff to an award of punitive damages.

5 5. As a direct and proximate result of defendants? unlawful retaliation against
plaintiff, plaintiff sustained and continues to sustain injury in the form of loss of pay and
bene?ts, emotional distress, humiliation, embarrassment and mental anguish, all to her damage
in an amount to be established at trial, but exceeding, in any event, the minimum amount
needed to qualify for assignment to the Unlimited Jurisdiction calendar of this Court.

FOURTH CAUSE OF ACTION

(FAILURE TO PREVENT DISCRIMINATION HARASSMENT Against
YOGA COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA

FEDERATION, BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)

56. The allegations set forth in paragraphs 1 through 55 above are alleged and
incorporated herein by reference as if fully set forth. 7

57. Plaintiff is informed and believes and thereon alleges that Defendants named
herein failed to take all steps reasonably necessary to prevent discrimination and harassment
from occurring. Such conduct violates Government Code, ?12940(k).

58. Such failure to act in violation of FEHA caused Plaintiff to be harassed and
discriminated against, as set forth more hereinabove.

59. Defendant?s conduct legally and directly caused Plaintiff to suffer damages,
including but not limited to, emotional distress damages, in excess of the minimum
jurisdiction of this Court subject to proof at the time of trial.

60. The aforepled conduct constitutes oppression, fraud or malice thereby entitling

plaintiff to an award of punitive damages. Defendants, acting through an officer, director or

COMPLAINT FOR DAMAGES
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managing agent authorized or rati?ed the aforepled conduct giving rise to punitive damages,

or was personally guilty of oppression, fraud or malice.

FIFTH CAUSE OF ACTION

(SEX BASED DISCRIMINATION IN VIOLATION OF THE UNRUH CIVIL RIGHTS
ACT CIVIL CODE ?511 - Against YOGA COLLEGE OF INDIA, L.P.,
BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY YOGA, INC.
and DOES 1 through 25)

61. Plaintiff incorporates by reference as though set forth herein, each and
every allegation set forth above in this Complaint. As a ?fth, separate and distinct cause of
action, Plaintiff complains against Defendants as follows:

62. Civil Code section 51, et seq., also known as ?The Unruh Act,? provides that all
persons in the state are entitled to the ?full and equal accommodations, advantages, facilities,
privileges, or services in all business establishments of every kind whatsoever,? regardless of
sex.

63. Plainti?? is informed and believed and thereon alleges that the aforementioned
conduct of defendants, and each of them, denied, aided, or incited in a denial of, discriminated
or made a distinction that denied plaintiff full and equal advantages, privileges, and services to
Plaintiff, based solely upon plaintiff?s sex, and therefore constituted a violation of the Unruh
Act.

64. As a proximate result of the wrongful actions of defendants, and each of them,
Plaintiff has suffered harm, including but not limited to, lost earnings and other employment
bene?ts, loss of ?Iture employment bene?ts, including insurance and pension, humiliation,
embarrassment, mental anguish, and physical harm, all in an amount to be proven at trial but
exceeding the minimum jurisdictional limits of this court.

65. Plaintiff is further informed and believes, and based thereon alleges, that
defendants, and each of them, acted and continue to act, with full knowledge of the

consequences and damage being caused to plaintiff, by defendants? actions, and defendants?

COMPLAINT FOR DAMAGES
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actions were, and are, willful, oppressive, and malicious. Accordingly, plaintiff is entitled to

punitive damages against defendants, and each of them, in a sum according to proof at trial.

SIXTH CAUSE OF ACTION

(UNFAIR COMPETITION BUS. PROF. CODE
17200] - Against YOGA COLLEGE OF INDIA, L.P., BIKRAM INC., USA
YOGA FEDERATION, BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)?

66. Plaintiff incorporates by reference as though fully set forth herein, each and
every allegation set forth above in this Complaint. As a sixth, separate and distinct cause of
action, Plaintiff complains against Defendants as follows:

67.
Code section 17200 et seq., speci?cally Business and Professions Code section 17203, which

The court has jurisdiction over this action pursuant to Business and Professions

provides that any person who engages, has engaged, or proposes to engage in unfair
competition may be enjoined in any court of competent jurisdiction; and the court may make
such orders or judgments, including the appointment of a receiver, as may be necessary to
prevent the use or employment by any person of any practice which constitutes unfair
competition, or as may be necessary to restore to any person in interest any money or property,
real or personal, which may have been acquired by means of such unfair competition; and
Business and Professions Code Section 17204, which provides for actions for any relief
pursuant to the Unfair Competition Law to be prosecuted exclusively in a court of competent
jurisdiction by any board, of?cer, person, corporation or association or by any person acting for
the interests of itself, or its members and that has suffered an injury in fact and lost money or
property as a result of Defendant?s conduct.

68. Defendants have engaged in, and continue to engage in the following unlawful,
unfair and/or fraudulent business practices in violation of Section 17200 of the Califomia
Business and Professions Code: sex based discrimination in violation of Civil Code section 51,
et. Seq.; sexual harassment and gender discrimination in violation of section 21940 et seq of the

California Government Code; defamation; civil conspiracy, intentional in?iction of emotional

COMPLAINT FOR DAMAGES
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walO?MAwN?




 

 



distress; negligent in?iction of emotional distress; failure to pay wages due and owing; failure
to provide itemized wage statements as required by law; failure to maintain accurate payroll
records; retaliatory ?ring of plaintiff; and negligence.

69. As a direct, proximate, and foreseeable result of Defendant?s wrongful conduct
as alleged above, Defendant?s business acts or practices have caused injury to the Plaintiff and
the public. Plaintiff is entitled to relief, including full restitution and/or disgorgement of all
revenues, earnings, pro?ts, compensation and bene?ts that may have been obtained by
Defendants as a result of such business acts or practices.

70. Plaintiff is informed and believes and based thereon alleges that Defendant?s
illegal acts as described above are a serious and continuing threat to Plaintiff and the public. If
Defendant is allowed to continue its unfair and unlaw?ll acts, Plaintiff and the public will
suffer further immediate and irreparable injury, loss and damage. Plaintiff is further informed
and believes, and based thereon alleges, that, in the absence of a temporary restraining order
and preliminary and permanent injunctions as prayed for below, Defendant will continue to
unfairly and unlawfully compete.

SEVENTH CAUSE OF ACTION

(T ORTIOUS INTERFERENCE WITH BUSINESS RELATIONSHIPS -
Against All Defendants)

71. Plaintiff, individually, incorporates by reference as though fully set forth herein,
each and every allegation set forth above in this Complaint. As a seventh, separate and distinct
cause of action, Plaintiff complains against Defendants as follows:

72. Between March 2011 and March 2013, Plaintiff was Head of Legal and
International Affairs for Defendant Bikram Choudhury and the Bikram entities, and was
engaged in that work and relationship pursuant to numerous written agreements and a contract.
That relationship conferred a ?nancial bene?t upon Plaintiff.

73. Defendants knew of the above-described contracts and ?nancial relationships

existing between Plaintiff and the Defendants.

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74. Starting in 2012 and continuing to March 1, 2013, Defendant engaged in a
number of acts designed to intentionally disrupt the economic relationship between Plaintiff
and Defendant and between Plaintiff and her former colleagues in India, including Som
Mandal. In particular, as but one example, Defendant defamed Plaintiff by falsely accusing her
of having a sexual relationship with an attorney representing Bikram Choudhury and the
Bikram entities.

75. This conduct was wrongful for reasons other than that it constituted interference
with a prospective economic advantage. The conduct also violated the Unruh Civil Rights Act,
Civil Code section 51 et seq.; Business and Professions Code section 17200 (Unfair/Unlawful
Competition), section 12940 of the California Government Code, constituted an unlawful civil
conspiracy; was defamatory; constituted intentional and/or negligent in?iction of emotional
distress; and was negligent.

76. This conduct prevented Plaintiff from earning money that she otherwise would
have earned pursuant to that agreement and those contracts.

77. As a result of Defendant?s conduct and the prevention and/or disruption of the
contract between Plaintiff and Defendants, Plaintiff has suffered damages in an amount to be
proved at trial.

78. The aforementioned acts of Defendant were Will?ll and oppressive or fraudulent
or malicious. Plaintiff is therefore entitled to punitive damages.

79. Defendants threaten to, and unless restrained, will continue to disrupt other
business relationships between Plaintiff and potential employers, to Plaintiff?s great irreparable
injury, for which damages would not afford adequate relief, in that they would not completely

compensate for the injury to Plaintiff?s business reputation and goodwill.

COMPLAINT FOR DAMAGES
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EIGHTH CAUSE OF ACTION
(DEFAMATION - Against All Defendants)

80. Plaintiff incorporates by reference as though fully set forth herein, each and
every allegation set forth above in this Complaint. As an eighth, separate and distinct cause of
action, Plaintiff complains against Defendants as follows:

81. Plaintiff is informed and believes, and therefore alleges, that Defendants,
recklessly and intentionally caused excessive and unsolicited internal and external publications
of defamation, of and concerning Plaintiff, to third persons. These false and defamatory
statements included express and implied accusations that Plaintiff was incompetent in her
work, profession or trade and that she was engaging in improper and unethical sexual conduct
with another attorney.

82. These statements were defamatory per se insofar as they related to Plaintiffs
quali?cations in her profession and trade.

83. While the precise date of all these publications are not known to Plaintiff,
Plaintiff is informed and believe that these various publications started in or about Fall of 2012
and continued to the present, and that it was foreseeable that they would be re-published by the
Defendants and the non-privileged third parties to whom Defendants spread the defamatory
statements.

84. During the above-described time-frame, Defendants did negligently, recklessly
and intentionally cause excessive and unsolicited publication of defamation, of and concerning
Plaintiff, to third persons who had no need or desire to know. Those third persons to whom
Defendants published this defamation are believed to include, but are not limited to the other
Defendants named in this Action, and each of them, as well as the Doe Defendants.

85. The defamatory publications consisted or oral, knowingly false and unprivileged
communications, tending directly to injure Plaintiff and her personal, business and professional

reputation and to cast her in a false light.

COMPLAINT FOR DAMAGES
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86. In addition, Plaintiff has been compelled to self-disclose this false information
and these untrue statements. Plaintiff is informed and believes that because of the negligent,
reckless, and intentional publications made by Defendants, and each of them, that it was
foreseeable that these statements would be published and re-published.

87. Plaintiff is informed, believes and fears that these unprivileged defamatory
statements will continue to be published by Defendants and will be re-published by their
recipients, all to the ongoing harm and injury to Plaintiffs business, professional and personal
reputation.

88. The defamatory meaning of all the above-described, false and defamatory
statements and their reference to Plaintiff was understood by Defendants. These statements
were false and were understood as assertions of fact, and not as opinion.

89. Each of these false defamatory per se publications (as set forth above) were
negligently, recklessly, and intentionally published in a manner equaling malice and abuse of
any alleged conditional privilege. These publications, and each of them, were made with
hatred, ill will, and an intent to vex, harass, annoy, and injure Plaintiff in order to justify the
illegal and cruel actions of Defendants and to cause further damage to Plaintiff?s professional
and personal reputation, for the purpose of causing Plaintiff to be terminated and in retaliation
for her reporting and opposing discrimination and harassment.

90. Each of these publications by Defendants was made with the knowledge that no
investigation supported the unsubstantiated and false statements. Defendants published these
statements knowing them to be false and unsubstantiated by any reasonable investigation.

91. Not only did Defendants have no reasonable basis to believe these statements,
Defendant also had no belief in the truth of these statements and, in fact, knew the statements to
be false.

92. Defendants committed the despicable acts as herein alleged maliciously,
?'audulently, and oppressively, with the wronng intent of injuring Plaintiff, and have acted

with an improper and evil motive amounting to malice, and fraud and in conscious disregard of

COMPLAINT FOR DAMAGES
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(a 

Plaintiff?s rights. Because the despicable acts taken toward Plaintiff were carried out in a

deliberate, cold, callous and intentional manner in order to injure and damage Plaintiff, she is

entitled to recover punitive damages from Defendants in an amount according to proof.
NINTH CAUSE OF ACTION

(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS - Against All Defendants)

93. Plaintiff incorporates by reference as though fully set forth herein, each and
every allegation set forth above in this Complaint. As a ninth, separate and distinct claim for
relief, Plaintiff complains against Defendants:

94. This is an action for, among other things, damages pursuant to the common law
of the State of California as mandated by the California Supreme Court in the decision of Rojo
v. Kliger (1990) 52 Cal. 3d 65.

95. Defendants engaged in the extreme and outrageous conduct herein above alleged
with wanton and reckless disregard of the probability of causing Plaintiff to suffer severe
emotional distress.

96. As a proximate result of the extreme and outrageous conduct engaged in by
Defendant, Plaintiff suffered humiliation, mental anguish and extreme emotional and physical
distress all to her general damage in an amount according to proof at trial.

97. Defendants? conduct as herein alleged was malicious and oppressive in that it
was conduct carried on by Defendants in a will?il and conscious disregard of Plaintiff?s rights
and subjected her to cruel and unjust hardship. Plaintiff is therefore entitled to an award of
punitive damages against Defendants.

98. As a direct, foreseeable and legal result of Defendants? unlawful acts, Plaintiff
has suffered and continues to suffer substantial losses in earnings, bonuses and other
employment benefits, in addition to expenses incurred in obtaining alternative employment,
and has suffered and continue to suffer humiliation, embarrassment, severe mental and

emotional distress, and discomfort, all to Plaintiff?s damage in an amount to be proven at trial.

COMPLAINT FOR DAMAGES
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TENTH CAUSE OF ACTION
(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS - Against All Defendants)
99. Plaintiff, individually, incorporates by reference as though ?illy set forth herein,
each and every allegation set forth above in this Complaint. As a tenth, separate and distinct

cause of action, Plaintiff complains against Defendants as follows:

100. Defendants owed Plaintiff a duty of care not to cause her emotional distress.

101. Defendants breached this duty of care by way of their own conduct as alleged
hereinabove.

102. Defendants? conduct starting in 2011 and continuing in the present has caused

Plaintiff emotional distress.

103. As a proximate result of Defendants? extreme and outrageous acts, Plaintiff has
suffered emotional distress, humiliation and embarrassment.

104. Defendants? conduct has caused and continues to cause Plaintiff substantial
losses in earnings, signi?cant reputation and professional injury, medical expenses, future
earnings and bene?ts, costs of suit, embarrassment and anguish, all to her damage in an amount
according to proof.

ELEVENTH CAUSE OF ACTION
(NEGLIGENCE - Against All Defendants)

105. Plaintiff incorporates by reference as though set forth herein, each and
every allegation set forth above in this Complaint. As an eleventh, separate and distinct cause
of action, Plaintiff complains against Defendants as follows:

106. Defendants and Does 1-25 inclusive, in their individual and of?cial capacities,
owed a duty to Plaintiff to protect her from foreseeable harm and damage, and Defendants, and
each of them, committed the negligent actions and/or negligent failures to act, as set forth
herein above and those acts proximately cause the emotional, physical and ?nancial injuries

in?icted upon plaintiff.

COMPLAINT FOR DAMAGES
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107. Plaintiff brings this action and claim for damages from said Defendants for
negligent actions and failures to act, and the resulting injuries and damages.

TWELFTH CAUSE OF ACTION
(NEGLIGENT HIRING, RETENTION SUPERVISION Against YOGA

COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM
CHOUDHURY YOGA, INC. and DOES 1 through 25 

108. Plaintiff incorporates by reference as though fully set forth herein, each and
every allegation set forth above in this Complaint. As an eleventh, separate and distinct cause
of action, Plaintiff complains against Defendants as follows:

109. At all times relevant the defendant Bikram Choudhury was employed by the
Defendant Bikram entities. Defendant Bikram entities owed a duty to plaintiff as an employee
to adequately investigate Bikram Choudhury before hiring him, not to retain Bikram
Choudhury once they learned he was incompetent or un?t, adequately supervise Bikram
Choudhury and adequately train him.

110. Defendants breached said duties of care by hiring and retaining Bikram
Choudhury, despite their actual or imposed knowledge that he had engaged in sexually
inapprorpriate conduct in the past, including sexual harassment, sex discrimination, and various
other assaults and attacks upon women.

111. Plaintiff is further informed and believes and thereon alleges that Defendants also
negligently supervised and trained Bikram Choudhury by allowing him to engage in the
aforepled conduct. Not only was Bikram Choudhury not disciplined in any way that might
have curtailed his conduct, his conduct was sanctioned and condoned by those that were in
leadership and management roles in his organizations, including but not limited to Defendant
Rajashree Choudhury.

117. Defendants are liable for the conduct of Bikram Choudhury because they rati?ed
said conduct by continuing to employ him despite their knowledge of his propensities, failing
to ?illy investigate the plaintiff?s complaints and/or discipline Bikram Choudhury, and
retaining the him in a leadership and management role.

COMPLAINT FOR DAMAGES
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1 18. As a proximate result of this negligence as aforepled, plaintiff has been injured

and continues to suffer injury, damage and harm all to her detriment.

TI-IIRTEENTH CAUSE OF ACTION

(ASSAULT Against DEFENDANT BIKRAM CHOUDHURY)
119. Plaintiff realleges and incorporates paragraphs 1 through 118 as though fully set

forth herein.

120. Defendant Bikram Choudhury repeatedly acted in a manner that was physically
threatening and intimidating to Plaintiff. In or about June 2012, when at a car show, Defendant
Bikram Choudhury screamed at Plaintiff ?who gave her my fucking bag?? and he grabbed at
Plaintiff and yanked the bag from her. On another occasion Bikram Choudhury glared at
Plaintiff and made a slicing gesture across his throat, demonstrating or suggesting to Plaintiff
that he would slit her throat if she did not do what he had directed. On a this occasion,
Defendant Bikram Choudhury pointed his hand at Plaintiff in the manner of a gun, gesturing to
indicate that we was shooting at Plaintiff. The defendant, Bikram Choudhury, in undertaking
the acts set forth above placed the plaintiff in apprehension of a harmful or offensive contact.
This is particularly true given Defendant Bikram Choudhury?s other threats and conduct and
Plaintiff?s understanding and belief that he had the ability to carry them out. As but one
example, Bikram Choudhury bragged about having assaulted a realtor, punched him in the face,
broken his teeth and ?punched him out.? Plaintiff often heard Bikram Choudhury say angrily
to people ?don?t fuck with me!? and she had been told by a woman who shared commercial
space next to Bikram that he had physically threatened her and was ?behaving like a gangster.?
This is an illustrative, not exhaustive, list of assaultive conduct by Bikram Choudhury.

121. Plaintiff is informed and believes and thereon alleges that the defendant Bikram
Choudhury intended to and did place plaintiff in apprehension of a harmful or offensive
contact, and that defendant Bikram Choudhury had the ability to injure or harm plaintiff.

COMPLAINT FOR DAMAGES
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122. As a proximate result of this conduct all as aforepled, plaintiff did suffer and
continues to suffer severe emotional distress all to her general damages in an amount in excess

of the minimum jurisdiction of the court and according to proof.

FOURTEENTH CAUSE OF ACTION

(WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY 
Against YOGA COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA
FEDERATION, BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)

123. Plaintiff re-alleges and incorporates by this reference, as if set forth in full, each
and every allegation contained in paragraphs 1 through 122, inclusive, as set forth above.

124. By retaliating against and eventually terminating plaintiff for her complaints to
Defendants regarding her reasonable beliefs of illegal conduct and for her refusal to go along
with illegal conduct and for her attempts to prevent illegal and unsafe conduct from occurring
(such as Bikram Choudhury being left alone in hotel rooms with female trainees), Defendants
violated the public policies of the State of California, as those policies are designed to ensure
that employees may work in safe and healthful working conditions free from danger to their
lives, safety or health and shall not be retaliated against for making complaints when they
reasonably believe that laws are being violated, including, but not limited to, California Labor
Code ??6300, 6306, 6405 and 6406(b) related to health and safety in the workplace. See,
Franklin v. Monadnock C0. 151 Cal.App.4th 252, 59 Cal.Rptr.3d 692, Cal.App. (2007)
(employee's allegations were suf?cient to state a claim for wrongful termination based on the
public policies requiring employers to provide a safe and secure workplace and encouraging
employees to report credible threats of violence in the workplace, and employee's complaint
about co-worker's threats and report of assault to police inured to the bene?t of the public).

125. The adverse action (Plaintiff?s termination on March 1, 2013) directly resulted
in loss of past and future salary, payments that would have become available through any pro?t

sharing or other retirement plans, medical and dental bene?ts, and other losses to be proven at

trial.

COMPLAINT FOR DAMAGES
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126. As a direct and proximate result of Defendant?s unlawful conduct, Plaintiff has
suffered and will continue to suffer pain and suffering, mental anguish, emotional and physical
distress and injury, humiliation, anxiety, loss of earnings, past and future, and other
employment bene?ts and job opportunities in an amount to be determined at trial, all in excess
of the Court?s jurisdiction.

127. As more fully stated by the facts alleged above, the wrongful conduct committed
by defendants was done with a conscious disregard of plaintiff?s rights with the intent to vex,
injure, and annoy plaintiff so as to cause the injuries sustained by plaintiff which amount to
oppression, fraud and malice, as stated in California Civil Code ?3294. Plaintiff is, therefore,

entitled to punitive damages in an amount sufficient to punish defendants as decided by the
jury.
FIFTEENTH CAUSE OF ACTION
(BREACH OF CONTRACT Against BIKRAM CHOUDHURY, YOGA

COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM
CHOUDHURY YOGA, INC. and DOES 1 through 25)

128.
129.

Plaintiff incorporates the above paragraphs as if they were fully set forth herein.
Plaintiff had a contract for a three year term, which contract was not to be
terminated without cause. [Exhibit hereto].

130. Plaintiffs performance at all times, even after assuming the former CEO Mark
Sacks?s entire workload, was and continued to be outstanding. Plaintiff relied on the consistent
praise of her work, the recognition of her excellence, the conferring of additional
responsibilities, and the industry practice of for cause termination, to support her belief that her
contract of employment included a covenant that she could not be demoted or terminated in the
absence of good cause.

131. Plaintiff undertook and continued employment and duly performed all the

conditions of the Contract to be performed by her. Plaintiff has at all times been ready, willing

COMPLAINT FOR DAMAGES
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and able to perform and has offered to perform all the conditions of this Contact to be
performed by her.

132. As a proximate result of defendant's breach of the employment contract, plaintiff
has suffered and continues to suffer substantial losses in earnings, and other employment
bene?ts which she would have received had defendants not breached said agreement, all to her
damage in an amount which cannot be ascertained with certainty at this time since these

damages are ongoing and cumulative. Plaintiff is informed and believes that these damages will

substantially exceed the minimum jurisdictional requirements of this court.

SIXTEENTH CAUSE OF ACTION

(BREACH OF COVENANT OF GOOD FAITH FAIR DEALING - Against BIKRAM
CHOUDHURY, YOGA COLLEGE OF INDIA, L.P., BIKRAM INC., USA
YOGA FEDERATION, BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)!

133.
134.

Plaintiff incorporates the above paragraphs as if they were fully set forth herein.
The aforesaid employment contract contained an implied covenant of good faith
and fair dealing by which defendant promised to give full cooperation to plaintiff and her
performance under said employment contract and to refrain from doing any act which would
prevent or impede plaintiff from performing all the conditions of the Contract to be performed
by her, or any act that would interfere with plaintiff?s enjoyment of the fruits of said Contract.
Speci?cally, said covenant of good faith and fair dealing required that defendants fairly,
honestly and reasonably perform the terms and conditions of the agreement.

135. Defendants breached their covenants of good faith and fair dealing with plaintiff
by terminating her knowing full well that plaintiff was dependent on her job to support herself
and her young daughter) having induced her to relocate to the United States ?'om Delhi, India),
without conducting any reasonable investigation concerning its obligations under said Contract,

without good or suf?cient cause, for retaliatory and unlawful reasons extraneous to the

Contract, and for the purpose of frustrating plaintiffs enjoyment of the bene?ts of the Contract.

COMPLAINT FOR DAMAGES
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136. As a result of defendant?s violations of said implied covenant of good faith and
fair dealing, plaintiff has been damaged in that she has lost income, her ability to perform her
part of the employment agreement was impeded, she was portrayed to co?workers and upper
management as being ineffective or incompetent and held up to ridicule, all of which combined
to produce: destruction or impairment of plaintiffs valuable property interests, her prospect

of continuing ?iture employment with defendants and receipt of continued compensation; and

substantial losses in earnings, and other employment benefits.

SEVENTEENTH CAUSE OF ACTION

(FAILURE TO FURNISH WAGE HOUR STATEMENTS [California Labor Code

Section 226] Against BIKRAM CHOUDHURY, YOGA COLLEGE OF

INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY
YOGA, INC. and DOES 1 through 25)

137. Plaintiff incorporates by reference and re-alleges paragraphs 1 through 40,
inclusive, as though set forth fully herein.

138. California Labor Code section 226(a) provides that employers must furnish the
following information on employees? paystubs: (1) employer?s name and address, (2)
employee?s name and social security number, (3) inclusive dates for which employee is being
paid, (4) gross wages earned, (5) the applicable hourly rate and total hours worked for hourly
employees, (6) all deductions, and (7) net wages earned.

139. Defendants knowingly and intentionally failed to provide Plaintiff with timely
and accurate wage and hour statements and paystubs with the required information, and failed
to pay Plaintiff as agreed.

140. Plaintiff suffered injury as a result of Defendants? knowing and intentional
failure to provide her with the wage and hour statements required by law. Labor Code Section
226.3 provides that if an employer knowingly and intentionally fails to provide a statement
itemizing, among other things, the total hours worked by the employee, then the employee is

entitled to recover the greater of all actual damages or ?fty dollars for the initial violation

COMPLAINT FOR DAMAGES
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and one hundred dollars ($100) for each subsequent violation, up to four thousand dollars
($4000). Defendants are also liable for civil penalties for late payments pursuant to Labor
Code Sections 226.3, 226(e) and 2698 et seq. in the amounts set forth therein.

141. In committing the foregoing acts, Defendants were guilty of Oppression, fraud or
malice, and, in addition to the actual damages caused thereby, Plaintiff is entitled to recover

damages for the sake of example and by way of punishing Defendants.

EIGHTEENTH CAUSE OF ACTION

(FAILURE TO PAY EARNED WAGES UPON TERMINATION OF EMPLOYMENT
LABOR CODE 201, 202, 203] Against BIKRAM CHOUDHURY, 
YOGA COLLEGE OF INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION,
BIKRAM CHOUDHURY YOGA, INC. and DOES 1 through 25)

142. Plaintiff incorporates by reference and re-alleges the preceding paragraphs,
inclusive, as though set forth fully herein.

143. Cal. Labor Code 201 and 202 required Defendants to pay all compensation
due and owing Plaintiff immediately upon discharge and no later than seventy two hours after
termination of her employment. Labor Code 203 provides that if an employer willfully fails
to pay compensation upon discharge or resignation, as required under Labor Code
201 and 202, then the employer is liable for waiting time penalties in the form of continued
compensation for up to thirty (30) work days.

144. Defendants willfully failed to pay Plaintiff compensation due upon termination
of employment as required by law. As a result, defendants are liable to Plaintiff for waiting
time penalties under Labor Code section 203 as well as reasonable attorneys? fees and costs of

suit as permitted law and equity.

COMPLAINT FOR DAMAGES
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NINETEENTH CAUSE OF ACTION

(CONVERSION Against BIKRAM CHOUDHURY, YOGA COLLEGE
OF INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY
YOGA, INC. and DOES 1 through 25)

145. Plaintiff re-alleges and incorporates herein by reference the preceding
paragraphs, inclusive, as though fully set forth herein.

146. Plaintiff had an absolute right to receive the salary she was promised, contracted
for and which was agreed to by Defendants in exchange for her re-locating herself and her
young daughter from India to the United States to perform work.

147. Plaintiff has been damaged by the conduct of Defendants, and each of them, by
unlawful conversion of wages known to be owed to her for which she has not been paid despite
repeated demands.

148. As a proximate result of the conversion by Defendants, and each of them,
Plaintiff is entitled to the return of the wages converted by Defendants, and each of them, in an
amount according to proof at the time of trial.

149. Plaintiff is further entitled to compensation for the time and money expended in
pursuit of the converted property.

150. In doing the acts herein alleged, Defendants, and each of them, acted with
oppression, fraud, malice, and in conscious disregard of the rights of Plaintiff, and Plaintiff is

therefore entitled to punitive damages in an amount according to proof at the time of trial.

TWENTIETH CAUSE OF ACTION

(FAILURE TO MAINTAIN ACCURATE PAYROLL RECORDS LABOR CODE
226 Against BIKRAM CHOUDHURY, YOGA COLLEGE OF INDIA,
L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY YOGA,
INC. and DOES 1 through 25)

15]. Plaintiff re-alleges and incorporates herein by reference the preceding

paragraphs, inclusive, as though ?illy set forth herein.

COMPLAINT FOR DAMAGES
- 31

 

 






 

 

152. Cal. Labor Code section 226(a) requires employers to maintain for at least three
years a copy of the wage statements and record of deductions for each employee ?in ink or
other indelible form, properly dated, showing the month, day, and year, and a copy of the
statement and the record of deductions.? Cal. Labor Code section 226 provides that if an
employer knowingly and intentionally fails to maintain payroll records then the employee is
entitled to recover the greater of all actual damages or ?fty dollars for the initial violation
and one hundred dollars ($100) for each subsequent violation, up to four thousand dollars
($4000).
153. Defendants knowingly and intentionally failed to maintain accurate payroll
records, as required by Cal. Labor Code section 226(a). Plaintiff has suffered injury as a result.
154. Accordingly, Defendants are liable to Plaintiff for the amounts allowed by law

as well as her attorneys? fees and costs pursuant to Cal. Labor Code section 226(c)(1).

TWENTY-FIRST CAUSE OF ACTION

(RETALIATORY DISCHARGE LABOR CODE 98.6 et. seq. Against
BIKRAM CHOUDHURY, YOGA COLLEGE OF INDIA, L.P., BIKRAM
INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY YOGA, INC. and DOES 1
through 25)

155. Plaintiff re-alleges and incorporates herein by reference the preceding
paragraphs, inclusive, as though fully set forth herein.
156. Cal. Labor Code section 98.6 provides that no person may discharge an
employee because of her exercise of any legal rights afforded to her.
157.

158.

Defendants terminated Plaintiff on March 1, 2013.
Upon information and belief, Defendants ?red Plaintiff for, among other things,
her exercise of legal rights afforded to her including:

Demanding payment of her lawfully earned, owing and unpaid wages;
and

(ii) Requesting copies of her proper and lawful payroll records.

COMPLAINT FOR DAMAGES
- 32

 






 

 

   

159. As a result of Defendants? retaliatory ?ring of Plaintiff, Plaintiff has lost wages
and has suffered severe mental, and emotional distress.

160. In doing these acts alleged above, Defendants were guilty of fraud, Oppression
or malice in violating Labor Code section 98.6 subjecting defendants to liability for punitive

damages.
TWENTY-SECOND CAUSE OF ACTION

(VIOLATION OF THE BANE ACT CIVIL CODE 52.1] Against BIKRAM
CHOUDHURY, RAJASHREE CHOUDHURY, YOGA COLLEGE OF
INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY
YOGA, INC. and DOES 1 through 25)

161. Plaintiff re-alleges and incorporates herein by reference the preceding
paragraphs, inclusive, as though fully set forth herein.

162. California Civil Code section 52.] provides that it is unlawful to interfere with
an individual?s exercise or enjoyment of any rights under the Constitutions of the United States
and California by use or attempted use of threats, intimidation or coercion.

163. At all materials times herein, there was a professional relationship between
Plaintiff and Defendants, namely that Plaintiff was an employee and colleague of Defendants.

164. Throughout her employment, Plaintiff was subjected to threats, intimidation and
coercion including when she attempted to investigate conduct that she reasonably believed
posed a risk to young women and trainees, and conduct that she reasonably believed was
illegal. Such conduct included, but is not limited to, Bikram Choudhury?s harassment and
sexual conduct with females, including female students and trainees who were extremely
vulnerable having been pre-conditioned and ?taught? not to question Bikram Choudhury, who
was referred to as their ?guru? and ?Boss.? Defendants, and each of them, participated with
one another to cover-up this illegal and immoral conduct. Plaintiff also attempted to prevent
what she reasonably believed was other illegal conduct and treatment by Defendants, including
the conduct by Defendant Petra Starke which Plaintiff reasonably believed amounted to self-

dealing, ethical violations and a clear con?ict of interest in that Defendant Starke was

COMPLAINT FOR DAMAGES
- 33

 






 

 

simultaneously engaged in work on Bikram Choudhury and the Bikrarn entities behalf while at
the same time she was still employed by the US. Government. Plaintiff was also subjected to
threats and threatening conduct on March 15?, 2013, while she was being terminated. After her
employment, Plaintiff was subject to threatening and intimidating conduct including, but not
limited to, having her car taken from her property with her own personal property inside.

165. Under California law, Plaintiff has the right to full and equal accommodation
and treatment as an employee and may not be treated differently based on her gender. Under
California law Plaintiff also has the right to complain about conduct she reasonably believes is
illegal and improper.

166. Plaintiff?s gender was the reason for the threatening, intimidating and coercive
conduct she received from Defendants.

167. Plaintiff is informed and believes and on that basis alleges that the
aforementioned conduct of Defendants, and each of them, denied, aided, or incited a denial of,
discriminated or made a distinction that denied Plaintiff full and equal advantages, privileges,
and services solely based upon Plaintiff?s refusal to stand silently by while illegal conduct took
place, and for her objections to Defendants? conduct all of which constitute a violation of the
Bane Act.

168. As a proximate result of the wrongful actions of Defendants, and each of them,
Plaintiff has suffered and will continue to suffer harm including but not limited to lost earnings,
wages and employment, humiliation, embarrassment, damage to her professional reputation,
mental anguish and physical harm all in an amount to be proven at trial.

169. Plaintiff is further informed and believes and on that basis alleges that
Defendants, and each of them, acted and continue to act with the knowledge of the
consequences and damage being caused to Plaintiff by their actions, and Defendants actions are

will?il, malicious and oppressive. Accordingly, Plaintiff is entitled to punitive damages in an

amount determined by the jury at trial.

COMPLAINT FOR DAMAGES
- 34

 






 

 

TWENTY-THIRD CAUSE OF ACTION

(VIOLATION OF THE RALPH ACT CIVIL CODE 51.7] Against BIKRAM
CHOUDHURY, RAJASHREE CHOUDHURY, YOGA COLLEGE OF
INDIA, L.P., BIKRAM INC., USA YOGA FEDERATION, BIKRAM CHOUDHURY
YOGA, INC. and DOES 1 through 25)

170. Plaintiff re-alleges and incorporates herein by reference the preceding
paragraphs, inclusive, as though fully set forth herein.

171. California Civil Code section 51.7, commonly referred to as ?The Ralph Act,?
provides that persons have the right to be free from violence or threats of violence, committed
against their persons or property due to, among other things, their gender.

172. Throughout her employment, Plaintiff was subjected to threats, intimidation,
violence and coercion including when she attempted to investigate conduct that she reasonably
believed posed a risk to young women and trainees, and conduct that she reasonably believed
was illegal. Such conduct included, but is not limited to, Bikram Choudhury?s harassment and
sexual conduct with females, including female students and trainees who were extremely
vulnerable having been pre-conditioned and ?taught? not to question Bikram Choudhury, who
was referred to as their ?guru? and ?Boss.? Defendants, and each of them, participated with
one another to cover-up this illegal and immoral conduct. Plaintiff also attempted to prevent
what she reasonably believed was other illegal conduct and treatment by Defendants, including
the conduct by Defendant Petra Starke which Plaintiff reasonably believed amounted to self-
dealing, ethical violations and a clear con?ict of interest in that Defendant Starke was
simultaneously engaged in work on Bikram Choudhury and the Bikram entities behalf while at
the same time she was still employed by the US. Government. Plaintiff was also subjected to
threats and threatening conduct on March 15?, 2013, while she was being terminated. After her

employment, Plaintiff was subject to threatening and intimidating conduct including, but not

limited to, having her car taken from her prOperty with her own personal property inside.

COMPLAINT FOR DAMAGES
- 35

 



173. Plaintiff 3 gender was the reason for the threatening, intimidating and coercive
conduct she received from Defendants.

174. Plaintiff is informed and believes and on that basis alleges that the
aforementioned conduct of Defendants, and each of them, denied, aided, or incited a denial of,
discriminated or made a distinction that denied Plaintiff full and equal advantages, privileges,
and services solely based upon Plaintiffs refusal to stand silently by while illegal conduct took
place, and for her objections to Defendants? conduct all of which constitute a violation of the
Bane Act.

175. As a proximate result of the wrongful actions of Defendants, and each of them,
Plaintiff has suffered and will continue to suffer harm including but not limited to lost earnings,
wages and employment, humiliation, embarrassment, damage to her professional reputation,
mental anguish and physical harm all in an amount to be proven at trial.

176. Plaintiff is further informed and believes and on that basis alleges that
Defendants, and each of them, acted and continue to act with the ?ll knowledge of the
consequences and damage being caused to Plaintiff by their actions, and Defendants actions are
will?11, malicious and oppressive. Accordingly, Plaintiff is entitled to punitive damages in an

amount determined by the jury at trial.
TWENTY-FOURTH CAUSE OF ACTION

(SEXUAL HARASSMENT IN VIOLATION OF THE UNRUH CIVIL RIGHTS ACT
CIVIL CODE 51.9] Against BIKRAM CHOUDHURY)

177. Plaintiff re-alleges and incorporates herein by reference the preceding
paragraphs, inclusive, as though fully set forth herein.
178. California Civil Code section 51.9 provides that a defendant is liable for sexual

harassment where there is a professional relationship between the Plaintiff and the Defendant.

COMPLAINT FOR DAMAGES
- 36

 






 

 

 

I79. As the term ?professional relationship? is de?ned by Cal. Civil Code 
Plaintiff was in a professional relationship to Defendant.

180. The defendant Bikram Choudhury made sexual advances, solicitations, sexual
requests, demands for sexual compliance by the plaintiff, or engaged in other verbal, visual, or
physical conduct of a sexual nature or of a hostile nature based on Plainti??s gender, that were
unwelcome and pervasive or severe and there was an inability by the Plaintiff to easily
terminate the relationship.

181 . As a proximate result of the wrongful actions of Defendant, Plaintiff has
suffered and will continue to suffer harm including but not limited to lost earnings, wages and
employment, humiliation, embarrassment, damage to her professional reputation, mental
anguish and physical harm all in an amount to be proven at trial.

182. Plaintiff is further informed and believes and on that basis alleges that
Defendants acted and continues to act with the full knowledge of the consequences and damage
being caused to Plaintiff by his actions, and Defendant?s actions are VVill?ll, malicious and

Oppressive. Accordingly, Plaintiff is entitled to punitive damages in an amount determined by

 

the jury at trial.
TWENTY-FIFTH CAUSE OF ACTION
(CIVIL CONSPIRACY Against All Defendants)
183. Plaintiff re-alleges and incorporates herein by reference the preceding

paragraphs, inclusive, as though fully set forth herein.
184. Starting in or about 2012, defendants and others began a campaign to knowingly
and willfully conspire and agree amongst themselves and cooperate to discriminate against
Plaintiff based on her gender and Defendants, and each of them, knowingly and willfully
conspired to permit, facilitate cooperate in and/or cover-up the illegal conduct, including the

sexual misconduct of Defendant Bikram Choudhury.

COMPLAINT FOR DAMAGES
- 37

 






 

 

185. As a proximate result of the wrongful actions of Defendants, and each of them,
Plaintiff has suffered and will continue to suffer harm including but not limited to lost earnings,
wages and employment, humiliation, embarrassment, damage to her professional reputation,
mental anguish and physical harm all in an amount to be proven at trial.

186. Plaintiff is further informed and believes and on that basis alleges that
Defendants acted and continue to act with the full knowledge of the consequences and damage
being caused to Plaintiff by their actions, and Defendants? actions are willful, malicious and
oppressive. Accordingly, Plaintiff is entitled to punitive damages in an Mount determined by
the jury at trial.

PRAYER FOR RELIEF

Wherefore Plaintiff JAFA-BODDEN prays for judgment against Defendants, and each

of them, as follows:

1. For a money judgment representing compensatory damages including lost
wages, earnings, and all other sums of money, together wi?i interest on these
amounts, according to proof;

2. For an award of money judgment for mental pain and anguish and severe

emotional distress, according to proof;

For an award of money judgment for defamation per se;
Punitive damages, according to proof;

For prejudgment and post-judgment interest;

For declarative and injunctive relief; and

899:5??

For any other relief that is just and proper.

COMPLAINT FOR DAMAGES
- 38

 

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STATE OF State and Consumer Services Agmcy GOVERNOR EDMUND G. BROWN JR.

macros mmus . no
DEPARTMENT OF FAIR EMPLOYMENT 8. HOUSING 
2218 Kausen Drive. Suite 100 Elk Grove I CAI 95759
800884-1684 lVideophone 916226-5285 ITDD 800400-2320
I email: contact.center@dleh.ca.gov

 

 

June 11, 2013

RE: Notice of Filing of Discrimination Complaint
DFEH Matter Number: 128731 -55552-Fl
Right to Sue: JafaBodden INC.

To All Respondent(s):

Enclosed is a copy of a complaint of discrimination that has been ?led with the Department of Fair Employment
and Housing (DFEH) in accordance with Government Code section 12960. This constitutes service of the
complaint pursuant to Government Code section 12962. The complainant has requested an authorization to ?le
a lawsuit. This case is not being investigated by the DFEH and is being closed A copy of the
Notice of Case Closure and Right to Sue is enclosed for your records.

Please refer to the attached complaint for a list of all respondent(s) and their contact information.

No response to DFEH is requested or required.

Sincerely,

Department of Fair Employment and Housing

 



I I.  . STATE OF CALIFORNIAI FaIr Employment and Housng EMPLOYMENT RIGHTTO SUE
COMPLAINT OF DISCRIMINATION UNDER THE PROVISIONS OF THE
CALIFORNIA FAIR EMPLOYMENT AND HOUSING ACT

 

DFEH MATTER NUMBER
128731 -55552-R

 

COMPLAINANT
Minakshi JafaBOdden

 

NAMED IS THE EMPLOYER. PERSON, AGENCY. ORGANIZATION OR GOVERNMENT ENTITY WHO DISCRIMINATED AGAINST ME

 

 

 

 

RESPONDENT ADDRESS PHONE
BIKRAM INC., 11500 OLYMPIC BLVD. SUITE 150 LOS ANGELES CA 90064 (310) 854-5800
BIKRAM INC.

AGENT FOR SERVICE ADDRESS PHONE
NO. OF EMPLOYEES MOST RECENT DISCRIMINATION TOOK PLACE TYPE OF EMPLOYER
50 Mar 01, 2013 Private Employer
CORESPONDENHS) ADDRESS
YOGA COLLEGE OF 11500 W. OLYMPIC BLVD. LOS ANGELES CA 90064
INDIA, YOGA COLLEGE OF INDIA,

LP

BIKRAM CHOUDHURY YOGA, INC. BIKRAM 11500 W. OLYMPIC BLVD. LOS ANGELES CA 90064
CHOUDHURY YOGA, INC.

USA YOGA FEDERATION USA YOGA 4335 VAN NUYS BLVD. SHERMAN OAKS CA 91403
FEDERATION

RAJASHREE CHOUDHURY 3172 TOPPINGTON DRIVE BEVERLY HILLS CA 90210
JUDY YANG CO YOGA COLLEGE OF INDIA LP LOS

ANGELES CA 90064

 

PETRA STARKE clo YOGA COLLEGE OF INDIA LOS ANGELES

A CA 90064
BIKRAM CHOUDHURY 3172 TOPPINGTON DRIVE BEVERLY HILLS CA 90210
DATE FILED Jun 11. 2013 REVISED APRIL 2013

MODIFIED Jun 11. 2013 PAGE ?3

(W 

A STATE OF Housng ENROYMENT 
COMPLAINT OF DISCRIMINATION UNDER THE PROVISIONS OF THE
CALIFORNIA FAIR EMPLOYMENT AND HOUSING ACT

 

OFEH MATTER NUMBER
1 28731 -55552-FI

 

IALLEGE THAT I EXPERIENCED Discrimination, Harassment, Retaliation
ON OR BEFORE Mar 01 2013
BECAUSE OF MY Association with a member of a protected class, Engagement in Protected

Activity, Sex- Gender

AS A RESULT. I WAS Denied a work environment free of discrimination and/or retaliation, Denied
employment, Denied equal pay, Forced to quit, Terminated,
Other RETALIATED AGAINST AND HARASSED

 

STATEMENT OF FACTS

FROM VERY EARLY ON IN MY EMPLOYMENT, I WAS SUBJECT TO A HARASSING AND DISCRIMINATORY
WORK ENVIRONMENT. BIKRAM CHOUDHURY REPEATEDLY AND ROUTINELY INJECTED SEXUAL
COMMENTS AND INNUENDO INTO THE WORKPLACE, OFTEN STARED AT MY PHYSICAL ATTRIBUTES
AND HE OFTEN LEERED AT THE PHYSICAL ATTRIBUTES OF OTHER WOMEN. WHEN I OBJECTED TO
HIS CONDUCT, WAS RETALIATED AGAINST. CHOUDHURY ALSO REPEATEDLY ATTEMPTED TO
ENGAGE IN CONDUCT THAT I REASONABLY BELIEVED WAS IN VIOLATION OF THE LAW. WHEN I
OBJECTED TO AND ATTEMPTED TO PREVENT SUCH ILLEGAL CONDUCT FROM OCCURRING, I WAS
RETALIATED AGAINST. CHOUDHURY MADE NUMEROUS DEROGATORY COMMENTS ABOUT MYSELF
AND OTHER WOMEN, INCLUDING BUT NOT LIMITED TO REFERRING TO WOMEN AS 
AND REFERRING TO SINGLE MOTHERS IN DISPARAGING TERMS AND
STATING THAT WE WERE NOT TO HIRE SINGLE WOMEN WITH CHILDREN. CHOUDHURY CREATED AND
FOMENTED A HYPER-SEXUALIZED, DEMEANING AND DEGRADING WORK ENVIRONMENT FOR WOMEN
WHICH INCLUDED HAVING WOMEN MASSAGING HIM AND BRUSHING HIS HAIR OUR
WHEN I ATTEMPTED TO PROTECT OTHER WOMEN, INCLUDING YOUNG YOGA TRAINEES
AND STUDENTS, FROM HIS PREDATORY AND INAPPROPRIATE BEHAVIOR I WAS RETALIATED
AGAINST. WHEN I ATTEMPTED TO INVESTIGATE ALLEGATIONS ABOUT HIS SEXUAL MISCONDUCT 
WAS TOLD TO IT AND NOT INVESTIGATE AND I WAS RETALIATED AGAINST FOR
TO FIND OUT THE TRUTH. ALL OF THIS CONDUCT WAS ONGOING, PERVASIVE AND
NEARLY CONSTANT. ALL OF THE OTHER ENTITIES NAMED IN
THIS COMPLAINT EITHER DIRECTLY ENGAGED IN HARASSING AND DISCRIMINATORY CONDUCT OR
SUPPORTED, ENCOURAGED CONDONED SUCH CONDUCT.

DATE FILED Jun 11, 2013 REVISED APRIL 2013
MODIFIED Jun 11, 2013 PAGE 213

(W MI

STATE OF CALIFORNIAI of Fair Employment and mm EMPLOYMENT RIGHTTO SUE

COMPLAINT OF DISCRIMINATION UNDER THE PROVISIONS OF THE
CALIFORNIA FAIR EMPLOYMENT AND HOUSING ACT

 

DFEH MATTER NUMBER
1 28731 -55552-R

 

SIGNED UNDER PENALTY OF PERJURY

I wish to pursue this matter in court. I hereby request that the Department of Fair Employment and Housing
provide a right to sue. I understand that if I want a federal right to sue notice, I must visit the US. Equal
Employment Opportunity Commission (EEOC) to ?le a complaint within 30 days of receipt of the DFEH "Notice of
Case Closure and Right to Sue," or within 300 days of the alleged discriminatory act, whichever is earlier.

I have not been coerced into making this request, nor do I make it based on fear of retalliation understand it is the Department of Fair Employment and Housing?s policy to not process or reopen a complaint
once the complaint has been closed on the basis of "Complainant Elected Court Action."

By submitting this complaint, I am declaring under penalty of perjury under the laws of the State of California that,
to the best of my knowledge, all information contained in this complaint is true and correct, except matters stated
on my information and belief, and I declare that those matters I believe to be true.

Verified by CARLA MINNARD, Attorney for Complainant, and dated on June 11 2013 at Oakland, CA.

 

DATE FILED Jun 11, 2013 REVISED APRIL 2013
MODIFIED Jun 11, 2013 PAGE 3/3

EXHIBIT


 

 

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