Bikram - Jane Doe 1 - Complaint

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COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF

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10. NEGLIGENT INFLICTIONS OF EMOTIONAL
DISTRESS
11. NEGLIGENCE
12. CLAIM FOR DECLARATORY AND
INJUNCTIVE RELIEF

REQUEST FOR JURY TRIAL

AMOUNT IN CONTROVERSY EXCEEDS
MINIMUM JURISDICTIONAL AMOUNT

Plaintiff Jane Doe No. 1 (a pseudonym) complains against Defendants BIKRAM
CHOUDHURY, an individual; BIKRAMS YOGA COLLEGE OF INDIA, L.P., and DOES 1-25
as follows. Defendants BIKRAM CHOUDHURY, an individual; BIKRAMS YOGA COLLEGE
OF INDIA, L.P., and DOES 1-25 are collectively referred to herein as Bikram Yoga or Bikram
Family or The Community.
NATURE OF THE ACTION
1. Plaintiff Jane Doe 1 brings this lawsuit because she was raped twice by
Defendant Bikram Choudhury in the Fall of 2011. Defendant Choudhury and Defendants
encouraged Jane Doe 1 to move to California on the false pretense that Defendants needed her to
work for them and that they were going to provide her with legitimate employment. Further,
Plaintiff JANE DOE NO. 1 was a victim of gender violence and human trafficking and other
unlawful acts that caused her physical and emotional harm as well as deprivation of a meaningful
income.
2. Plaintiff also contends that Defendants 1-25 (whose precise names are not
known to Plaintiff), who were other persons in Defendant Bikram Choudhurys inner circle, were
aware of Defendant Bikram Choudhurys pattern and practice of causing, inducing, or persuading
young women to travel to his place of work and business so Defendant Bikram Choudhury could
obtain forced labor or services, including sexual massages. Plaintiff is informed and believes that
after Defendant Bikram Choudhury lures the young women to his place of business, through
various schemes and designs and with the participation of his inner circle who are knowledgeable of

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and complicit in the abuse, he sexually assaults and/or rapes them. Plaintiff also contends that
Defendants 1-25 (whose precise names are not known to Plaintiff), who were other persons in
Defendant Bikram Choudhurys inner circle, were aware of Defendant Bikram Choudhurys
propensity to sexually assault young women, yet they did nothing to prevent this from happening to
Plaintiff or to protect her.
3. Plaintiff is informed and believes and otherwise contends that all the
Defendants (including those whose precise names are not known to Plaintiff) in some manner or
another conspired to facilitate, ratify or authorize Defendant Bikram Choudhurys unlawful conduct
as alleged herein or otherwise engaged in their own unlawful acts toward Plaintiff.
4. On March 19, 2013, Plaintiff found the courage to expressly communicate to
Defendant Bikram Choudhury that his conduct was unlawful, unwanted, and unconsented to, just as
she had during the two rapes. Defendant Choudhury attempted to force Plaintiff Jane Doe. No.1 to
forgive him and to inflict guilt on the Plaintiff by citing that if she were to come forward it would
have adverse effects on the entire Bikram Yoga Community (of which she had been a part.)
Defendant Bikram Choudhury attempted to meet Plaintiff in person like old times, for tea, despite
the fact they had never had tea together as equals. Plaintiff Jane Doe No. 1 had never had personal
contact with Bikram Choudhury except as his student, as a Teacher Training staff member, at
teacher dinners, lectures, or when visiting his home or business.
5. After the rapes, Plaintiff Jane Doe No. 1 was never alone with Bikram
Choudhury again and warned other young women not to go to his room alone. She knew that he
attacked younger women and suggested to his wife Rajashree Choudhury that they get a professional
masseuse for his apparent physical distress instead of recruiting young women (who had no formal
training in massage except for the direct commands Bikram Choudhury made as their teacher of
Hatha yoga.) These young women blindly trusted that Defendant Bikram Choudhury had more
knowledge of human anatomy than they did and that they were learning something by taking care of
their guru when they provided these massages.
6. In response, and after Plaintiff demanded that there be no contact with her,
she was met with intimidating emails from Defendants Bikram Choudhury and his new CEO Petra

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Starke (who also happens to be an attorney). Plaintiff interpreted these emails as threatening in light
of Defendant Bikram Choudhurys repeated comments that he will crush anyone who speaks against
him and that he has friends in high places including past United States Presidents.
7. As a direct consequence of these unlawful acts, Plaintiff has suffered severe
emotional distress including post-traumatic stress disorder, as well as economic, consequential, and
other damages, all to her detriment. Defendants actions forced Plaintiff to hire attorneys and file
suit and she, therefore, has incurred substantial attorneys fees and costs.
PARTIES
8. Plaintiff Jane Doe No 1. (hereinafter, Jane Doe No. 1, Plaintiff, or
Jane) is a pseudonym for a woman whose name is kept confidential for personal, safety and
privacy reasons. Plaintiff Jane Doe No. 1, is a resident of a state outside of California and a citizen
of the United States of America. Jane Doe No. 1 is a young woman who is fully qualified as a yoga
teacher and who was certified by Defendants Bikram Choudhury (hereinafter, Choudhury or
Defendant Choudhury) and Bikrams Yoga College of India, L.P. (hereinafter, Yoga College.) to
teach Bikram Yoga which is a type of Hatha Yoga practiced in rooms heated to 105 degrees
Fahrenheit.
9. Plaintiff is informed and believes that Defendant Bikram Choudhury is an
individual and a resident of Los Angeles, California in the County of Los Angeles at all times
material to this complaint.
10. Plaintiff is informed and believes that Defendant Yoga College was a
California Limited Partnership (California Secretary of State No. 200223100010) and operated in the
City and County of Los Angeles at all times material to this complaint. Plaintiff is informed and
believed that Defendant Bikram Choudhury treats the partnership as his alter ego rather than as a
separate entity, and that upholding the corporate entity and allowing Defendant Bikram Choudhury
to escape personal liability for its actions would sanction a fraud or promote an injustice.
11. 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 fictitious names. Plaintiff will amend this Complaint by inserting the true names

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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.
12. Plaintiff is informed and believes and thereon alleges that at all times material
to this Complaint, Defendant and each of the defendants fictitiously named in this Complaint, in
addition to acting for himself, herself or itself, and on his, her or its own behalf individually, is and
was acting as the agent, servant, employee and representative of, and with the knowledge, consent
and permission of, and in conspiracy with each and all of the defendants and within the course,
scope and authority of that agency, service, employment, representation and conspiracy. Plaintiff
further alleges on information and belief that the acts of each of the defendants were fully ratified by
each and all of the defendants. Specifically, and without limitation, Plaintiff alleges on information
and belief that the actions, failures to act, breaches, conspiracy and misrepresentations alleged herein
and attributed to one or more of the specific defendants were approved, ratified and done with the
cooperation and knowledge of each and all of the defendants.
13. The allegations of this Complaint stated on information and belief are likely
to have evidentiary support after a reasonable opportunity for further investigation and discovery.
VENUE
14. Venue is proper because the injuries to Plaintiff occurred in Los Angeles,
California and because Defendant Yoga College is a limited partnership that is doing business, or
has done business during the times related herein, in the City and County of Los Angeles.
15. Defendant Bikram Choudhury, individually and as a managing agent of
Defendant Yoga College, committed acts causing harm to Plaintiff in the State of California.
CONTINUING VIOLATIONS
16. The wrongful acts and omissions giving rise to the Defendants liability in
this action commenced in or about 2004 and have been and are continuing in nature as of the date
of filing this Complaint. Plaintiff reserves the right to amend this Complaint as new and additional
facts and claims arise or become known to Plaintiff.

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TOLLING DUE TO DURESS AND DISABILITY
17. Plaintiff was incapacitated for period at a time due to post-traumatic stress
disorder as a result of Defendant Choudhurys actions, and as a result was incapable of transacting
business or understanding the nature and effect of her actions, and as a result is entitled to equitable
tolling of her claim as well at tolling under California Code of Civil Procedure section 352.
18. Further, the wrongful acts of Defendants placed Plaintiff under economic
duress. Plaintiff delayed filing suit for the additional reason that she feared for her livelihood and
reprisals by Defendants, due in part to being deeply in debt as a result of the significant unpaid labor
she engaged in at Defendant Choudhurys behest. In addition, Plaintiff spent more than $10,000 to
attend Teacher Training (TT) and spent thousands of dollars on travel and living expenses.
Defendants cannot equitably benefit from this economic duress, and thus are equitably estopped
from asserting the statute of limitations against Plaintiff.
19. Further, Defendants placed Plaintiff under emotional duress in an attempt to
prevent her from filing suit or otherwise complaining of their unlawful acts. Plaintiff contends that
Defendant Bikram Choudhury has made threatening comments or otherwise engages in implicitly
threatening actions in an attempt to prevent her from coming forward. Under California law,
threats and undue influence are both grounds for tolling based on estoppel. It is well settled that
where delay in commencing an action is induced by the conduct of the defendant, he cannot avail
himself of the defense of the statute [of limitations]. [Citations.] (Gaglione v. Coolidge (1955) 134
Cal.App.2d 518, 527, 286 P.2d 568; see also Rupley v. Huntsman (1958) 159 Cal.App.2d 307, 313, 324
P.2d 19; Langdon v. Langdon (1941) 47 Cal.App.2d 28, 32, 117 P.2d 371; Industrial Indem. Co. v. Ind.
Acc. Com. (1953) 115 Cal.App.2d 684, 689, 252 P.2d 649; Carruth v. Fritch (1950) 36 Cal.2d 426, 434,
224 P.2d 702.)
TOLLING DUE TO DEFENDANTS UNAVAILABILITY
20. On information and belief, Defendant Bikram Choudhury regularly leaves
the State of California and the United States for at least three (3) months a year, if not longer.
Under California law, the statute of limitations does not run, or tolls, while a resident Defendant is
out of state. (Code Civ. Proc., 351.)

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FACTUAL DISCUSSION
A. BIKRAM YOGA
21. Bikram Yoga is a system of yoga that Bikram Choudhury claims he
synthesized from traditional Hatha yoga techniques and popularized beginning in the early 1970s.
All Bikram Yoga classes run for 90 minutes and consist of the same series of 26 postures and 2
breathing exercises. Bikram Yoga is typically practiced in a room heated to 105F ( 40.6C) with
a humidity of 40%.
22. On information and belief, there are over 650 Bikram Yoga studios around
the world. On information and belief, in an effort to endear themselves to Defendant Bikram
Choudhury, certain Bikram Yoga studio owners, instructors and practitioners encourage young,
attractive and/or vulnerable female students to attend TT and become certified because they know
of Defendant Bikram Choudhurys penchant for younger women who are flexible and love the
yoga.
23. On information and belief, these certain Bikram Yoga studio owners,
instructors and practitioners who supply Defendant Choudhury with young women for sexual
purposes are rewarded in various ways and promoted within the organization.
B. DEFENDANT BIKRAM CHOUDHURYS KNOWN PATTERN AND PRACTICE OF ABUSING
YOUNG WOMEN INCLUDING SEXUALLY ASSAULTING AND RAPING THEM.
24. On information and belief, certain Bikram Yoga studio owners, instructors
and practitioners, particularly those who have high status in the Bikram organization or are in the
inner circle, are fully aware that Defendant Bikram Choudhury has a pattern and practice of: a)
mentally manipulating or otherwise controlling the minds and will of certain young women in an
effort to get them to work for Defendant Choudhury for free or little pay and become economically
and emotionally dependent on him; b) once young women are under his control, requiring them to
work for him for little or no pay including acting as his personal servant, massaging him, and
performing other tasks that would otherwise be performed by paid employees while he personally
financially benefits from their labor; c) sexually demeaning, abusing, harassing and discriminating
against young women; and, d) sexually assaulting and raping certain young women.

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25. On information and belief, Plaintiff Jane Doe No. 1 contends that instead of
reporting Defendant Choudhurys behavior to police or other legal authority, or taking affirmative
action to stop him, certain Bikram Yoga studio owners, instructors and practitioners have put their
own selfish economic interests before the personal safety of others and, incredibly, blame the
innocent young women for being sexually assaulted and raped by Defendant Bikram Choudhury.
Armed with the knowledge of Defendant Bikram Choudhurys propensity to sexually assault
younger women, these studio owners, instructors and practitioners have failed to protect young
women like Jane Doe No. 1 from Defendant Choudhury, and have knowingly, willfully, and
voluntarily participated in threats and cover-ups to keep victims silent, including verbally attacking
victims or people who they believe might be victims on social media.
C. INDOCTRINATION AND MIND CONTROL AT BIKRAM YOGA TT.
26. The only way to become a Bikram Yoga certified instructor and teach at an
official Bikram Yoga studio is to complete Bikram Yoga TT. The course lasts nine weeks, six days
a week, more than twelve hours a day, and costs approximately $13,000 for tuition and room and
board. Students are required to stay in the hotel where TT is occurring. They must leave behind
their family, their jobs, their entire life, and during TT, are barred from having sex, even if they are
married. It is a total immersion experience.
27. At least twice a year, Defendant Bikram Choudhury and his wife Rajashree
hold a TT in Los Angeles, California. They also held TTs in Acapulco, Mexico, Hawaii and
provide recertification training and yoga seminars around the world.
28. Defendant Bikram Choudhury lures past students to volunteer their services
to him under the guise of Karma Yoga and the obligation to give back to their guru what they
have been given by Defendant Bikram Choudhury and his other followers. There is an
undercurrent of promises that if you serve the Family or the Community it will help you
becomes a better teacher, help you to become a yoga studio owner, and/or promote the benefits of
yoga. Certified Bikram Yoga teachers work at the TT for little or no pay. Many of these
volunteers step away from their jobs or income-producing work and travel to these TTs at great
personal expense for fear that if they do not do as Defendant Bikram Choudhury demands, they

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will suffer and be barred from teaching. Some volunteers are so in fear of Defendant Bikram
Choudhurys wrath that they will travel from other countries and enter the United States illegally to
work for Bikram for free, risking violating immigrations laws. Once in the United States, these
volunteers are required to serve Defendant Bikram Choudhury for zero or little pay. Their duties
include grooming him, massaging him, making his tea, bringing him food and being forced to
submit to non-consensual sexual assaults and rapes.
29. During TT, every moment of a students day is controlled by the schedule set
by Defendant Bikram Choudhury. The day usually starts at 7:00 a.m., and ends between 2:00 and
3:00 a.m. Students are required to attend each and every class, and spend eight plus hours a day
being instructed. When they can eat, what they can drink during class (water only, and even that is
heavily frowned upon by Defendant), what they wear (no color green, and tight, skimpy clothing),
the expressions on their faces, the words that come out of their mouths and the position of their
bodies are all controlled by Defendant Choudhury and other instructors.
30. If students miss a TT class, or accidentally forget to sign in to class at the
very beginning, they must attend makeup classes.
31. On a typical day, students will do the ninety-minute Bikram Yoga sequence
twice, and spend five hours or more in posture clinic, practicing the postures and learning the
dialogue. They also sit through hours of anatomy lectures, and read extensively on the subjects of
anatomy and yoga. At night, what little free time they have is often spent studying The Dialogue,
which they must memorize and perform, at times in front of hundreds of students.
32. Plaintiff is informed and believes that the sole purpose of the TT is to break
down the body, will and spirit of the students and rebuild them in the vision and teachings of
Defendant Bikram Choudhury. Day in and day out, TT students are pounded with, among other
things, the knowledge that:
a. Bikram Yoga is the only true yoga all others are false;
b. That Bikram Yoga can cure cancer and other life threatening illnesses;
c. That Bikram Yoga will enable practitioners to live 100 years;

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d. That Defendant Bikram Choudhury is on the same level as Jesus Christ or the
Buddha;
e. That Defendant Bikram Choudhury was given special knowledge by his guru;
f. That TT students lives will be ruined if they dont follow the teachings of Defendant
Bikram Choudhury; and,
g. That TT students must completely submit their lives, will and spirit to TT and to
Defendant Bikram Choudhury.
33. Students are also often required to attend evening lectures, where Defendant
Choudhury rants on subjects including his negative views on certain races; negative views on
homosexuality; the poor attitudes of Americans; his guru; his views on sex, marriage, and
relationships; and whatever else he should care to talk about. In addition to this indoctrination,
Defendant Choudhury will often require that students stay up until 2:00 a.m. or 3:00 a.m. watching
Bollywood movies with him while young female followers, sometimes students, sometimes teachers,
rub his feet and massage him for hours.
34. Even for devoted students who have been performing Bikram Yoga once a
day, TT is brutal. A medical tent is set up next door, and students are known to faint during class
for a number of reasons including dehydration, gastrointestinal problems, vomiting, heat stroke,
and according to a reporter who attended TT, seizures. Other students have reported that it is
common for students to collapse and be unable to rise, or to be overcome with weeping in a room
full of hundreds of people due to the sheer physical exhaustion. These experiences are dismissed
by staff members and Defendant Bikram Choudhury himself, often times being chalked up to
healing reactions, and promises that the yoga will build character and make you stronger or
make you bullet proof, instead of being acknowledged as bodies crying out for food and rest.
Trainees are given a false impression that if they get through it (TT), they are somehow
physically, mentally, emotionally, and spiritually superior to people who have not submitted to such
intense training. This creates dangerous and confusing approaches to yoga practice that is
subsequently passed on to the public studying with students who are taught in this environment.

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35. Defendant Yoga College does not pay a medical professional to be on staff
during the training. Although some nurses are available for consultations, there are weeks when the
only medical advice in the medical tent is from staff members who have never been medically
trained. This is a blatant attempt to hide the unsafe, physically and mentally exhausting atmosphere
of the teacher training. For emotional issues, trainees are encouraged to seek out Rajashree who is
typically not on site and has no background in traditional psychotherapy. Defendant Bikram
Choudhury discourages followers from attending therapy, regardless of their mental state. He
repeatedly refers to counselors in the field of psychology as psychopaths and publicly discourages
students from getting help, saying, your only problem is that you have no problem and/or
Western people have too many choices, I give you no choice.
36. If a student objects to anything Defendant Bikram Choudhury says or does,
he or she risks being banished and losing the registration fee. If a student drops out of the course
or is ejected, he or she generally will not receive a refund. The decision as to whether a student will
be certified is in the sole discretion of Defendant Bikram Choudhury. Once certified, the newly-
certified instructor may only teach at an approved Bikram Yoga studio.
37. Each and every student who attends TT attends weeks of classes led by
Defendant Bikram Choudhury. Defendant Choudhurys classes are peppered with highly offensive
and inappropriate language, sexual talk, and even sexual commentary directed at individual students,
particularly women. Defendant Choudhury requires certain female followers to brush his hair in
front of the entire class, and has been known to demand kisses from female students in front of four
hundred (400) plus students.
38. Female instructors at teacher training, who work without pay, often are even
more sleep-deprived and controlled than the students. They are required to provide Defendant
Choudhury with near-constant attention, food, and conversation. They must also run errands, at
times must rub his feet while he watches movies with students, or massage him for hours,
sometimes until he falls asleep between three and five in the morning. These female instructors are
required to attend to Defendant Bikram Choudhury at all times. They are warned by the other staff
that Defendant Choudhury will be in a bad mood if he is left alone. Women are bullied into

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checking on him constantly and making sure that he is always comfortable for fear of his mercurial
moods and the abuse he will inflict on them, other staff members, or even the entire teacher training
group of four hundred (400) plus students. This causes a great amount of fear and anxiety among
the female instructors.
39. Although Defendant Choudhury does not directly hire or compensate most
Bikram Yoga teachers, he still controls their lives and employment.
40. First of all, many Bikram Yoga teachers end up subsequently helping to lead
TT. Despite working 16-18 hour days, these teachers are not compensated, and are improperly
treated as unpaid interns. Teachers are unable to advance in the Bikram Yoga organization, or
obtain studios of their own, if they do not maintain a positive relationship with Defendant
Choudhury. In general, this requires spending time with him, which usually means working for him
for free, and showing your face at events to prove loyalty. Defendant Bikram Choudhury would
say, loyalty is the highest form of spiritualism and use this tag-line to manipulate and control the
behavior of his followers. He publicly reprimands anyone who has gone against him and his
organization saying they are greedy or bitches while likening himself to God and saying [I]
could never hurt another human or spirit because his guru (Bishnu Ghosh) said he could do no
wrong.
41. Second, Defendant Choudhury not only has the exclusive power to decide
which teachers are certified and re-certified (a process that must occur every three years) he also
exercises a great deal of control over who studio owners are encouraged to hire. If a teacher falls
out of favor with Defendant Bikram Choudhury, studio owners risk losing their certification if they
hire the disfavored teacher. On information and belief, at other times, Defendant Bikram
Choudhury and his assistants directly contact yoga studios and encourage them not to hire
individuals with whom he is displeased.
42. Because many Bikram Yoga teachers go into debt and/or give up their jobs
to attend TT, his displeasure risks their entire livelihood. For many, yoga is not simply a job, but
also a calling and a way of life. Those followers are faced with a harsh choiceeither tolerate
and/or participate in Defendant Choudhurys isolation, shunning, and punishment of others or risk

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being shunned themselves, losing their livelihood, and being ejected from a spiritual community that
is near and dear to their hearts. Many practitioners come to Bikram Yoga from illness, emotional
and physical problems, and disease, and find relief in the sweating, and consistent experience of 26
postures and 2 breathing exercises, and so they are particularly vulnerable to abuse and also unlikely
to leave the community, despite harsh treatment.
43. Plaintiff is informed and believes that Defendant Choudhury controls his
followers livelihoods, emotions and ability to think critically while working and living in his studios
and because he has conditioned them to accept his abuse and that he is able to mistreat his followers
with impunity, and indeed with the support of others that he employs in his organization.
44. Taken together, these practices enable Defendant Choudhury to wear down
the resistance of his followers, and also to normalize his improper sexual behavior toward female
followers. Through a pattern and practice of alternating praise and criticism, sleep deprivation,
artificial intimacy, attempts to exercise spiritual control, Defendant Bikram Choudhury targets
vulnerable young women.
D. PLAINTIFF JANE DOE NO. 1 IS INTRODUCED TO BIKRAM YOGA.
45. Around 2002, Plaintiff Jane Doe No. 1 took her first Bikram Yoga class
when she was 18 years old, and remembers feeling wonderful after class. Prior to beginning to
practice Bikram Yoga, Jane had chronic back pain and decided to embark on a yoga practice in
effort to heal her back. After only a couple of months, she was completely free of the chronic pain
that had previously limited her enjoyment of her life.
46. A few years later, when she was 23 years old, Plaintiff Jane Doe No. 1
attended Bikram Yoga TT in Hawaii. She didnt know what being a teacher meant or why she was
going. She simply wanted to meet Bikram, in gratitude for the way the yoga practice he pioneered
had cured her. Like so many others, she was naively drawn to his charismatic ways. Although TT
was difficult, and she found some of the comments and behavior of Defendant Bikram Choudhury
off-putting, she was able to keep her distance and did not give them much thought. Her sole focus
was on becoming a yoga teacher. She thought Defendants offensive behavior was a sort of rite of
passage a way to break her ego to become a good teacher.

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47. From that point on (until she was raped) she dedicated herself to Bikram
Yoga and worked around the world as an instructor. She went to many Bikram Yoga seminars and
teachings; focusing on the yoga only.
48. In one class at the Bikram Yoga Headquarters in Los Angeles, before
Plaintiff ever worked at TT, Defendant Bikram Choudhury looked at Plaintiff and said "I am going
to kill you." He said that a lot. When it happened to Plaintiff, it was very unsettling, but she
convinced herself that he meant it spiritually/egocentrically; in other words, that he would destroy
the parts of her that were egocentric and that were holding her back, that she needed to be humbled
to reach her full potential. It wasnt until later that these words took on a whole new nefarious
meaning.
49. In the spring of 2011, Plaintiff traveled to Indonesia to teach Bikram Yoga.
After she arrived, and learned that the studio that had hired her was not going to receive Bikram
certification, she refused to teach the slate of classes she had scheduled because she feared
Defendant Bikram Choudhurys wrath and shunning by The Community if she dared teach a class
there. This cost her and her boyfriend (also a Bikram yoga instructor) quite a bit of money in
international airfares and lost wages (because they cancelled all of their classes and cut their
international trip short).
50. When Plaintiff Jane Doe No. 1 returned to the U.S., she reconnected with
Defendant Bikram Choudhury at the Los Angeles headquarters, and traveled to the Bikram Yoga
University/Palm Desert studio opening to watch Bikram and Rajashree break the tape.
51. At the studio opening, Plaintiff Jane Doe No. 1 and her boyfriend were
approached by a Bikram employee, and recruited to work at Teacher Training. The employee
proceeded to flatter Plaintiff Jane Doe No. 1 and her boyfriend, praising them and saying that they
would be a good fit for the training. Plaintiff Jane Doe No. 1 and her boyfriend felt honored by
being invited to assist with teacher training after having gone through that whole ordeal overseas.
52. They felt like they had reconnected with the Bikram Yoga Family and that
good things were coming their way for doing the right thing by refusing to teach at an uncertified
Bikram Yoga studio while they were abroad.

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E. DEFENDANT BIKRAM CHOUDHURY STARTS TO TARGET PLAINTIFF JANE DOE NO. 1.
53. The Spring 2011, TT was the first time that Plaintiff Jane Doe No. 1 had
participated as a leader instead of as a student. Initially, she was pleased and excited to be a part of
the team.
54. As the TT progressed, the demands on Plaintiff Jane Doe No. 1s time began
to mount. Initially, Plaintiff was in charge of accommodations. Plaintiff Jane Doe No. 1 had to deal
with roommate disputes, including threats; room issues involving bed bugs, unauthorized animals,
illicit drug use, and teachers sharing rooms with trainees; and a serious administrative error with
regard to room assignments at check-in, such that it took weeks for Plaintiff Jane Doe No. 1 to
determine who had been assigned to what rooms. At the same time, Plaintiff Jane Doe No. 1 was
required to change peoples accommodations. It was physically and emotionally draining.
55. Plaintiff Jane Doe No. 1 led posture clinics for the first time (again without
pay.) While Plaintiff enjoyed teaching and saw it as a wonderful opportunity, it was also physically
demanding and time consuming, particularly in light of her other duties.
56. In addition to her daily duties, Plaintiff Jane Doe No. 1 was also required,
along with the rest of the staff, to stay up late and watch movies in Defendant Bikram Choudhurys
room.
57. As Plaintiff Jane Doe No. 1s was drawn into Defendant Bikram Choudhurys
inner circle, Defendant Choudhury began requesting that Plaintiff massage him more frequently.
Defendant Bikram Choudhury would complain of being in pain and needing her help. So, initially,
Plaintiff viewed this massage obligation as therapeutic and part of her duties.
58. Although she did not recognize it at the time, Plaintiff now believes she was
being set-up to be a sexual assault victim. She was being slowly worn down by the way the Bikram
organization deprived her of sleep and required her to minister to Defendant Choudhurys every
whim.
59. Over time, Defendant Bikram Choudhurys requests began to make Plaintiff
Jane Doe No. 1 uncomfortable. One night (while another instructor) and Plaintiff were in
Defendant Bikrams Choudhurys suite, he asked them to massage his coccyx. Plaintiff Jane Doe

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No. 1 remembers thinking to herself, this is weird. But, Plaintiff also remembered Defendant
Bikram Choudhury pulling his pants down at her TT to show how he had gotten stung by a jellyfish,
so Plaintiff brushed off her discomfort and chalked it up to cultural differences. Plaintiff did not
massage his coccyx.
60. This was the first time that Defendant Choudhurys request for a massage
seemed creepy and gave Plaintiff an uncomfortable feeling in the pit of her stomach.
61. Defendant Bikram Choudhury insisted on obedience. More than once,
Defendant Choudhury told Plaintiff that only he knew what was best for her, and that she did not.
62. Around this time, (another instructor) mysteriously left TT early, shortly
before it ended. Plaintiff does not remember when the other instructor left, but she remembered
that a Bikram employee left the other instructors goodbye letter on the table for everyone to see.
Plaintiff read the letter, and was deeply troubled. The letter seemed filled with desperation. J.
explained that she was leaving because she did not believe that the environment at TT was healthy
or good for her. Plaintiff recalls thinking that the letter read just like a break-up letter, causing her to
wonder what had happened.
63. After J. left, Plaintiff was responsible both for accommodations and for
being Defendant Bikram Choudhurys new full-time masseuse. It was a huge workload and Plaintiff
had never been so worn down.
64. Defendant Bikram Choudhury repeatedly told Jane Doe No. 1 that only he
knew what was best for her, and that she did not.
65. As time progressed, Defendant Choudhury alternated between praising
Plaintiff and publicly humiliating her. This became deeply disturbing and emotionally confusing and
taxing especially in light of her sleep deprivation and physical weakness.
66. During the last class of TT in Spring 2011, Defendant Choudhury yelled at
Plaintiff Jane Doe. No. 1 in front of a huge room full of teachers and students for not making his
tea hot enough. Jane Doe No. 1 was completely shaken by this unexpected attack and began to
leave the stage to make him a new cup of tea, when he snapped at her, Not now you idiot!

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Plaintiff Jane Doe No. 1 was humiliated to her core and deeply embarrassed to be reprimanded in
such a way in front of hundreds of people. Some of them laughed, and some appeared horrified.
67. At the TT graduation, Defendant Rajashree Choudhury gave Jane Doe No. 1
a cotton-candy pink sari as a thank you and asked her wear it on stage along with her fellow staff
members. The sari made her look a lot younger than she actually is; a thought that made Plaintiff
uncomfortable. Simultaneously, the gift made the Plaintiff Jane Doe No. 1 feel connected to the
lineage, and sealed the knowledge for her that Defendant Bikram Choudhury and Rajashree
Choudhury were her gurus or teachers. After so many public humiliations, Plaintiff was relieved
to be honored.
68. Despite the fact that Jane Doe No. 1 and her boyfriend were exhausted and
running short on funds, Defendant Choudhurys right hand person, Judes Yang, insisted that they
stay in Los Angeles to assist with the Yoga Championships. Plaintiff felt she could not say no to
Judes Yang because she was a bully and that would be the same as saying no to Defendant Bikram
Choudhury, which would have serious repercussions. Jane Doe No. 1 and the other teachers were
required to volunteer again without pay. They were not given the option to leave.
69. During the competition, Plaintiff Jane Doe No. 1 noticed that Defendant
Bikram Choudhury was behaving quite badly and was embarrassing everyone. He yelled at a girl
who did what he called a gymnastics move and in front of the audience forced the judges to give
her 0s for the whole routine. Plaintiff Jane Doe No. 1 later saw the competitor at TT in Fall of
2012 because Defendant Bikram Choudhury said she had returned for more training. Defendant
Choudhury required her and others who displeased him to return to training (at great expense to
them) to prove their loyalty to Defendant Choudhury, the lineage, and the Community.
70. Plaintiff and her boyfriend were now in a considerable amount of debt
because they had spent the spring and summer of 2011 working for free instead of teaching for
compensation at a studio. This caused tension in their relationship.
71. Additionally, Plaintiffs boyfriend became increasingly disturbed by the
attention Defendant Bikram Choudhury was giving Plaintiff and at the number of nights Defendant
Choudhury required her to massage him.

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72. During the course of her past trainings, Plaintiff was taught to believe that
Defendant Bikram Choudhury, his wife Rajashree Choudhury and many senior teachers were gift
guides, wise people, and holders of a very special yoga lineage that was handed down from the
spiritual teacher and healer Paramahansa Yogananda. She had come to view Defendant Bikram
Choudhury and his wife Rajashree Choudhury as parental figures and naively assumed that they
were good people who had her best interests at heart.
73. Over time, Jane Doe No. 1 began to fall prey to Defendant Choudhurys
manipulations. Jane Doe No. 1 began to believe that she was part of the Bikram Yoga Family,
also referred to as The Community. Later, when she was subjected to Defendant Choudhurys
increasingly sexually inappropriate actions, she found herself in the position of not knowing who to
trust or talk to.
74. Plaintiffs next troubling interaction with Defendant Bikram Choudhury
happened following her breakup with her boyfriend over the summer of 2011, when she was
particularly vulnerable.
75. Plaintiff Jane Doe No. 1 was completely devastated by the breakup. Hoping
to find some relief, she sought out additional Bikram Yoga training and connection with the
Community that she thought sustained her, and traveled to Seattle to attend a Bikram seminar. Her
mother and her mothers boyfriend traveled with her. Plaintiff introduced Defendant Bikram
Choudhury to her mother and her mothers boyfriend, and Defendant Bikram Choudhury said, Oh
this is the little one who takes care of me. Then, much to everyones consternation, Defendant
Bikram Choudhury grabbed Plaintiff away from her mother and said, She is mine now! This
upset and confused everyone but again Plaintiff tried to dismiss it as an aberrant comment.
76. Defendant Bikram Choudhury made other mystifying and inappropriate
remarks during a lecture in Seattle. At one point, he leered at Jane Doe No. 1 and said, A man is a
dog, pig or goat; I am no differentnow why would you want to hang around them? Initially, Jane
Doe No. 1 felt uneasy about this remark, but again, she brushed off Defendant Bikram Choudhurys
conduct as being eccentric and blamed herself for being overly sensitive.

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77. While attending the Bikram Yoga seminar in Seattle, Plaintiff talked to the
Bikram Yoga employee who asked her work at the Spring TT, who knew that Plaintiff and her
boyfriend were broken up, and who encourage her to come to Fall 2011 teacher training. This
employee told Plaintiff that she would have a group of good people around her who loved her, and
that maybe if Plaintiff did this, then Plaintiff and her boyfriend might end up back together.
78. Plaintiffs mother paid for her flight down to the Fall 2011 TT and gave her
some cash, because Plaintiff was still in debt from the Spring training. Plaintiff arrived two weeks
late because she had some teaching commitments in another state.
E. DEFENDANT BIKRAM CHOUDHURY SEXUALLY ASSAULTS AND RAPES JANE DOE 1 AT THE
FALL 2011 TT
79. When Plaintiff arrived at the TT in Fall 2011, she initially stayed in a room
with I.A., although Defendant Bikram Choudhury was still keeping her up very late in the night.
Plaintiff Jane Doe No. 1s new position was to take over for O.Z., who had not been happy about
being Defendant Bikram Choudhurys assistant. She was not paid for her work, except briefly for
work she performed in the Bikram Yoga shop. When the employee who recruited her and her
boyfriend learned that the shop manager was attempting to compensate Plaintiff, that employee put
a stop to it, and Plaintiff received no further wages.
80. Plaintiff felt unsettled, untrusting, and noticed that the other staff appeared
jealous that Defendant Bikram Choudhury was now calling Plaintiff by her real name, which they
took as a show of favor. Defendant Bikram Choudhury started giving her special attention. It
appeared he was very happy to see her.
81. At one point, Defendant Bikram Choudhurys told Plaintiff Jane Doe No. 1
that he was going to give her a transmission. Plaintiff Jane Doe 1 thought that meant he was
going to give her a special meditation that was reserved for teachers that had been practicing for a
number of years and had shown loyalty to their teacher. He said he had a gift for her; that he
believed we thought the same. Defendant Bikram Choudhury told Plaintiff Jane Doe No. 1 that
she really understood and was in-line with his teaching. Later, he would tell her to keep
everything he said to her a secret between her, him and God.

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82. Plaintiff Jane Doe No. 1 heard Rajashree Choudhury mention something to
Defendant Bikram Choudhury over dinner one evening; how she thought the Spring 2011 staff were
really in-line with Bikram. Defendant Bikram Choudhury asked Plaintiff Jane Doe No. 1 how her
teaching was progressing. Plaintiff had been insecure about her teaching since her first TT but
Plaintiff had worked really hard, and had students who really loved her style. Plaintiff had always
tended more toward less dialogue and more emphasis on stillness and breath, which was milder than
Defendant Choudhurys standard approach. Plaintiff said, It is definitely improving, as she had
sought mentoring and traveled to wherever she could teach to gain experience.
83. Plaintiff Jane Doe No. 1 was pleased because Defendant Bikram
Choudhurys praise and questions about her teaching made her think that he was going to give her
the honor of teaching the large group, something her boyfriend had really wanted during the Spring
training but was denied. Plaintiff Jane Doe No. 1 later learned that J.R. told an H.Q. staff member
A. that she wanted to teach the large group and A. and J.R. found this funny and humiliated
Plaintiff Jane Doe No. 1 for thinking that this was possible. This would not be the first time women
in the Defendant Bikram Choudhurys circle would gang up against Plaintiff Jane Doe No. 1. On a
separate occasion, the same two women denied her the right to lead posture clinic in an effort to
make sure her ego didnt get too big and because, as A. described, she lacked energy after
Defendant Bikram Choudhurys had worn her down her by constant massages and demands that
she constantly accompany him.
84. Over time, Plaintiff Jane Doe No. 1 was worn down by the constant
demands on her time and her emotions, particularly by Defendant Bikram Choudhury. She was
highly emotional about the breakup with her boyfriend, and because she was working so much for
months on end without pay and with little sleep, Plaintiff felt like she was and emotional wreck.
Plaintiff Jane Doe No. 1 missed her boyfriend, she was financially broke, physically exhausted and
she cried often.
85. Meanwhile, Defendant Bikram Choudhurys psychological manipulation of
Plaintiff escalated as he alternated between humiliating and complimenting her. The criticisms came
more and more often. Plaintiff Jane Doe No. 1 was publicly shamed; repeatedly called you idiot.

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When Plaintiff weakly tried to stand up for herself, Defendant Bikram Choudhury slammed her
down and barked, I am your teacher! Just as she was recovering from a round of public
humiliations, Defendant Bikram Choudhury started in with you will make a good wife someday,
that I want you to be free, and I believe in you or by calling her little one. He wore her down
physically as well; insisting that she massage him nightly for hours on end.
86. One night Plaintiff Jane Doe No. 1 and Defendant Bikram Choudhury were
alone together in the auditorium and Defendant Choudhury began behaving extremely strange.
Defendant Bikram Choudhury said to her, I have something to tell you. and Plaintiff said, What
is it? Defendant Bikram Choudhury said, Well, what if you dont like it? Plaintiff didnt respond,
but she felt both a little uncomfortable but also very curious.
87. Defendant Bikram Choudhury said, I have never met someone who had a
mind quite like my guru. You have the divine in you. You have been touched by God. Plaintiff
connected these statements with Defendant Choudhurys earlier mention of wanting to give her a
transmission, which meant that he saw something special and divine in her. Plaintiff felt special,
which helped her in her grief over the separation from her boyfriend and best friend.
88. As she and the other assistants were expected to do, Plaintiff walked
Defendant Bikram Choudhury up to his room early in the morning, between 4-5 a.m. He told her to
come into his room and put him to sleep by massaging him because his body hurt. While in the
room he attempted to make sexual advances while telling her that she was radiant, and that he had
picked her because she was not like others who distract him with clothing, make up and their hair,
that [he] could pick anyone but that he had chosen her. Plaintiff Jane Doe No. 2 said No, why are
you doing this? What about Rajashree? to which he replied, that they werent really married, that
Rajashree has a good life and that they would talk about that later. After realizing that the
Plaintiff Jane Doe. No. 2 was not going to willingly have sex with him, he dismissed her and eerily
said, I will be waiting for you.
89. The next morning, as part of her duties, Plaintiff went to tidy up his suite and
check and see if there was fresh fruit. Trying to make sure he had left the room, she peeked in first
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into the room; he then forced her onto the bed and started to take her pants off. Defendant Bikram
Choudhury complained that it was difficult to take her pants off because of the elastic. Meanwhile.
Plaintiff pleaded with Defendant Bikram Choudhury to stop. Plaintiff clearly objected, No this is
not safe, I dont want to do this.
90. Defendant Bikram Choudhury would not stop.
91. Defendant Bikram Choudhury kept calling her an idiot over and over again,
Idiot, idiot, idiot, idiot!
92. Defendant Bikram Choudhury demanded that Plaintiff look at his penis to
see how big it got and look at what she did to him. Plaintiff was horrified, in shock, and felt
completely violated.
93. Next, Defendant Bikram Choudhury demanded that Plaintiff lick his penis
and pushed her down on him. Defendant Bikram Choudhury vigorously penetrated her vagina with
his unprotected penis against her will. Defendant Choudhury forcefully manipulated her legs into a
yoga posture, and laughed at her, saying, You are a yogini! Plaintiff was horrified and in pain.
Throughout the painful ordeal, Plaintiff pleaded with Defendant Bikram Choudhury to stop, saying,
You are hurting me. Defendant Bikram Choudhury callously responded, I know, it is supposed
to hurt. Defendant Bikram Choudhury also told Plaintiff that she had not bloomed yet, that she
was like a bud, which she took to mean that he thought she was a virgin, or had been one until
recently.
94. Plaintiff was finally able to escape Defendant Bikram Choudhurys room and
went to her own room and collapsed. Plaintiff was so overwrought that she could not think of a
way that she could get out of TT. In shock, Jane Doe No. 1 began functioning on autopilot. She
felt lost, scared and did not know who to trust.
95. At the same time, Jane Doe No. 1 was financially destitute and depending on
the Community. She had been deprived of all her financial resources. Jane Doe No. 1 had invested
$10,000, had worked for Defendant Choudhurys TT twice for free, and spent five years of her life
teaching his yoga by the time that he raped her. Jane Doe No. 1 felt trapped. As she was not able,
financially or emotionally, to walk away in the immediate aftermath of being attacked.

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96. Plaintiff had become so accustomed to blindly obeying Defendant Bikram
Choudhurys orders, and being surrounded by people who were themselves obedient and enforced
Defendant Bikram Choudhurys rules on others. Plaintiff didnt know where to go. Assisting with
TT and Defendant Bikram Choudhury kept her almost too busy to think -- laundering towels,
leading classes, and preparing Defendant Bikram Choudhurys room.
97. Still in shock and on auto-pilot, Plaintiff proceeded to do her work and
ended up going back to Defendant Bikram Choudhurys suite to do her chores. She was under the
belief that he had left the room. She was mentally undone; all that Plaintiff could think was that she
did not want to get in trouble for not having fruit in the room. Defendant Bikram Choudhury was
shopping with his daughter when Plaintiff encountered his niece, Paloma, who said, Bikram has
been looking for you. Paloma made a gun shape with her hand and finger, pointed at her and then
shot Jane Doe No. 1, which was the first of many vaguely threatening gestures Defendant Bikram
Choudhurys other followers made to her after the assault.
98. Later in the day, Jane Doe No. 1 started to cry at a staff meeting. No one
asked her what was wrong.
99. Jane Doe No. 1 attended evening lecture, as she was required to, as
Defendant Bikram Choudhury ranted about sex being just an exchange of energy and ones
karma/destiny. Plaintiff knew he was talking about her and the fact that he raped her, and that he
was trying to minimize his actions and dress up the attack in spiritual language. Jane Doe No. 1 felt
frozen, alone, and terrified.
100. Defendant Choudhury stayed off-site that weekend and Plaintiff did not see
him for a couple of days. Plaintiff was still processing everything and was in a state of shock. She
was trying to figure out how to make her escape.
101. Jane Doe No. 1 was still in shock and still felt trapped. She did not know
what to do, so she continued work robotically.
102. Plaintiff does not have very many specific memories from the second attack,
which occurred early in the morning on Tuesday.

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103. On the night of the second attack, Plaintiff was isolated from other staff
members and again left alone with Defendant Bikram Choudhurys who continued to demand
massages from her in front of the trainees. She felt trapped. S.C., Bikrams family friend, was the
last one left with her and Bikram. Defendant Bikram Choudhurys looked over at S.C. and said, I
have no self-control. At this point, completely demoralized from the first encounter she felt
trapped and knew no way out of her situation. Over the weekend her room had been moved closer
to Defendant Bikram Choudhurys in an attempt to consolidate rooms because O.Z. was sent to
India.
104. The second rape occurred early on Tuesday morning. Bikram caught her
alone as she was doing her chores and would not let her leave. When Defendant Bikram Choudhury
raped her the second time, Plaintiff Jane Doe No. 1 remembers thinking, I cant believe this is
going to happen again, and responding by completely freezing up. Defendant Bikram Choudhury
ordered her onto the bed and said this time he was going to cum. The Plaintiff could not feel in
her body, she felt disassociated. She could not run or act. Plaintiff remembers feeling that his
sexual assaults were incestuous; like a family member attacking her. Defendant Bikram Choudhurys
eventually pulled out, ejaculated on her abdomen, threw a towel on her face and walked off to
answer his phone.
105. Plaintiff Jane Doe No. 1 was finally able to escape the hotel room and went
to her room to collapse on her bed, nearly catatonic. When Plaintiff showed her face at a staff
meeting another staff member commented on how bad she looked and then said, You really took
one for the team. It was s deeply hurtful comment and , to this day, it is not clear to her what this
staff member meant by that.
106. Later J.R. questioned Plaintiff and expressly asked her if Defendant
Choudhury had raped her. Plaintiff didnt say yes or no, she was simply too traumatized to speak.
107. It appeared to Plaintiff that J.R. sensed something was wrong with Plaintiff
and stayed up with her that night. J.R. never left Plaintiff alone with Defendant Choudhury again.
When it was time to go up to his room to do her duties, J.R. walked with Plaintiff and Defendant
Choudhury, and carried his bag.

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108. On one occasion, Defendant Choudhury left them both at the door and
pointed at J. and said, You this time. Plaintiff just stood there with her, and J.R. pleaded, [Jane
Doe 1] dont leave me. Even after all of the trauma she had suffered, Plaintiff Jane Doe No. 1
summoned enough strength and courage to try and protect J.R. from Defendant Choudhury.
Plaintiff Jane Doe No. 1 stayed with J.R. went into the room with her, and they massaged Defendant
Bikram Choudhury (who was complaining of how much his body hurt) together until he fell asleep.
Both Plaintiff and J.R left the room shortly thereafter.
109. Soon after the rapes, Plaintiff developed a severe urinary tract infection. She
was in constant fear that that Defendant had given her an STD. She wanted to escape. Plaintiff
feared not being able to support herself if she was not allowed to teach yoga, if she were to be black
listed by Defendants and the community.
110. Plaintiff Jane Doe No. 1 finally found a way to escape TT a few days after
the second rape by borrowing money from her mother. Upon her departure she told another
teacher to protect the girls.
111. After Plaintiff left, A. the employee who had recruited her to work at the TT
kept calling and kept trying to get her to talk to Defendant Bikram Choudhury to say, Goodbye
because it was a nice thing to do.
112. In November of 2012, Plaintiff Jane Doe No. 1 briefly returned to TT to see
if she could face her attacker and to visit three of the female students and warned them not to be
alone with him. One trainee was asked up to his suite and was given the advice to not go alone, so
she took a friend. She was able to get away.
113. Plaintiff lived in fear of telling anyone about the rapes. She kept hearing
Defendant Bikram Choudhurys voice in her head saying over and over again that No one fucks
with me, and that people who were disloyal had mysterious ill fortune happen upon them, and No
one goes against me.
114. As a consequence of Defendant Bikram Choudhury actions, and in particular
the rapes, Plaintiff suffered severe and debilitating emotional distress. She was barely able to work

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and went into a deep depression. For a period of time she was afraid to go to the police because she
feared Defendant Bikram Choudhury might find her and harm her.
115. After Sarah Baughn came forward about her assault, and Plaintiff surmised
that she was not alone, Plaintiff felt that she could no longer stay silent. She wanted to stop
Defendant Bikram Choudhury, make him accountable for the harm he caused and protect other
girls.
116. On March 19, 2013 Defendant Bikram Choudhury called Plaintiff Jane Doe
No. 1 asking for forgiveness and asked her to turn the other cheek in an effort to try to
manipulate her, and to keep her from speaking out about what had happened to her. At this point
she knew that this was a pattern for him, after she had been raped in October of 2011 she realized
that there were probably other girls whom Defendant Bikram Choudhury harassed, solicited, bullied,
assaulted or raped.
117. Defendant Bikram Choudhury tried to guilt her into keeping quiet by saying
that the whole community depended upon her forgiving him, even her health was at stake. Plaintiff
Jane Doe No. 1 said that she was perfectly strong in body and said she really did not know what he
was talking about. Defendant Bikram Choudhury told her, As your teacher, I do not want you to
hold on to this.
118. Now that Plaintiff Jane Doe No. 1 was outside of TT she knew full well that
he was lying and said, You are not my teacher. How do I know you are not going to do it again to
another girl? To which the Defendant Bikram Choudhury replied, You are the only one whose
advice I would seek in the whole world, what do you think I should do? Defendant Bikram
Choudhury tried to have her meet with him for tea, like old times, which thoroughly confused
Plaintiff because she never met him outside of TT or outside of the context of him being her
teacher. Plaintiff Jane Doe No. 1 replied, I do not trust you. Oddly, Defendant Choudhury then
asked Plaintiff Jane Doe No. 1 she was and commented that she looked like she was 15.
119. Plaintiff was so enraged by Defendant Bikram Choudhury callousness that she sent
an email to Defendants instructing them to have no contact with her or she would seek a
restraining order.

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120. On March 26, 2013, after Plaintiff expressly asked for no contact, she received an
email from Defendant Bikram Choudhury stating that he was naming Petra Starke the new
President and CEO of Yoga College, and another press release appeared on the Bikram Yoga
website apparently responding to the allegations of the Baughn complaint. The press release stated
that Defendant Choudhury was disappointed by the false charges made in this lawsuit, but then,
paradoxically, claimed that he will not comment at this time.
121. The March 26, 2013 press release was originally signed by Petra Starke, President --
Bikrams Yoga College of India LLP. There is no such entity registered with the California
Secretary of State. In a later draft, the entity was correctly identified as Bikrams College of India
LP.
122. On March 27, 2013, Plaintiff Jane Doe No. 1 reported the rapes to her local police
whom she expected would communicate the report to LAPD.
123. On about April 4, 2013, again, in direct contravention of her instruction to have no
contact, she received an email from Defendant Bikram Choudhury, announcing that the Yoga
College had a change in leadership. A press release was disseminated to the Yoga College mailing
list that attorney Petra Starke was the new President and CEO of Yoga College, a limited
Partnership. That announcement expressly touted Petra Starkes prior positions at the White
House as Deputy Associate Counsel to President Barack Obama, President of the United States of
America, and General Counsel for the Council of Economic Advisors. The press release also
mentioned that Petra Starke practiced law for approximately 7 years with the highly respected law
firm of OMelveny & Myers, LLP in Washington, D.C. The press release was simply signed
Bikram. As of the date of the press release, Plaintiff is informed and believes that Petra Starke
was still listed on White House website as a current White House employee.
124. Plaintiff is informed and believes that that announcement was in reference to
the lawsuit filed by Sarah Baughn (Baughn v. Bikram Choudhury, et al, Los Angeles County
Superior Court Case No. BC502424 [the Baughn Complaint]) on March 7, 2013 and was intended
to have a chilling effect on other victims and on witnesses who supported Sarah Baughn and other
victims. Plaintiff is informed and believes that as a result of the press coverage surrounding the

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Baughn Complaint, other women began coming forward about their own experiences and, it
appeared that Defendants and their attorney wanted them silenced and wanted to stop them from
pursuing their claims.
125. On information and belief, Defendant Bikram Choudhury and people in his
inner circle began contacting women who he believed had legal claims against him or people who
were witnesses to Defendant Choudhurys interactions with Sarah Baughn or with others victims to
discourage them from coming forward.
126. On information and belief, these phone calls were meant to determine who
might testify against Defendant Choudhury, to discourage witnesses, and perhaps even to implicitly
threaten those who Defendant Choudhury knew could bring legal claims against him. On
information and belief, some witnesses and possible plaintiffs were in fact intimidated by these
phone calls and considered them to be threatening.
127. On information and belief, the March 26 and April 4 press releases were
meant to intimidate witnesses and potential claimants. Defendant Bikram Choudhury has a history
of threatening that he will crush anyone who goes against him and of publicly claiming personal
relationships with past presidents of the United States, including Richard Nixon, Ronald Reagan,
and Bill Clinton, and with other people in high places. Plaintiff is informed and believes that
Defendants hiring of Petra Starke, and his express reference to her White House connection, was a
way of further threatening and intimidating victims and witnesses.
128. On information and belief, Defendant Starkes Linked In Profile listed her
as a White House employee as recently as April 11, 2013, sixteen days after she first publicly signed a
Press Release as President of a Bikram entity.
129. On information and belief, as of April 29, 2013, the White House web page
still listed Ms. Starke as the General Counsel to the Council for Economic Advisors. Plaintiff is
informed and believes that this series of facts creates the impression that Defendant Starke worked
for Defendant Yoga College and implicitly referenced Sarah Baughns lawsuit as containing false
charges while still an employee of the White House, part of the Executive Branch that is
responsible for enforcing the law of the land.

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FIRST CAUSE OF ACTION
SEXUAL BATTERY IN VIOLATION OF CALIFORNIA CIVIL CODE 1708.5
Against all Defendants
130. Plaintiff Jane Doe No. 1 incorporates by reference as though fully set forth
herein, each and every allegation set forth above in this Complaint. As a first separate and distinct
claim for relief, Plaintiff Jane Doe No. 1 complains against all Defendants as follows:
131. California Civil Code 1708.5 provides as follows:
(a) A person commits a sexual battery who does any of the
following:
(1) Acts with the intent to cause a harmful or offensive contact
with an intimate part of another, and a sexually offensive contact
with that person directly or indirectly results.
(2) Acts with the intent to cause a harmful or offensive contact
with another by use of his or her intimate part, and a sexually
offensive contact with that person directly or indirectly results.
(3) Acts to cause an imminent apprehension of the conduct
described in paragraph (1) or (2), and a sexually offensive contact
with that person directly or indirectly results.
(b) A person who commits a sexual battery upon another is liable
to that person for damages, including, but not limited to, general
damages, special damages, and punitive damages.
(c) The court in an action pursuant to this section may award
equitable relief, including, but not limited to, an injunction,
costs, and any other relief the court deems proper.
(d) For the purposes of this section "intimate part" means the
sexual organ, anus, groin, or buttocks of any person, or the breast
of a female.
(e) The rights and remedies provided in this section are in

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addition to any other rights and remedies provided by law.
(f) For purposes of this section "offensive contact" means contact
that offends a reasonable sense of personal dignity.
132. Plaintiff Jane Doe No. 1 alleges that Defendant Bikram Choudhury
committed the act of civil sexual battery in violation of California Civil Code 1708.5, when, on two
occasions in the Fall of 2011 when Plaintiff was working for Defendants Bikram Choudhury, at the
Radisson Hotel in Los Angeles, California, Defendant Bikram Choudhury, willfully, maliciously,
intentionally and without the consent of Plaintiff Jane Doe No. 1 subjected to forceful, harmful
and/or offensive touching of Plaintiff Jane Doe No. 1s breasts, buttocks and vagina, including
viciously raping Plaintiff by way of vaginal penetration with his unprotected penis, potentially
exposing her to unknown sexually transmitted diseases, against her will, without her consent, and
in spite of her express objection.
133. Plaintiff Jane Doe No. 1 is informed and believe and otherwise alleges that
Defendants BIKRAMS YOGA COLLEGE OF INDIA, L.P., a California Limited Partnership, and
DOES 1-25 are strictly liable for Defendants actions under the principles of respondeat superior, as
alleged herein and otherwise had advance knowledge that Defendant Choudhury would engage in
this despicable conduct and by their actions and inactions ratified, authorized and condoned this
unlawful behavior.
134. As a direct and proximate result of Defendant Bikram Choudhurys unlawful
conduct, Plaintiff Jane Doe No. 1 has suffered severe emotional distress, humiliation,
embarrassment, mental and emotional distress and anxiety, all in an amount according to proof at
trial.
135. As a direct and proximate result of Defendant Bikram Choudhurys unlawful
conduct, Plaintiff Jane Doe No. 1 has suffered economic harm and other consequential damages all
in an amount according to proof at trial.
136. The acts of Defendant Bikram Choudhury, as alleged herein were willful,
wanton, and malicious and were intended to oppress and cause injury to Plaintiff Jane Doe No. 1.

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In light of the willful, wanton, malicious and intentional conduct engaged in by Defendant Bikram
Choudhury, Plaintiff Jane Doe No. 1 is entitled to an award of punitive damages.
137. Plaintiff Jane Doe No. 1 also seeks declaratory and injunctive relief as set
forth below.
Wherefore, Plaintiff Jane Doe No. 1 prays for judgment against Defendants as set forth below.
forth below.
139. Plaintiff has incurred, and will continue to incur, attorneys fees in the
prosecution of this action and therefore demand such reasonable attorneys fees and costs as set by
the court.
WHEREFORE, Plaintiff prays for relief as set forth herein.

SECOND CAUSE OF ACTION

CIVIL ACTION FOR GENDER VIOLENCE IN VIOLATION OF CALIFORNIA CIVIL CODE 52.4
herein, each and every allegation set forth above in this Complaint. As a second separate and
distinct claim for relief, Plaintiff Jane Doe No. 1 complains against all Defendants as follows:
141. California Civil Code Section 52.4 provides:
(a) Any person who has been subjected to gender violence may
bring a civil action for damages against any responsible party. The
plaintiff may seek actual damages, compensatory damages, punitive
damages, injunctive relief, any combination of those, or any other
appropriate relief. A prevailing plaintiff may also be awarded
attorney's fees and costs.
(b) An action brought pursuant to this section shall be commenced
within three years of the act, or if the victim was a minor when the
act occurred, within eight years after the date the plaintiff attains

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the age of majority or within three years after the date the
plaintiff discovers or reasonably should have discovered the
psychological injury or illness occurring after the age of majority
that was caused by the act, whichever date occurs later.
(c) For purposes of this section, "gender violence," is a form of
sex discrimination and means any of the following:
(1) One or more acts that would constitute a criminal offense
under state law that has as an element the use, attempted use, or
threatened use of physical force against the person or property of
another, committed at least in part based on the gender of the
victim, whether or not those acts have resulted in criminal
complaints, charges, prosecution, or conviction.
(2) A physical intrusion or physical invasion of a sexual nature
under coercive conditions, whether or not those acts have resulted in
criminal complaints, charges, prosecution, or conviction.
(d) Notwithstanding any other laws that may establish the
liability of an employer for the acts of an employee, this section
does not establish any civil liability of a person because of his or
her status as an employer, unless the employer personally committed
an act of gender violence.
142. Plaintiff Jane Doe No. 1 alleges that Defendant Bikram Choudhury violated
California Civil Code Section 52.4 in that one or more acts inflicted on Plaintiff constitutes a
criminal offense under state law that has as an element of use, attempted use, or threatened use of
physical force against the person or property of another, committed at least in part based on the
gender of the victim, whether or not those acts have resulted in criminal complaints, charges,
prosecution, or conviction.
143. Plaintiff Jane Doe alleges that Defendant Bikram Choudhury violated
California Civil Code Section 52.4 in that he engaged in a physical intrusion or physical invasion of a

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sexual nature under coercive conditions, even if those acts have not yet resulted in criminal
complaints, charges, prosecution, or conviction.
144. As direct and proximate result of Defendant Bikram Choudhurys violated
California Civil Code Section 52.4, Plaintiff Jane Doe No. 1 suffered severe emotional distress, post
traumatic stress disorder, humiliation, embarrassment, mental and emotional distress and anxiety, all
in an amount according to proof at trial.
145. As direct and proximate result of Defendant Bikram Choudhurys violation
of California Civil Code Section 52.4, Plaintiff Jane Doe No. 1 suffered economic harm and other
consequential damages all in an amount according to proof at trial.
wanton, and malicious and were intended to oppress and cause injury to Plaintiff Jane Doe No. 1. In
light of the willful, wanton, malicious and intentional conduct engaged in by Defendant Bikram
forth below.
the court.

THIRD CAUSE OF ACTION
CIVIL ACTION FOR DAMAGES FOR VIOLATION OF HUMAN TRAFFICKING IN VIOLATION OF
CALIFORNIA CIVIL CODE 52.5
herein, each and every allegation set forth above in this Complaint. As a third separate and distinct
claim for relief, Plaintiff Jane Doe No. 1 complains against all Defendants as follows:
150. California Civil Code 52.5 provides as follows:

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(a) A victim of human trafficking, as defined in Section
236.1 of the Penal Code, may bring a civil action for actual damages,
compensatory damages, punitive damages, injunctive relief, any
combination of those, or any other appropriate relief. A prevailing
plaintiff may also be awarded attorney's fees and costs.
(b) In addition to the remedies specified herein, in any action
under subdivision (a), the plaintiff may be awarded up to three times
his or her actual damages or ten thousand dollars ($10,000),
whichever is greater. In addition, punitive damages may also be
awarded upon proof of the defendant's malice, oppression, fraud, or
duress in committing the act of human trafficking.
(c) An action brought pursuant to this section shall be commenced
within five years of the date on which the trafficking victim was
freed from the trafficking situation, or if the victim was a minor
when the act of human trafficking against the victim occurred, within
eight years after the date the plaintiff attains the age of
majority.
(d) If a person entitled to sue is under a disability at the time
the cause of action accrues, so that it is impossible or
impracticable for him or her to bring an action, then the time of the
disability is not part of the time limited for the commencement of
the action. Disability will toll the running of the statute of
limitation for this action.
(1) Disability includes being a minor, insanity, imprisonment, or
other incapacity or incompetence.
(2) The statute of limitations shall not run against an
incompetent or minor plaintiff simply because a guardian ad litem has
been appointed. A guardian ad litem's failure to bring a plaintiff's

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action within the applicable limitation period will not prejudice
the plaintiff's right to do so after his or her disability ceases.
(3) A defendant is estopped to assert a defense of the statute of
limitations when the expiration of the statute is due to conduct by
the defendant inducing the plaintiff to delay the filing of the
action, or due to threats made by the defendant causing duress upon
the plaintiff.
(4) The suspension of the statute of limitations due to
disability, lack of knowledge, or estoppel applies to all other
related claims arising out of the trafficking situation.
(5) The running of the statute of limitations is postponed during
the pendency of any criminal proceedings against the victim.
(e) The running of the statute of limitations may be suspended
where a person entitled to sue could not have reasonably discovered
the cause of action due to circumstances resulting from the
trafficking situation, such as psychological trauma, cultural and
linguistic isolation, and the inability to access services.
(f) A prevailing plaintiff may also be awarded reasonable attorney's fees and
litigation costs including, but not limited to, expert
witness fees and expenses as part of the costs.
(g) Any restitution paid by the defendant to the victim shall be
credited against any judgment, award, or settlement obtained pursuant
to this section. Any judgment, award, or settlement obtained
pursuant to an action under this section shall be subject to the
provisions of Section 13963 of the Government Code.
(h) Any civil action filed under this section shall be stayed
during the pendency of any criminal action arising out of the same
occurrence in which the claimant is the victim. As used in this

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section, a "criminal action" includes investigation and prosecution,
and is pending until a final adjudication in the trial court, or
dismissal.

151. California Penal Code 236.1 provides:
236.1. (a) Any person who deprives or violates the personal liberty
of another with the intent to obtain forced labor or services, is
guilty of human trafficking and shall be punished by imprisonment in
the state prison for 5, 8, or 12 years and a fine of not more than
five hundred thousand dollars ($500,000).
(b) Any person who deprives or violates the personal liberty of
another with the intent to effect or maintain a violation of Section
266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6,
or 518 is guilty of human trafficking and shall be punished by
imprisonment in the state prison for 8, 14, or 20 years and a fine of
not more than five hundred thousand dollars ($500,000).
(c) Any person who causes, induces, or persuades, or attempts to
cause, induce, or persuade, a person who is a minor at the time of
commission of the offense to engage in a commercial sex act, with the
intent to effect or maintain a violation of Section 266, 266h, 266i,
266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6, or 518 is
guilty of human trafficking. A violation of this subdivision is
punishable by imprisonment in the state prison as follows:
(1) Five, 8, or 12 years and a fine of not more than five hundred
thousand dollars ($500,000).
(2) Fifteen years to life and a fine of not more than five hundred
thousand dollars ($500,000) when the offense involves force, fear,
fraud, deceit, coercion, violence, duress, menace, or threat of

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unlawful injury to the victim or to another person.
(d) In determining whether a minor was caused, induced, or
persuaded to engage in a commercial sex act, the totality of the
circumstances, including the age of the victim, his or her
relationship to the trafficker or agents of the trafficker, and any
handicap or disability of the victim, shall be considered.
(e) Consent by a victim of human trafficking who is a minor at the
time of the commission of the offense is not a defense to a criminal
prosecution under this section.
(f) Mistake of fact as to the age of a victim of human trafficking
who is a minor at the time of the commission of the offense is not a
defense to a criminal prosecution under this section.
(g) The Legislature finds that the definition of human trafficking
in this section is equivalent to the federal definition of a severe
form of trafficking found in Section 7102(8) of Title 22 of the
United States Code.
(h) For purposes of this chapter, the following definitions apply:
(1) "Coercion" includes any scheme, plan, or pattern intended to
cause a person to believe that failure to perform an act would result
in serious harm to or physical restraint against any person; the
abuse or threatened abuse of the legal process; debt bondage; or
providing and facilitating the possession of any controlled substance
to a person with the intent to impair the person's judgment.
(2) "Commercial sex act" means sexual conduct on account of which
anything of value is given or received by any person.
(3) "Deprivation or violation of the personal liberty of another"
includes substantial and sustained restriction of another's liberty
accomplished through force, fear, fraud, deceit, coercion, violence,

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duress, menace, or threat of unlawful injury to the victim or to
another person, under circumstances where the person receiving or
apprehending the threat reasonably believes that it is likely that
the person making the threat would carry it out.
(4) "Duress" includes a direct or implied threat of force,
violence, danger, hardship, or retribution sufficient to cause a
reasonable person to acquiesce in or perform an act which he or she
would otherwise not have submitted to or performed; a direct or
implied threat to destroy, conceal, remove, confiscate, or possess
any actual or purported passport or immigration document of the
victim; or knowingly destroying, concealing, removing, confiscating,
or possessing any actual or purported passport or immigration
document of the victim.
(5) "Forced labor or services" means labor or services that are
performed or provided by a person and are obtained or maintained
through force, fraud, duress, or coercion, or equivalent conduct that
would reasonably overbear the will of the person.
(6) "Great bodily injury" means a significant or substantial
physical injury.
(7) "Minor" means a person less than 18 years of age.
(8) "Serious harm" includes any harm, whether physical or
nonphysical, including psychological, financial, or reputational
harm, that is sufficiently serious, under all the surrounding
circumstances, to compel a reasonable person of the same background
and in the same circumstances to perform or to continue performing
labor, services, or commercial sexual acts in order to avoid
incurring that harm.
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relationship between the victim and the trafficker or agents of the
trafficker, and any handicap or disability of the victim, shall be
factors to consider in determining the presence of "deprivation or
violation of the personal liberty of another," "duress," and
"coercion" as described in this section.
152. Plaintiff Jane Doe No. 1 contends that she was a victim of human trafficking
at the hands of Defendants because she was deprived or experienced violation of her personal
liberty by Defendants with the intent to obtain forced labor or services. Plaintiff was coerced by
Defendants by way of a scheme, plan, or pattern intended to cause Plaintiff to believe that failure to
perform work or acts demanded of by Defendants would result in serious harm to Plaintiff to or
physical restraint against Plaintiff; the abuse or threatened abuse of the legal process and/or debt
bondage.
of California Civil Code Section 52.5, Plaintiff Jane Doe No. 1 suffered severe emotional distress,
humiliation, embarrassment, mental and emotional distress and anxiety, all in an amount according
to proof at trial.
of California Civil Code Section 52.5, Plaintiff Jane Doe No. 1 suffered economic harm and other
consequential damages all in an amount according to proof at trial.
wanton, and malicious and were intended to oppress and cause injury to Plaintiff Jane Doe No. 1. In
light of the willful, wanton, malicious and intentional conduct engaged in by Defendant Bikram
forth below.
the court.

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FOURTH CAUSE OF ACTION
FALSE IMPRISONMENT
herein, each and every allegation set forth above in this Complaint. As a fourth separate and distinct
claim for relief, Plaintiff Jane Doe No. 1 complains against all Defendants BIKRAM
CHOUDHURY, an individual, BIKRAMS YOGA COLLEGE OF INDIA, L.P., a California
Limited Partnership ,and DOES 1-25 as follows:
159. On about Friday October 21, 2011 and Monday October 24, 2011, Plaintiff
was subjected false imprisonment by Defendant BIKRAM CHOUDHURY when he lured her into
his hotel room, or otherwise entrapped her, at the Radisson Hotel in Los Angeles California and
prevented Plaintiff from leaving his room while he forcibly raped her, as herein alleged.
160. Defendant BIKRAM CHOUDHURY intended to confine and in fact
confined Plaintiff against her will for an appreciable period of time of at least thirty (30) minutes or
more.
161. At no time did Plaintiff consent to any of the acts of Defendant BIKRAM
CHOUDHURY, as alleged herein.
162. Plaintiff Jane Doe No. 1 suffered severe emotional distress as a legal result of
the confinement by Defendants of which Plaintiff Jane Doe No. 1 complains. Specifically, Plaintiff
Jane Doe No. 1 suffered post traumatic stress disorder, mental distress, indignity, great humiliation,
emotional distress manifesting in physical symptoms, humiliation, embarrassment, anger,
disappointment and worry, all of which is substantial and enduring.
163. Defendants actions have caused and continue to cause Plaintiff substantial
losses in earnings, significant professional injury and other economic harm as well as medical
expenses, future earnings and benefits, cost of suit, humiliation, embarrassment and anguish, all to
his damage in an amount according to proof.

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164. At all material times, Defendants, and each of them, knew that Plaintiff Jane
Doe No. 1 depended on her income as a yoga teacher for her livelihood. At all material times,
Defendants were in a position of power over Plaintiff Jane Doe No. 1 physically and financially --
with the potential to abuse that power.
165. Plaintiff Jane Doe No. 1 was in a vulnerable position because she was in a
physically weakened physical and emotional state due to sleep deprivation and malnutrition having
worked for Defendants at the Bikram Yoga TT Los Angeles of nearly 8 weeks (two 90 minute hot
yoga sessions a day, 3 hours a sleep a night and minimal food intake), because of her small size and
stature, relative lack of power, because of she had placed her trust in Defendants, because she
depended on her Defendants for her self esteem and sense of belonging, because she relied upon
employment as a yoga teacher as source of income. Defendants were aware of Plaintiff's
vulnerability and the reasons for it.
166. Notwithstanding such knowledge, Defendants, and each of them, acted
oppressively, fraudulently, and maliciously, in willful and conscious disregard of Plaintiff's rights, and
with the intention of causing or in reckless disregard of the probability of causing injury and
emotional distress to Plaintiff Jane Doe No. 1. Further, Defendants were informed of the
oppressive, fraudulent and malicious conduct of their employees, agents and subordinates, and
ratified, approved, and authorized that conduct. The acts of Defendants, as alleged herein, were
willful, wanton, and malicious and were intended to oppress and cause injury to Plaintiff. In light of
the willful, wanton, malicious and intentional conduct engaged in by Defendant, Plaintiff is entitled
to an award of punitive damages.
forth below.
the court.
WHEREFORE, Plaintiff prays for judgment against Defendants as set forth below.

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FIFTH CAUSE OF ACTION
SEX-BASED DISCRIMINATION IN VIOLATION OF THE
UNRUH CIVIL RIGHTS ACT [CALIFORNIA CIVIL CODE 51]
(Jane Doe No. 1Against All Defendants)
169. Plaintiff, individually, incorporates by reference as though fully set forth
herein, each and every allegation set forth above in this Complaint. As a separate and distinct cause
of action, Plaintiff complains against Defendants as follows:
170. California Civil Code section 51, et seq., also known as the Unruh Civil
Rights 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.
171. Plaintiff, a female, 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 plaintiffs sex (female), and therefore constituted a violation
of the Unruh Civil Rights Act.
172. 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
benefits, loss of future employment benefits, including insurance and pension, , all in an amount to
be proven at trial but exceeding the minimum jurisdictional limits of this court.
them, Plaintiff has suffered harm, including severe emotional distress, embarrassment, mental
anguish, and physical harm, all in an amount to be proven at trial but exceeding the minimum
jurisdictional limits of this court.
174. 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 actions were, and are,

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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.
forth below.
the court.
SIXTH CAUSE OF ACTION
SEXUAL HARASSMENT IN VIOLATION OF THE
UNRUH CIVIL RIGHTS ACT [CALIFORNIA CIVIL CODE 51.9]
(Against All Defendants)
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:
178. Civil Code section 51.9, also part of the Unruh Civil Rights Act, provides
that a defendant is liable for sexual harassment where there is a professional relationship between
the plaintiff and defendant, including the teacher-student relationship and The defendant has 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
gender, that were unwelcome and pervasive or severe.
179. At all times herein mentioned, there was a professional relationship between
plaintiff and the Defendants, namely, that she was Defendants student and that they taught her
Bikram Yoga and certified her as an instructor.
180. In or about Spring of 2011, defendant Choudhury began making sexual
advances on Plaintiff. He eventually demanded sexual compliance, and when it was denied to him,
sexually assaulted her, twice and continued to retaliate against her for refusing his sexual advances.

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181. Plaintiff cannot easily terminate her relationship with defendant without
tangible hardship because she is an experienced and accomplished practitioner of Bikram Yoga, and
her considerable expertise would be difficult to otherwise employ, particularly because of Defendant
Choudhurys control over other practitioners of that form of Hatha Yoga. Terminating the
relationship would cause her great financial hardship, as she would no longer be able to teach at
approved Bikram studios.
182. Plaintiff is informed and believed and thereon alleges that the
services to Plaintiff, based solely upon plaintiffs refusal to submit to sexual advances, and therefore
constituted a violation of the Unruh Act.
benefits, loss of future employment benefits, all in an amount to be proven at trial but exceeding the
minimum jurisdictional limits of this court.
them, Plaintiff has suffered harm, including severe emotional distress, humiliation, embarrassment,
mental anguish, and physical harm, all in an amount to be proven at trial but exceeding the
forth below.

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the court.
SEVENTH CAUSE OF ACTION
VIOLATION OF THE RALPH ACT [CALIFORNIA CIVIL CODE 51.7]
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:
189. Civil Code section 51.5, the Ralph Act, provides that persons have the right
to be free from violence or threat of violence, committed against their persons or property due to,
among other things, their gender.
190. On or about Spring 2011, Defendant Bikram Choudhury began making
sexual advances on Plaintiff. These advances were physical and verbal in nature, at times involving
touching the person of plaintiff and/or making inappropriate sexual comments, and eventually
culminating in two violent sexual assaults.
191. Plaintiffs sex was the reason for Defendants unwanted physical contact and
ultimate sexual assault.
discriminated or made a distinction that denied Plaintiff full and equal advantages, privileges, and
services to Plaintiff, based solely upon plaintiffs refusal to submit to sexual advances and her
objections to the physical assault that was inflicted upon her, and therefore constituted a violation of
the Ralph Act.

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them, Plaintiff has suffered harm, including but not limited to sever emotional distress, 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.
forth below.
the court.
EIGHTH CAUSE OF ACTION
INTERFERENCE WITH THE EXERCISE OF CIVIL RIGHTS
IN VIOLATION OF THE BANE ACT [CALIFORNIA CIVIL CODE 52.1]
herein, each and every allegation set forth above in this Complaint. As an eighth separate and
199. Civil Code section 52.1, the Bane Act, provides that it is unlawful to interfere
with the exercise or enjoyment of any rights under the Constitution and laws of this state and the
United States by use or attempted use of threats, intimidation or coercion.

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200. At all times herein mentioned, there was a professional relationship between
plaintiff and the Defendants, namely, that plaintiff was a student whom they taught Bikram Yoga
and certified as an instructor.
201. On or about Spring of 2011, defendant Choudhury began making sexual
advances on Plaintiff. These advances were at times physical and violent in nature, at times involved
touching the person of plaintiff while making sexual comments and eventually culminated in violent
sexual assault.
202. Under Civil Code 51, Plaintiff has the right to full and equal
accommodation and service in all business establishments within the state, and may not be refused
entry or service because of her gender.
203. Plaintiffs sex was the reason for Defendants unwanted physical contact and
ultimate sexual assault.
services to Plaintiff, based solely upon plaintiffs refusal to submit to sexual advances and her
objections to the physical assault that was inflicted upon her, and therefore constituted a violation of
the Bane Act.
them, Plaintiff has suffered harm, including severe emotional distress, humiliation, embarrassment,
mental anguish, and physical harm, all in an amount to be proven at trial but exceeding the

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NINTH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
208. 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:
209. This is an action for 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.
210. 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.
211. As a proximate result of the extreme and outrageous conduct engaged in by
Defendants, Plaintiff suffered severe emotional distress, humiliation, mental anguish and extreme
emotional and physical distress all to her general damage in an amount according to proof at trial.
benefits, loss of future employment benefits, including insurance and pension, humiliation, all in an
amount to be proven at trial but exceeding the minimum jurisdictional limits of this court.
213. Defendants conduct as herein alleged was malicious and oppressive in that it
was conduct carried on by Defendants in a willful and conscious disregard of Plaintiffs rights and
subjected her to cruel and unjust hardship. Plaintiff is therefore entitled to an award of punitive
damages against Defendants.

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214. 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.
TENTH CAUSE OF ACTION
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
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:
216. Defendants owed Plaintiff a duty of care not to cause her emotional distress.
217. Defendants breached this duty of care by way of their own conduct as
alleged herein.
218. Defendants conduct from 2004 and continuing in the present has caused
Plaintiff emotional distress.
219. As a proximate result of Defendants extreme and outrageous acts, Plaintiff
has suffered emotional distress, humiliation and embarrassment.
220. Defendants conduct has caused and continues to cause Plaintiff substantial
losses in earnings, significant reputation and professional injury, medical expenses, future earnings
and benefits, costs of suit, embarrassment and anguish, all to her damage in an amount according to
proof.
ELEVENTH CAUSE OF ACTION
NEGLIGENCE

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herein, each and every allegation set forth above in this Complaint. As an eleventh, separate and
222. Defendants and Does 1-25 inclusive, in their individual capacities and official
capacities, committed the negligent actions and/or negligent failures to act, as set forth herein above
and those acts proximately caused the emotional, physical and financial injuries visited upon
plaintiff.
223. Plaintiff brings this action and claim for damages from said Defendants for
negligent actions and failures to act, and the resulting injuries and damages.
224. As a proximate result of Defendants extreme and outrageous acts, Plaintiff
has suffered emotional distress, humiliation and embarrassment.
225. Defendants conduct has caused and continues to cause Plaintiff substantial
losses in earnings, significant reputation and professional injury, medical expenses, future earnings
and benefits, costs of suit, embarrassment and anguish, all to her damage in an amount according to
proof.
TWELFTH CAUSE OF ACTION
CLAIM FOR DECLARATORY AND INJUNCTIVE RELIEF
226. Plaintiff incorporates by reference as though fully set forth herein, each and
every allegation set forth above in this Complaint. As a twelfth, separate and distinct claim for relief,
Plaintiff complains against Defendants and each of them, as follows:
1. For all the reasons set forth above, Plaintiff seeks a declaration from the
Court that the contracts she signed with Defendants are void. Plaintiff seeks a further declaration
from the Court that Defendant Bikram Choudhury behavior is that of a sexual predator and that
his words and conduct at the Bikram Yoga TT violates the civil rights of women under the
various Acts alleged above;.
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2. Further, Plaintiff seeks a Court Order enjoining Defendant Bikr
Choudhury from (a) being alone with any female student during IT; prohibiting Defendant Bikra
Choudhury from making sexual comments or comments of a sexual nature at IT; and (c) debasin
or humiliating women in word or conduct..
PRAYER FOR REUEF
Wherefore Plaintiff Jane Doe No.1 prays for judgment against Defendants, and each of
them, as follows:
1. For a money judgment representing compensatory damages including consequential
damages, lost wages, earnings, and all other sums of money, together with 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;
3. Punitive damages, according to proof;
4. For attorney's fees and costs;
5. For an additional statutory civil penalty in the sum of $25,000, pursuant to Civ. Code
52(b);
6. For an additional statutory civil penalties under Civil Code 52.5 and 52.5
6. For prejudgment and post-judgment interest;
7. For declaratory and injunctive relief; and
8. For any other relief that is just and proper.
Dated: May 6, 2013 SHEA LAW OFFICES
B y ~ ~ ~ b
Mary hea Hagebols
Attorney for Plaintiff Jane Doe No.1
JURY TRIAL DEMANDED
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Plaintiff Jane Doe No.1 demands trial of all issues by jury.
Dated: May 6, 2013 SHEA LAW OFFICES
By:
Mary Shea Hagebols
Attorney for Plaintiff Jane Doe No.1
52

Bikram - Jane Doe 1 - Complaint

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COMPLAINT FOR DAMAGES AND DECLARATORY AND INJUNCTIVE RELIEF

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