Taranjeet singh
SPNer
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO
S. PREMKA KAUR KHALSA,
Plaintiff,
vs.
HARBHAJAN SINGH KHALSA YOGIJI, a/k/a Harbhajan Puri, a/k/a/ Yogi Bhajan, a/k/a/ Sin Singh Sahib, Individually, and In His Capacity as the Sole Officer and Director of the Sin Singh Sahib of Sikh Dharma Brotherhood, a California Corporation, and in his Capacity as an Officer of the Sikh Dharma Brotherhood, a California Corporation, and in this capacity as an officer and director of the 3H0 Foundation, a California Corporation, and the '3HO Foundation of New Mexico, a New Mexico Corporation; and
SIRI SINGH SAHIB OF SIKH DHARMA
BROTHERHOOD, a California
Corporation; and
SIKH DHARMA BROTHERHOOD, a
California Corporation; and
3H0 FOUNDATION, a California
Corporation Licensed to do
Business in New Mexico;
and
Civil Action No. 86--0838 M SECOND AMENDED COMPLAINT
(For Fraud and Deceit;
Assault and Battery; False
Arrest and Imprisonment;
Intentional Infliction of
Severe Emotional Distress;
Violation of the Fair
Labor Standards Act; and
Invasion of Privacy.)
3H0 FOUNDATION OF NEW MEXICO, a New Mexico Corporation.
Defendants.
Parties Before the Court
Plaintiff, S. Premka Kaur Khalsa, is a adult citizen of the State of Hawaii.
Defendant Harbhajan Singh Khalsa Yogiji, formerly known as Harbhajan Puri, and also known as Yogi Bhajan and. Siri Singh Sahib, (hereinafter Bhajan), is an adult citizen of the State of California, with his principal residence at 1620 Preuss Road, Los Angeles, California 90035.
Defendant Sin Singh Sahib of Sikh Dharma Brotherhood is a corporation organized and doing business under the laws of the State of California, with its principal place of business located at 1649 Robertson Building, Los Angeles, California 90035. This corporation is of a unique type, known under California law as a corporation sole. (Hereinafter this corporation shall be referred to as the corporation sole.)
Defendant 3H0 Foundation is a corporation organized and doing business under the laws of the State of California, and doing business in the State of New Mexico under a Certificate of Authority issued by the New Mexico State Corporation Commission. The principal place of business of the 3H0 Foundation is located at 1649 Robertson Boulevard, Los Angeles, California 90035. 3H0 is an acronym for Healthy--Happy--Holy Organization.
Defendant Sikh Dharma Brotherhood is a corporation organized and doing business under the laws of the State of California, with its principal place of business located at 1649 Robertson Boulevard, Los Angeles, California. (To avoid confusion with a religious order in India called the Sikh Dharma Brotherhood, this corporate entity shall hereinafter be referred to as the Sikh Dharma Brotherhood Corporation.)
Defendant 3H0 Foundation of New Mexico is an affiliate of defendant 3H0 Foundation, and is a corporation organized and doing business under the laws of the State of New Mexico. The principal place of business of defendant 3H0 Foundation of New Mexico is Route 1, Box ].32--D, Espanola, New Mexico 87532.
Jurisdiction of this Court
Facts That Give Rise to this Complaint
COUNT I: FOR FRAUD AND DECEIT
Yogi Bhajan then made a number of false promises and misrepresentations of fact to the plaintiff in order to induce her to enroll in his yoga course, and later to induce hen to follow him as a spiritual teacher. Among the misrepresentations of fact which he made at their initial meeting were: (a) That if plaintiff enrolled in his yoga classes he would be able to teach her to be a yoga teacher in two months' time. (b) That as a yoga teacher, she would be able to tour Europe and stay at various ashrams throughout Europe. (c) That he would personally oversee the plaintiff's education and personally instruct her in Yoga if she became his follower. (d) That if the plaintiff studied under him, served him and agreed to stay with him, Bhajan would provide for all of the plaintiff's material needs for life. (e) That he was a high master of yoga, who had studied many years under various masters of yoga in India, was a skilled teacher of and was particularly skilled in the form of yoga called Kundalini yoga.
All of the foregoing representations were false, and Bhajan knew them to be false at the time he made them. They were made only for the purpose of inducing the plaintiff to enroll in Bhajan's yoga course, as a means by which he could covertly subject the plaintiff to the thought reform program described above.
WHEREFORE, under this Count the plaintiff respectfully prays this Honorable Court will grant the following relief: A. Entry of a judgment in favor of the plaintiff and against the defendants, jointly and severally, in the amount of $1.5 million in compensatory damages, plus punitive on exemplary damages, plus interest and all costs of suit. B. Such other relief as the Court may deem to be just and equitable after trial.
COUNT II: ASSAULT AND BATTERY
As a complete and independent cause of action the plaintiff hereby asserts this Count against each of the defendants named in this Complaint.
The factual averments set forth in paragraphs 1 through 40 above, are hereby incorporated into this Count by reference.
During the period between November 1968 and November, 1984, the plaintiff was repeatedly sexually and physically assaulted, touched, and treated in a manner which any person of ordinary sensibilities would find to be- highly offensive, and which caused the plaintiff pain and physical harm, as well as fear, apprehension and resulting mental and emotional harm.
COUNT IV: FOR INTENTIONAL INFLICTION OF SEVERE EMOTIONAL DISTRESS
COUNT V: FOR VIOLATION OF THE FEDERAL FAIR LABOR STANDARDS ACT
Dividing the number of hours the plaintiff worked during most work weeks in that period into her weekly salary for that period, the plaintiff was usually, if not always, paid less than the minimum wage required by the ~Federal Fair Labor Standards Act during the entire relevant period.
A substantial portion of the total business conducted by the Sikh Dharma Brotherhood corporation, corporation sole and 3130 Foundation between November, 1981 and November, 1984 was carried out in interstate commerce.
COUNT VI: INVASION OF PRIVACY
Respectfully submitted,
Gordon Reiselt, Esq.
Singer, Smith and Williams
P.O. Box 25565
FlameOut.org - Gurus - Bhajan - S. Premka Kaur Khalsa sues Yogi Bhajan
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO
S. PREMKA KAUR KHALSA,
Plaintiff,
vs.
HARBHAJAN SINGH KHALSA YOGIJI, a/k/a Harbhajan Puri, a/k/a/ Yogi Bhajan, a/k/a/ Sin Singh Sahib, Individually, and In His Capacity as the Sole Officer and Director of the Sin Singh Sahib of Sikh Dharma Brotherhood, a California Corporation, and in his Capacity as an Officer of the Sikh Dharma Brotherhood, a California Corporation, and in this capacity as an officer and director of the 3H0 Foundation, a California Corporation, and the '3HO Foundation of New Mexico, a New Mexico Corporation; and
SIRI SINGH SAHIB OF SIKH DHARMA
BROTHERHOOD, a California
Corporation; and
SIKH DHARMA BROTHERHOOD, a
California Corporation; and
3H0 FOUNDATION, a California
Corporation Licensed to do
Business in New Mexico;
and
Civil Action No. 86--0838 M SECOND AMENDED COMPLAINT
(For Fraud and Deceit;
Assault and Battery; False
Arrest and Imprisonment;
Intentional Infliction of
Severe Emotional Distress;
Violation of the Fair
Labor Standards Act; and
Invasion of Privacy.)
3H0 FOUNDATION OF NEW MEXICO, a New Mexico Corporation.
Defendants.
Parties Before the Court
Plaintiff, S. Premka Kaur Khalsa, is a adult citizen of the State of Hawaii.
Defendant Harbhajan Singh Khalsa Yogiji, formerly known as Harbhajan Puri, and also known as Yogi Bhajan and. Siri Singh Sahib, (hereinafter Bhajan), is an adult citizen of the State of California, with his principal residence at 1620 Preuss Road, Los Angeles, California 90035.
Defendant Sin Singh Sahib of Sikh Dharma Brotherhood is a corporation organized and doing business under the laws of the State of California, with its principal place of business located at 1649 Robertson Building, Los Angeles, California 90035. This corporation is of a unique type, known under California law as a corporation sole. (Hereinafter this corporation shall be referred to as the corporation sole.)
Defendant 3H0 Foundation is a corporation organized and doing business under the laws of the State of California, and doing business in the State of New Mexico under a Certificate of Authority issued by the New Mexico State Corporation Commission. The principal place of business of the 3H0 Foundation is located at 1649 Robertson Boulevard, Los Angeles, California 90035. 3H0 is an acronym for Healthy--Happy--Holy Organization.
Defendant Sikh Dharma Brotherhood is a corporation organized and doing business under the laws of the State of California, with its principal place of business located at 1649 Robertson Boulevard, Los Angeles, California. (To avoid confusion with a religious order in India called the Sikh Dharma Brotherhood, this corporate entity shall hereinafter be referred to as the Sikh Dharma Brotherhood Corporation.)
Defendant 3H0 Foundation of New Mexico is an affiliate of defendant 3H0 Foundation, and is a corporation organized and doing business under the laws of the State of New Mexico. The principal place of business of defendant 3H0 Foundation of New Mexico is Route 1, Box ].32--D, Espanola, New Mexico 87532.
Jurisdiction of this Court
Facts That Give Rise to this Complaint
COUNT I: FOR FRAUD AND DECEIT
Yogi Bhajan then made a number of false promises and misrepresentations of fact to the plaintiff in order to induce her to enroll in his yoga course, and later to induce hen to follow him as a spiritual teacher. Among the misrepresentations of fact which he made at their initial meeting were: (a) That if plaintiff enrolled in his yoga classes he would be able to teach her to be a yoga teacher in two months' time. (b) That as a yoga teacher, she would be able to tour Europe and stay at various ashrams throughout Europe. (c) That he would personally oversee the plaintiff's education and personally instruct her in Yoga if she became his follower. (d) That if the plaintiff studied under him, served him and agreed to stay with him, Bhajan would provide for all of the plaintiff's material needs for life. (e) That he was a high master of yoga, who had studied many years under various masters of yoga in India, was a skilled teacher of and was particularly skilled in the form of yoga called Kundalini yoga.
All of the foregoing representations were false, and Bhajan knew them to be false at the time he made them. They were made only for the purpose of inducing the plaintiff to enroll in Bhajan's yoga course, as a means by which he could covertly subject the plaintiff to the thought reform program described above.
WHEREFORE, under this Count the plaintiff respectfully prays this Honorable Court will grant the following relief: A. Entry of a judgment in favor of the plaintiff and against the defendants, jointly and severally, in the amount of $1.5 million in compensatory damages, plus punitive on exemplary damages, plus interest and all costs of suit. B. Such other relief as the Court may deem to be just and equitable after trial.
COUNT II: ASSAULT AND BATTERY
As a complete and independent cause of action the plaintiff hereby asserts this Count against each of the defendants named in this Complaint.
The factual averments set forth in paragraphs 1 through 40 above, are hereby incorporated into this Count by reference.
During the period between November 1968 and November, 1984, the plaintiff was repeatedly sexually and physically assaulted, touched, and treated in a manner which any person of ordinary sensibilities would find to be- highly offensive, and which caused the plaintiff pain and physical harm, as well as fear, apprehension and resulting mental and emotional harm.
COUNT IV: FOR INTENTIONAL INFLICTION OF SEVERE EMOTIONAL DISTRESS
COUNT V: FOR VIOLATION OF THE FEDERAL FAIR LABOR STANDARDS ACT
Dividing the number of hours the plaintiff worked during most work weeks in that period into her weekly salary for that period, the plaintiff was usually, if not always, paid less than the minimum wage required by the ~Federal Fair Labor Standards Act during the entire relevant period.
A substantial portion of the total business conducted by the Sikh Dharma Brotherhood corporation, corporation sole and 3130 Foundation between November, 1981 and November, 1984 was carried out in interstate commerce.
COUNT VI: INVASION OF PRIVACY
Respectfully submitted,
Gordon Reiselt, Esq.
Singer, Smith and Williams
P.O. Box 25565
FlameOut.org - Gurus - Bhajan - S. Premka Kaur Khalsa sues Yogi Bhajan
