awe wD ° ew “Lae ounty of Los Angeles RUSHOVICH MEHTANI LLP Nov 13°2015 AANAND GHODS-MEHTANI (SBN 251556) JANA M. MOSER (SBN 281073) ‘Sherr R. Gay ve OMiced ter 3900 Wilshire Blvd., Suite 2600 ie a Los Angeles, California 90036-5013 Telephone: (323) 330-0543 Facsimile: (323) 395-5507 amehtani@rmlawpartners.com |jmoser@rmlawpartners.com Attomeys for Plaintiff SHARON CLERKIN SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES SHARON CLERKIN, an individual, Case No. BC6 00925 Plaintiff, ‘ComPLatnt For DAMAGES “s 1, DISCRIMINATION IN VIOLATION OF THE BIKRAM’S YOGA COLLEGE OF INDIA FEHA™— GOVERNMENT CODE § 12940 et LP. a California limited partnership: seq. DRAM CHOUDHURY, an individuals and | >. ay URE TO PREVENT DISCRIMINATION IN DOES 1 through 50, inclusive, VIOLATION OF THE FEH AL GOVERNMENT CoDE § 12940 et seq. Defendants. 3, RETALIATION IN VIOLATION OF LABOR Cope § 1102.5, 4, WRONGFUL TERMINATION IN VIOLATION OF PuBLic POLicy [DemaNo For Jury TRIAL] 2838 2 ssss 6 COMPLAINT FOR DAMAGES THSRIEIT #396/ 119 szeooso8wi 10 ul 12 13 4 15 16 7 18 19 20 a 2 23 24 25 26 27 28 Plaintiff Sharon Clerkin (“Plaintif?”) hereby brings this Complaint against Defendants Bikram ‘Yoga College of India, LP (the “Company”), Bikram Choudhury (“Choudhury”), and Does 1 through 50 and alleges the following based on kriowledge as to herself and her known acts, and on information and belief as to all other matters: L PARTIES 1. tthe relevant times mentioned herein, Plaintiff performed work for Choudhury and the Company at the Company’s headquarters, located at 11500 West Olympic Blvd., Los Angeles, California 90064. The unlawful conduct alleged herein occurred in Los Angeles County. 2. At the relevant times mentioned herein, the Company was a limited partnership conducting business in Los Angeles County with its principal place of business located at 11500 West Olympic Bivd., Los Angeles, California 90064. Plaintiff is informed and believes that the Company's general and limited partners are Defendant Bikram Choudhury and Bikram Choudhury Yoga, Inc. 3. At the relevant times mentioned herein, the Company and Choudhury were an “employer” (or joint employer) of Plaintiff as such term is defined under California Government Code section 12926(d) in that they regularly employed five (5) or more persons. Therefore, the Company and Choudhury were subject to the Fair Employment Housing Act (the “FEHA"). 4. At the relevant times mentioned herein, Defendant Bikram Choudhury was an individual who acted as the general or limited partner of the Company, and was a resident of Los Angeles County. 5. Plaintiff's ignorant of the true names and capacities of defendants sued herein as DOES. 1 through 50, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will amend this Complaint to allege the true names and capacities of said defendants when the same has been ascertained. Each of the fictitiously named defendants is responsible in some manner for the acts ‘complained of herein. Unless otherwise stated, all references to named defendants shall include DOE defendants as well. Ie COMPLAINT FOR DAMAGES a1 IL 2 JURISDICTION AND VENUE 3 6. Jurisdiction and venue are proper in this Court because all of the claims alleged herein 4 [arose in Los Angeles County and all of the defendants are doing or did business in Los Angeles 5 |] County, and/or their principal place of business is in Los Angeles County, in each case, at the times 6 |[relevant herein. See also Govt. Code § 12965() (stating venue is appropriate i, intr alia, any county 7 |[in the state in which the unlawful practice is alleged to have been committed). 8 7. The amount in controversy in this matter exceeds the sum of $25,000.00, exclusive of 9 | interest and costs 10 mm. u FACTUAL ALLEGATIONS 2 8. Plaintiff was been employed by the Company as a yoga instructor and, later, as a full- 13 |] time registrar from 2010 until her termination on August 6, 2015. As a registrar, Plaintiff eamed 14 1) $54,000 per year working as a teacher-training recruiter and coordinator, 15 9. Plaintiff consistently received positive reviews from Choudhury over the course of her 16 |]employment at the Company. During her time as the Company's registrar, Plaintiff helped the 17 || Company increase its annual teacher-training registrants from approximately 300 students to 440 18 []students. Over the last two years, however, the number of registrants has fallen simultaneously with 19 || the deluge of lawsuits brought against Choudhury alleging sexual harassment and sexual assault, 20 |] among other things. a 10. As part of her job duties as the Company's registrar, Plaintiff managed the registration 22 || for a teacher training originally scheduled to take place from September 13, 2015 to November 14, 23 |/2015 at Harrah’s Atlantic City Resort in Atlantic City, New Jersey. The training was sold at a rate of cr t+ 24 |1$12,500 for a shared room or $16,600 for a single room. Students began registering for the training in » 25 |]or about early-July 2015, 26 11. On or about July 29, 2015—six weeks before the training was scheduled to begin— ~ 27 || Choudhury’s assistant, Monica Shigenaga, informed Plaintiff that the training was being cancelled. At j, 28 || this time, 36 students had already paid for the training. Plaintiff suggested that Choudhury conduct a : 2. uw cone Lae TOR Daadnces fusnovicn eran uur eea 24 25 26 2 28 small training for the students who had already paid for training at the Company’s headquarters in Los Angeles, but Choudhury refused. 12. The following day, on or about July 30, 2015, Shigenaga informed Plaintiff that ‘Choudhury had changed his mind about canceling the training and decided to move the training to an ‘unknown venue in California. Shigenaga further instructed Plaintiff to keep the change in venue secret and to continue collecting money from prospective students for the Atlantic City location. When Plaintiff asked whether students would be compensated for the flight tickets they had already purchased to Atlantic City, Shigenaga instructed Plaintiff to “mind your own business.” Plaintiff informed Shigenaga that knowingly charging students for a training that was no longer being offered at the advertised location was illegal. Plaintiff continued to process prospective students” registrations for the training, but refused to further Defendants’ scheme by instructing her assistant to process the applications without taking payments until a decision as to the training’s location had been made. 13. On the evening of July 22, 2015, Plaintiff received medical treatment related to her pregnancy that made Plaintiff extremely nauseous, causing her to leave work early the following day ‘on or about July 23, 2015. That same day, Shigenaga called Plaintiff's husband, Balwan Singh (who also worked for Defendants) into her office and asked whether Plaintiff was having a baby, claiming she could “feel her strong feminine energy.” Shigenaga then asked Singh’s assistant whether Plaintiff /was pregnant. 14. The following day on or about July 24, 2015, Plaintiff missed work for a medical appointment related to her pregnancy. That same day, while Shigenaga was present, Choudhury asked Singh why Plaintiff had been missing work of late. Singh informed Choudhury that they were having a baby. 15. On or about July 27, 2015, Plaintiff returned to work at the Company. That day, another Company employee asked Plaintiff whether she was pregnant. Plaintiff inquired why the employee was asking, to which the employee responded with an apology. 16. On or about July 30, 2015, Plaintiff left work early for a medical appointment related to her pregnancy. Plaintiff's doctor instructed her to rest for several days following that appointment. Accordingly, Plaintiff and Singh scheduled time off work from July 31 to August 5, 2015. While as ees usnovicH MENTANI LLPB 14 15 16 7 18 19 20 au 22 2B 24 %6 <2 S28 See Plaintiff was away from work, her assistant informed Plaintiff that the Company had hired another person, Shelly Kompel, to work as its registrar in Plaintiff's absence. 17. When Plaintiff returned to work at the Company on August 6, 2015, one of Choudhury’s employees, Sando, informed Plaintiff that Choudhury had ordered her to step away from her computer, refrain from touching anything, and return her office keys to Choudhury’s assistant, Shigenaga. Sando further informed Plaintiff that Choudhury was instructing her to go to the Company’s studio to teach a yoga class. However, the Company does not pay its employees to teach yoga classes. Confused by the instructions, Plaintiff asked Sando whether she was being terminated, and Sando replied that he did not know. 18. Plaintiff then called Choudhury to ask whether she was being terminated. Choudhury asked Plaintiff whether she had received Sando's message, and again instructed Plaintiff to leave her desk to teach a yoga class. When Plaintiff asked for a reason as to why she was being told to leave her desk, Choudhury responded, “You're a failure. I should have fired you two years ago. You're not selling the teacher training. Hand everything over to Monica, and don’t touch anything.” Plaintiff understood from this conversation that Choudhury had terminated her employment. 19. Plaintiff then met with Shigenaga, Singh, and other Company employees. During that meeting, Shigenaga called Choudhury, who confirmed that Plaintiff and Singh were both terminated ‘and instructed Shigenaga to call the police and have Plaintiff and Singh removed from the premises. 20. Later that same day, the Company posted a picture of Kompel on its Facebook page, announcing her as the Company's new registrar. 21. The Company’s conduct, as described in paragraphs 8-20 above, was performed or ratified by managing agents of the Company, including, but not limited to, Bikram Choudhury, The ‘Managing Agents were each responsible for overseeing a substantial portion of the Company's business operations, and each exercised substantial discretionary authority over vital aspects of such operations, including making significant decisions that affect the Company's intemal policies. The Managing Agents engaged in malicious, fraudulent, and oppressive conduct that justifies an award of Punitive damages. <4. ‘COMPLAINT FOR DAMAGES a1 22, In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing 2 || Agents willfully disregarded Plaintiff's right to be free from unlawful discrimination based on her 3 || pregnancy and retaliation based on her refusal to further their illegal and fraudulent conduct. The 4 || Managing Agents discriminated against Plaintiff based in part on her pregnancy by, among other 5 | things, terminating her employment. The Managing Agents retaliated against Plaintiff based on her stated belief that their conduct constituted an illegal and fraudulent scheme and refusal to participate in said scheme by, among other things, terminating her employment. 23. The Managing Agents’ conduct demonstrates a callous indifference for the law and Plaintiff's rights. In committing the foregoing acts as set forth in paragraphs 8-20 above, the 10 || Managing Agents acted despicably and subjected Plaintiff to cruel and unjust hardship in conscious 11 || disregard for her rights under California law. 2 24. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing 13 |] Agents intended to cause emotional and financial injury to Plaintiff. Specifically, the Managing 14 |} Agents terminated Plaintiff's employment unlawfully with the intent to cause her severe emotional 15 J} distress or atleast without regard for the consequences on Plaintiff's career, livelihood, and her 16 |} emotional wellbeing. 7 W 18 EXHAUSTION OF ADMINISTRATIVE REMEDIES 19 25. Prior to the initiation of this lawsuit, Plaintiff filed a complaint against each named 20 |} defendant with the California Department of Fair Employment and Housing (“DFEH") pursuant to 21 || section 12900 et seq, of the California Government Code alleging the claims described in 22 || Complaint. On November 10, 2015, the DFEH issued a “right to sue” letter. True and correct copies 23 || of the complaint and the “right to sue" letter are attached collectively hereto as Exhibit A. All 24 || conditions precedent to the institution of this lawsuit have been fulfilled. This action is filed within one year of the date that the DFEH issued its right to sue letter. Mog e <5. ul ‘CORPCATIT FOR DawAGES eee10 u 2 13 15 16 7 18 19 20 a 22 2B 24 v. FIRST CAUSE OF ACTION (Discrimination in Violation of the FEHA On Behalf of Plaintiff Against All Defendants) 26. Plaintiff realleges and incorporates by reference paragraphs 1-25, inclusive, of this ‘Complaint as though fully set forth herein. 27. As set forth more fully in paragraphs 8-20 above, Plaintiff became pregnant while /employed by the Company. 28. The Company was made aware of Plaintiff’s pregnancy in or about July 2015. 29. The Company discriminated against Plaintiff based on her pregnancy by, among other things, terminating Plaintiff's employment. 30. Asa proximate result of the Company's conduct, Plaintiff suffered and continues to suffer damages in terms of lost wages, lost bonuses, lost benefits, and other pecuniary loss according to proof. Plaintiff bas also suffered and will continue to suffer physical and emotional injuries, including ‘nervousness, humiliation, depression, anguish, embarrassment, fright, shock, pain, discomfort, fatigue, and anxiety. The amount of Plaintiff's damages will be ascertained at trial 31. The Company's conduct, as described in paragraphs 8-20 above, was performed or ratified by managing agents of the Company, including, but not limited to, Bikram Choudhury. The Managing Agents were each responsible for overseeing a substantial portion of the Company’s business operations, and each exercised substantial discretionary authority over vital aspects of such operations, including making significant decisions that affect the Company’s internal policies. The Managing Agents engaged in malicious, fraudulent, and oppressive conduct that justifies an award of Punitive damages. 32. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing Agents willfully disregarded Plaintiff's right to be free from unlawful discrimination based on her pregnancy and retaliation based on her refusal to further their illegal and fraudulent conduct. The ‘Managing Agents discriminated against Plaintiff based in part on her pregnancy by, among other things, terminating her employment. The Managing Agents retaliated against Plaintiff based on her -6- COMPLAINT FOR DAMAGES asstated belief that their conduct constituted an illegal and fraudulent scheme and refusal to participate in said scheme by, among other things, terminating her employment. 33. The Managing Agents’ conduct demonstrates a callous indifference for the law and Plaintiff's rights. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing Agents acted despicably and subjected Plaintiff to cruel and unjust hardship in conscious disregard for her rights under California law. 34. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing Agents intended to cause emotional and financial injury to Plaintiff. Specifically, the Managing /Agents terminated Plaintiff's employment unlawfully with the intent to cause her severe emotional distress or at least without regard for the consequences on Plaintiff's career, livelihood, and her emotional wellbeing, 35. The FEHA provides for an award of reasonable attomeys? fees and costs incurred by a prevailing plaintiff in an action brought under its provisions. Plaintiff has employed and will continue to employ attorneys for the initiation and prosecution of this action. Plaintiff has incurred and will ‘continue to incur attomeys’ fees and costs herein. Plaintiff is entitled to an award of attorneys” fees and costs. 36. Plaintiff has been generally damaged in an amount within the jurisdictional limits of this Court, VI. SECOND CAUSE OF ACTION (Failure to Prevent Discrimination in Violation of the FEHA Against All Defendants) 37. Plaintiff realleges and incorporates by reference paragraphs 1-36, inclusive, of this Complaint as though fully set forth herein, 38. California Government Code section 12940(k) makes it an unlawful employment practice for an employer to “fail to take all reasonable steps to prevent discrimination and harassment from occurring,” California courts have held that a plaintiff seeking to recover damages based on a Claim for failure to prevent discrimination must show that the plaintiff was subjected to discrimination, defendant employer failed to take all reasonable steps to prevent discrimination and this failure caused oe ‘CONPLAINT FOR DAMAGES1 |[plaintiff to suffer injury, damage, loss or home. See, e.g., Leland v. City & Cnty. of San Francisco, $76 2 |/F. Supp. 2d 1079, 1103 (N.D. Cal. 2008). See also Adetuyi v. City and County of San Francisco, 2014 WL 3885874 *1, *14 (N.D. Cal. 2014); Vierria v. California Highway Patrol, 644 F. Supp. 24 1219 (ED. Cal. 2009). However, no liability can arise from not preventing discrimination that did not occur. ‘See Trujillo v. N. Cnty: Transit Dist., 63 Cal. App.4th 280, 289 (1998) (affirming trial court's grant of aw ee judgment as a matter of law for defendants where jury found that there had been a failure to protect but there had been no discrimination). 8 39. As set forth more fully in paragraphs 8-20 above, Plaintiff became pregnant while 9 || employed by the Company. 10 40." The Company was made aware of Plaintiff's pregnancy in or about July 2015. u 41. ‘The Company discriminated against Plaintiff based on her pregnancy by, among other 12 || things, terminating Plaintiff's employment. Accordingly, the Company also violated Government 13 |} Code section 12940(k) by failing to prevent that discrimination against Plaintiff. 4 42. Asa proximate result of the Company's conduct, Plaintiff suffered and continues to 15 || suffer damages in terms of lost wages, lost bonuses, lost benefits, and other pecuniary loss according to 16 || proof. Plaintiff has also suffered and will continue to suffer physical and emotional injuries, including 17 | nervousness, humiliation, depression, anguish, embarrassment, fright, shock, pain, discomfor, fatigue, 18 |} and anxiety. The amount of Plaintiff's damages will be ascertained at trial 19 43. The Company's conduct, as described in paragraphs 8-20 above, was performed or 20 || ratified by managing agents of the Company, including, but not limited to, Bikram Choudhury. The 21 ||Managing Agents were each responsible for overseeing a substantial portion of the Company's 22 || business operations, and each exercised substantial discretionary authority over vital aspects of such 23 || operations, including making significant decisions that affect the Company's internal policies. The + 24 || Managing Agents engaged in malicious, fraudulent, and oppressive conduct that justifies an award of "25 [| punitive damages. e i) 28 44, In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing 27 |] Agents willfully disregarded Plaintif's right to be fiee from unlawful discrimination based on her W ‘28 || pregnancy and retaliation based on her refusal to further their illegal and fraudulent conduct. The o e -8- wl CowPcAin FOR Daiiadts ee eeeeeeeeeSSSSSSSSSSSSSSSeee& ul 10 u 12 13 4 15 16 7 18 19 20 2 22 23 24 25 26 27 28 Managing Agents discriminated against Plaintiff based in part on her pregnancy by, among other things, terminating her employment. The Managing Agents retaliated against Plaintiff based on her stated belief that their conduct constituted an illegal and fraudulent scheme and refusal to participate in said scheme by, among other things, terminating her employment. 45, The Managing Agents’ conduct demonstrates a callous indifference for the law and Plaintiff's rights. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing Agents acted despicably and subjected Plaintiff to cruel and unjust hardship in conscious disregard for her rights under California law. 46. — In.committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing ‘Agents intended to cause emotional and financial injury to Plaintiff. Specifically, the Managing, ‘Agents terminated Plaintiff's employment unlawfully with the intent to cause her severe emotional distress or at least without regard for the consequences on Plaintiff's career, livelihood, and her emotional wellbeing, 47. The FEHA provides for an award of reasonable attomeys” fees and costs incurred by @ prevailing plaintiff in an action brought under its provisions. Plaintiff has employed and will continue to employ attomeys for the initiation and prosecution of this action. Plaintiff has incurred and will continue to incur attorneys” fees and costs herein. Plaintiff is entitled to an award of attorneys” fees and costs. 48, Plaintiff has been generally damaged in an amount within the jurisdictional limits of this Court. Vil. ‘THIRD CAUSE OF ACTION (Retaliation in Violation of Labor Code § 1102.5 Against All Defendants) 49, Plaintiff realleges and incorporates by reference paragraphs 1-48, inclusive, of this Complaint as though fully set forth herein. 50. Defendants terminated Plaintifi’s employment in violation of California Labor Code section 1102.5(b) and (c) because Plaintiff disclosed information about what she had reasonable cause to believe constituted illegal and fraudulent conduct to persons with authority over her, and further -9- COMPLAINT FOR DAMAGES eninesmeeun ta)1 || refused to further said scheme. In response, Defendants terminated Plaintiff's employment. Defendants conduct therefore constituted unlawful retaliation on account of Plaintif’s protected activity in violation of California Labor Code section 1102.5(b) and (e). 51, Asa proximate result of Defendants’ conduct, Plaintiff suffered and continues to suffer ‘damages in terms of lost wages, lost bonuses, lost benefits, and other pecuniary loss according to proof. Plaintiff has also suffered and will continue to suffer physical and emotional injuries, including nervousness, humiliation, depression, anguish, embarrassment, fright, shock, pain, discomfor, fatigue, 8 ||and anxiety. The amount of Plaintiff's damages will be ascertained at trial. 9 52. The Company's conduct, as described in paragraphs 8-20 above, was performed or 10 || ratified by managing agents of the Company, including, but not limited to, Bikram Choudhury. The 11 || Managing Agents were each responsible for overseeing a substantial portion of the Company's 12 J} business operations, and each exercised substantial discretionary authority over vital aspects of such 13 || operations, including making significant decisions that affect the Company's internal policies. The 14 || Managing Agents engaged in malicious, fraudulent, and oppressive conduct that justifies an award of 15 || punitive damages. 16 53. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing 17 |) Agents willfully disregarded Plaintiff's right to be free from unlawful discrimination based on her 18 | pregnancy and retaliation based on her refusal to further their illegel and fraudulent conduct. The 19 || Managing Agents discriminated against Plaintiff based in part on her pregnancy by, among other 20 |} things, terminating her employment. The Managing Agents retaliated against Plaintiff based on her 21 || stated belief that their conduct constituted an illegal and fraudulent scheme and refusal to participate in 22 || said scheme by, among other things, terminating her employment. 2B 54. ‘The Managing Agents’ conduct demonstrates a callous indifference for the law and 24 || Plaintiff's rights. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing Agents acted despicably and subjected Plaintiff to cruel and unjust hardship in conscious disregard for her rights under California law. 55. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing ‘Agents intended to cause emotional and financial injury to Plaintiff. Specifically, the Managing Be -10- vl ‘CowPLAINT FOR DAMAGES eee1 |] Agents terminated Plaintif?"s employment unlawfully with the intent to cause her severe emotional 2 |} distress or at least without regard for the consequences on Plaintiff's career, livelihood, and her 3 || emotional wellbeing. 4 56. Plaintiff has been generally damaged in an amount within the jurisdictional limits of this, i 5 |} Court. : 6 val. 7 FOURTH CAUSE OF ACTION 8 (Wrongful Termination in Violation of Public Policy Against All Defendants) 9 57. Plaintiff realleges and incorporates by reference paragraphs 1-56, inclusive, of this 10 |) Complaint as though fully set forth herein. f un 58. The Company terminated Plaintiff's employment in violation of fundamental and well- ! 12 |lestablished public policies, as set forth in the California constitution and various statutes including, but ' 13 |} not limited to, the FEHA and Labor Code section 1102.5. 4 59. Employers are required under the California constitution and the FEHA to refrain from 15 |] discriminating against employees on the basis of sex and pregnancy. Employers are required under 16 || Labor Code section 1102.5 to refrain from retaliating against an employee for disclosing information 17 || she reasonably believes constitutes a violation or noncompliance with a local, state, or federal rule or 18 || regulation, 19 60. _ Plaintiff"s employment was terminated because of her pregnancy and in retaliation for, 20 || among other things, stating her belief that knowingly selling teacher training courses for a location that 21 ||had been cancelled constituted illegal activity. This termination resulted in the violation of the public 22 || policies set forth in the California constitution and statutes set forth above. 23 61, Asa proximate result of the Company's conduct, Plaintiff has suffered and will continue 1+ 24 ||1o suffer damages in terms of lost wages, lost bonuses, lost benefits, and other pecuniary loss according » 25 ||to proof. Plaintiff has also suffered and will continue to suffer physical and emotional injuries, b 26 | including nightmares, nervousness, humiliation, depression, anguish, embarrassment, fright, shock, ‘5 27 ||pain, discomfort, fatigue, and anxiety. The amount of Plaintiff's damages will be ascertained at trial Re oi. wn COMPLAINT FOR DAMAGES eee1 62. The Company's conduct, as described in paragraphs 8-20 above, was performed or 2 || ratified by managing agents of the Company, including, but not limited to, Bikram Choudhury. The 3 || Managing Agents were each responsible for overseeing a substantial portion of the Company's : 4 || business operations, and each exercised substantial discretionary authority over vital aspects of such 5 |] operations, including making significant decisions that affect the Company's internal policies. The 6 || Managing Agents engaged in malicious, fraudulent, and oppressive conduct that justifies an award of 7 || punitive damages. 8 63. In committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing ‘ 9 || Agents wilfully disregarded Plaintiff's right to be free from unlawful discrimination based on her i 10 || pregnancy and retaliation based on her refusal to further their illegal and fraudulent conduct. The 11 || Managing Agents discriminated against Plaintiff based in part on her pregnancy by, among other \ 12 |] things, terminating her employment. The Managing Agents retaliated against Plaintiff based on her 13 |} stated belief that their conduct constituted an illegal and fraudulent scheme and refusal to participate in 14 }} said scheme by, among other things, terminating her employment. 15 64, ‘The Managing Agents’ conduct demonstrates a callous indifference for the law and 16 |) Plaintiff's rights. In committing the foregoing acts as set forth in paragraphs 8-20 above, the 17 |] Managing Agents acted despicably and subjected Plaintiff to cruel and unjust hardship in conscious 18 |] disregard for her rights under California law. 19 65. In-committing the foregoing acts as set forth in paragraphs 8-20 above, the Managing 20 || Agents intended to cause emotional and financial injury to Plaintiff. Specifically, the Managing 21 || Agents terminated Plaintiff's employment unlawfully with the intent to cause her severe emotional 22 || distress or at least without regard for the consequences on Plaintiff"s career, livelihood, and her 23 || emotional wellbeing. 24 xX 25 26 1, For general damages, including emotional distress damages, according to proof on each 27 || cause of action for which such damages are available, ize A COMPLAINT FOR DAMAGES ee eeeeeeeeeSeSSSSSSSSSSSFSSee10 n i2 14 15 16 7 18 19 20 21 2. For special damages, according to proof on each cause of action for which such [damages are available. 3. For compensatory damages, including emotional distress damages, according to proof ‘on each cause of action for which such damages are available. 4. For punitive damages, according to proof on each cause of action for which such damages are available. 5. Fora statutory penalty not exceeding $10,000 pursuant to Labor Code section 1102.5(1). 6 Fordeclaratory and injunctive relief as appropriate. 7. For prejudgment interest and post-judgment interest according to law. 8. For reasonable attomeys’ fees incurred in this action pursuant to the FEHA and Code of Civil Procedure section 1021.5. 9. For costs of suit incurred in this aetion. 10. For such other and further relief and the Court deems proper and just. Dated: November 11, 2015 RUSHOVICH MEHTANI LLP AND GHODS-MEHTANT M. MOSER Attorneys for Plaintiff SHARON CLERKIN <13- ‘COMLAINT FOR DawaGes usnovicn srirasiuue renner!DEMAND FOR JURY TRIAL Plaintiff’ Sharon Clerkin hereby demands a trial by jury on all causes of action alleged herein in the Complaint for Damages. Dated: November 11, 2015 RUSHOVICH MEHTANI LLP jHODS-MEHTANI. M. MOSER, Aitorne¥s for Plaintiff SHARON CLERKIN -14- eee SnOvICH MEAN LAPSTATE. CAUCRNAL Benes, oman Sense te ——sxeemne sss seo DEPARTMENT OF Fair EMPLOYMENT & HOUSING Corucron acumen 2258 avs Dive. Se 1001 Eh Grave CA S5750 ‘rouehes gore cata cane@ilehca.gor AMENDED November 10, 2015 Jana Moser 5900 Wilshire Blvd., #2600 Los Angeles California 90036 RE: Notice to Complainant or Complainant’s Attorney DFEH Matter Number: 705738-194227-R Right to Sue: Clerkin / Bikram’s Yoga College Of India, LP Dear Complainant or Complainant's Attorney: Attached is a copy of your complaint of discrimination fited with the Department of Fair Employment and Housing (DFEH) pursuant to the California Fair Employment and Housing ‘Act, Government Code section 12900 et seq, Also attached is a copy of your Notice of Case Closure and Right to Sue. Pursuant to Government Code section 12962, DFEH will not serve these documents on the employer. You or your attorney must serve the complaint. If you do not have an attorney, you must serve the complaint yourself. Please refer to the attached Notice of Case Closure and Right to Sue for information regarding filing a private lawsuit in the State of, California Be advised that the DFEH does not review or edit the complaint form to ensure that it meets procedural or statutory « nents, Sincerely, Department of Fair Employment and Housing, EXASTATE. OF conan conus sas DEPARTMENT OF FAIR EMPLOYMENT & HOUSING ‘ecroR texmvest Som len ea ov ena cast carealca gov AMENDED November 10, 2015 RE: Notice of Filing of Discrimination Complaint DFEH Matter Number: 705738-194227-R Right to Sue: Clerkin / Bikram’s Yoga College Of India, LP To All Respondent(s): Enclosed is a copy of a complaint of discrimination that has been filed with the Department of Fair Employment and Housing (DFEH) in accordance with Government Code section 12960, ‘This constitutes service of the complaint pursuant to Government Code section 12962. The complainant has requested an authorization to file a lawsuit. This case is not being investigated by DFEH and is being closed immediately. A copy of the Notice of Case Closure and Right to Sue is enclosed for your records. Please refer to the attached complaint for alist ofall respondent(s) and their contact information No response to DFEH is requested or required. Sincerely, Department of Fair Employment and Housing _Ww SUE. Aone ons Ss Per SENEESOALEDNOGEROUEL DEPARTMENT OF Fair EMPLOYMENT & HOUSING ‘mgcron ecw stwutenea gov ena cmactcener@dhca.9ov AMENDED November 10, 2015) Shaton Clerkin 507 Boccaccio Avenue Venice California 90291 RE: Notice of Case Closure and Right to Sue DFEH Matter Number: 705738-194227-R Right to Sue: Clerkin / Bikram’s Yoga College Of India, LP Dear Sharon Clerkin, ‘This leter informs you that the above-referenced complaint was filed with the Department of Fair Employment and Housing (DFEH) has been closed effective November 10, 2015 because an immediate Right to Sue notice was requested, DEEH will take no further action on the complaint. This letter is also your Right to Sue notice. According to Government Code section 12965, subdivision (b), civil action may be brought under the provisions of the Fair Employment and Housing Act against the person, employer, labor organization or employment agency named in the above-referenced complaint. The civil action must be filed within one year from the date of ths leter. To obtain a federal Right to Sue notice, you must visit the U.S. Equal Employment Opportunity Commission (EEOC) to file a complaint within 30 days of receipt of this DFEH Notice of Case Closure ‘or within 300-days-of the-atleged-diseriminatory act; whicheveris‘earlier: Sincerely, Department of Fair Employment and Housingel) Deparment oF Fair Ev Ly errs mins. 200s. MENT & HOUSING Conceron news eS. FacentisearTo6 99:700:2500 ‘doen gov ema coca center@denca.gov AMENDED Enclosures ce: Bikram Choudhuryi 10 uv R 13 14 COMPLAINT OF EMPLOYMENT DISCRIMINATION BEFORE THE STATE OF CALIFORNIA DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING Under the California Fair Employment and Housing Act (Gov. Code, § 12900 et seq.) in the Matter of the Complaint of {Sharon Clerkin, Complainant. 507 Boccaccio Avenue Venice California 90291 DFEH No. 705738-194227-R Bikram’s Yoga College Of India, LP, Respondent. 11500 West Olympic Blvd. Los Angeles, California 90064 Complainant alleges: 1. Respondent Bikramn's Yoga College Of India, LP is subject to suit under the California Fair Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.). Complainant believes respondent is subject to the FEHA, 2, On oF around August 06, 2015, complainant alleges that respondent took the following adverse actions against complainant: Discrimination Asked impermissible non-job-related questions, Denied a work environment free of discrimination and/or retaliation, Denied employment, Denied pregnancy leave, Denied reinstatement, Terminated, . Complainant believes respondent committed these actions because of tele: Sex- Gender, Sex - Pregnancy. 3. Complainant Sharon Clerkin resides in the City of Venice, State of California, If complaint includes co: respondents please see below. 3. Complaint ~ DFEH No. 705735 THOT R Date Filed: November 10, 2015 ate Amended: November 10, 2015Co-Respondents: Bikram Choudhury 11500 West Olympic ive Ls Angeles California 90068 ti Date Filed: November 10, 2015 Date Amended: November 10, 2015 be mplain = DFEH Wo, 7OST3E- THOT RAdditional Complaint Details: Plaintiff Sharon Clerkin (’Plaintitt") was been employed by Bikram Yoga College of 4 | india, LP (the "Company") and Bikram Choudhury as a yoga instructor and, later, as a full-time registrar from 2010 until her termination on August 6, 2015. Plaintiff consistently received positive reviews trom Choudhury over the course of her employment at the Company. During her time as the Companys registrar, Plaintiff helped the Company increase its annual teacher-training registrants from approximately 300 students to 440 students. Over the last two years, however, the number of registrants has fallen simultaneously with the deluge of lawsuits brought against 8] Choudhury alleging sexual harassment and sexual assault, among other things. As part of her job duties as the Companys registrar, Plaintiff managed the registration for a teacher training originally scheduled to take place from September 13, 2015 to 10 | November 14, 2015 at Harrahs Atlantic City Resort in Atlantic City, New Jersey. The training was sold at a rate of $12,500 for a shared room or $16,600 for a single room. 11 | Students began registering for the training in or about early-July 2015. On or about July 29, 2015six weeks before the training was scheduled to beginChoudhurys assistant, 12 | Monica Shigenaga, informed Plaintiff that the training was being cancelled. At this time, 36 students had already paid for the training. Plaintiff suggested that Choudhury conduct a small training for the students who had already paid for training at the 14. | Companys headquarters in Los Angeles, but Choudhury refused. The following day, on or about July 30, 2015, Shigenaga informed Plaintiff that Choudhury had changed his 15] mind about canceling the training and decided to move the training to an unknown venue in California. Shigenaga further instructed Plaintiff to keep the change in venue 16] secret and to continue collecting money from prospective students for the Atlantic City location. When Plaintiff asked whether students would be compensated for the flight tickets they had already purchased to Atlantic City, Shigenaga instructed Plaintiff to 13 | mind your own business. Plaintiff informed Shigenaga that knowingly charging students for a training that was no longer being offered at the advertised location was illegal. Plaintiff continued to process prospective students registrations for the training, burrefused to further Defendants Scheme by instructing her assistant to process the” applications without taking payments until a decision as to the trainings location had been made. On the evening of July 22, 2015, Plaintiff received medical treatment related to her pregnancy that made Plaintiff extremely nauseous, causing her to leave 22. | work early the following day on or about July 23, 2015. That same day, Shigenaga called Plaintiffs husband, Balwan Singh (who also worked for Defendants) into her office and asked whether Plaintiff was having a baby, claiming she could feel her strong feminine energy. Shigenaga then asked Singhs assistant whether Plaintiff was B pregnant. The following day on or about July 24, 2015, Plaintiff missed work for a | medical appointment related to her pregnancy. That same day, while Shigenaga'was reas a. = Complaint = BFEH No. TOS7IE-TOVETR Date Filed: November 10, 2015 w . Date Amended: November 10, 2015 Rwl present, Choudhury asked Singh why Plaintiff had been missing work of late. Singh informed Choudhury that they were having a baby. On or about July 27, 2015, Plaintiff returned to work at the Company. That day, another Company employee asked Plaintiff Whether she was pregnant. Plaintiff inquired why the employee was asking, to which the employee responded with an apology. On or about July 30, 2015, Plaintiff left work early for a medical appointment related to her pregnancy. Plaintiffs doctor instructed her to rest for several days following that appointment. Accordingly, Plaintitf and Singh scheduled time off work from July 31 to August 5, 2015. While Plaintiff was away from work, her assistant informed Plaintiff that the Company had hired another person, Shelly Kompel, to work as its registrar in Plaintifs absence. When Plaintiff returned to work at the Company on August 6, 2015, one of Choudhurys employees, Sando, informed Plaintiff that Choudhury had ordered her to step away from her computer, refrain from touching anything, and return her office keys to Choudhurys assistant, Shigenaga. ‘Sando further informed Plaintiff that Choudhury was instructing her to go to the Companys studio to teach a yoga class. However, the Company does not pay its employees to teach yoga classes. Confused by the instructions, Plaintiff asked Sando whether she was being terminated, and Sando replied that he did not know. Plaintiff then called Choudhury to ask whether she was being terminated. Choudhury asked Plaintif whether she had received Sandos message, and again instructed Plaintiff to leave her desk to teach a yoga class. When Plaintiff asked for a reason as to why she was being told to leave her desk, Choudhury responded, Youre a failure. | should have fired you two years ago. Youre not selling the teacher training. Hand everything over to Monica, and dont touch anything. Plaintiff understood from this conversation that Choudhury had terminated her employment. Plaintiff then met with Shigenaga, Singh, and other Company employees. During that meeting, Shigenaga called Choudhury, Who confirmed that Plaintiff and Singh were both terminated and instructed Shigenaga to call the police and have Plaintiff and Singh removed from the premises. Later that same day, the Company posted a picture of Kompel on its Facebook page, announcing her as the Companys new registrar. 8 Complaint = DFE No. POSTE TH2I7R Date Filed: November 10,2015 Date Amended: Novernber 10, 2015= ie a VERIFICATION 1, Jana M. Moser, am the Auosney for Complainant in the above-enttled complaint, 1 have read the foregoing complaint and know the contents thereof. ‘The same is true of my own knowledge, except as t those matters whieh are therein alleged on information and belief, and as to those matters, I believe it to be rue (On November 10, 2015, I declare under penalty of perjury under the laws of the State of California that the foregoing is tue and correct. Los Angeles, California Jana M. Moser 9. Tomplaint = DFEH Wo. TOSTIB- THOT Date Filed: November 10, 2015, ate Amended: November 10, 2015e e __cwo19 [asa Pay wana ER a Om mr aee '——acorarenroar “Aanand Ghods-Nehiant (SBN 3317350) Jana M, Moser (SBN 281073), FILED Rushovigh Mchan LLP Superior Coutt 3 Catfomia S300 Wishire Biv Suite 2600, Los Angeles. CA 90036 OURAN AS atm ‘eutmone vo: (323) 330-0543 ‘aso, (323) 395-5507 arromer rox quer Plaintiff Sharon Clerkin J NOV 13 2015 |surenion counT oF caLiForwa, county oF Los Angeles Stree aoouss-T11 N, Fill Street hen No OficaCterk si scones o, ia ccrry noe cove: Los Angeles, CA 90012 funva Bolden samen, Stanley Mosk CASE NAME Sharon Clerkin v. Bikram’s Yoga College of India, LP CIVIL CASE COVER SHEET ‘Complex Case Designation we [ET tinea tiie alee einen | HUUIGIOUIN2 5 demanded demanded is Filed with first appearence by defendant | “° exceeds $25,000) $25,000 orless)| (Gal ules f Cour rule 3402) | oer: “tems 1=6 below musi be completed (see instructions Gn page 2) [i- Check one box below for the case fype thal best describes this case: ‘ule Tort Contract Provsionally Complex Ci CF Auto (22) [J Breach of contractiwarranty (06) (Cal. Rules of Cour, rules 3.400-3.403) Uninsured motorist (48) (J Rate 3.740 collections (08) () Antirust trade regulation (03) (ther PUPDIWD (Personal InjuryProperty _[__] other collections (09) 5) construction detect 10) Damagerrongul Death) Tor TT nawancs covers 18) tras to 0) Asbestos (04) TF) ote contact (37) (secures tigation 26) Ly Product iaiy cs) Ba papery erromanaonn Media mapracice (48) Eminent domsintoverse Insurance coverage dais ang rom me |, 2 ote pred (2 tendemnaton (1) Shove hted prooalycompos esse Non-PUPDIWD (Other) Tort 1 Weongtut eviction (22) ‘ypes (41) (1 ausinesstriuntsr business practice (97) [] ther real property (26) Enforcement of Judgment ED civirights (08) Unlawful Detainer CD enforcement of utgment (20) Defamation (13) [1 commercial (31) Miscellaneous Civil Complaint I Fraws ce) Ty resent 2) CT mcoun TE) teeta propery (19) 1 onugs 20) orer complaint (not specified above) (42) Protesional nagigance (25) Judea Review cen eae (Other non-PUPONYD tort (38) LJ Asset forfeiture (05) Partnership and corporate governance (21) Employment [1 Petition re: atitration award (11) =] ote petition (not specified above) (43) ‘Wrongful termination (36) 1 wt of mandate (02) [4] otherrempioyment (15) 7) other jucsiciat review (99) 2 Thiscase LJis [Tisnot — complex under rule 3.400 of the California Rules of Court. Ifthe case is complex, mark the factors requiring exceptional judicial management + a. Large number of separately represented paries 4] Large numberof winesses &-[] Extensive maton practic rising cticultor novel e. [] Coordination wih related actions pending in oe or mare courts issues that wil be time-consuming to resolve inother countes, tates, or countries, orn federal count J Substantial mount of documentary evidence _¢. (] Substantial postjudgment judicial supervision Remedies sought (check ail that apply): monetary .[_] nonmonetary; dectaratory or injunctive relief ©. Number of causes of action (speciy): 4 This case (_Jis isnot a class action suit If there are any known related cases, fle and serve a nic of related case. (You may use form CM-015}) Date: November I1, 2015 Jana M. Moser d Jpunitive Telnaes NOTICE Plaintiff must file his cover sheet with the frst paper fed in the action or prosbeefQ (except small claims cases or cases fied under the Probate Code, Family Code, or Welfare and Insitutions Cade). (Cal. Rules of Court, rule 3.220.) Failure to fle may result s,_ in sanctions. File this cover sheet in addition to any cover sheet require by local court rule {is If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all E} other parties to the action or proceeding, Unless ths is ¢ collections case under rue 3.740 or a complex case, this cover sheet will be used for statistical purposes only. ‘orem 1 Tamar CIVIC CASE COVER SHEET SRT eae eee~ 7 ca INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET ee To Plaintifs and Others Filing First Papers. Ifyou ae fing a frst paper (fr example, 2 complaint) in a cil case, you must complete an fle, along wih yout fst paper the ivf Case Cover Sheet contained on page i This formation vl be used io comple Statstics about the lypes and numbers of cases flee, You must complete ems 1 though 6 on the sheet. In item *, you must check ‘ne box forthe case ype thal best describes the case. Ite ease ie bth a general anda more spect ype of case seinem 1, heck he more specite one. the case has mute cavses of action, check the box that best indicates the primary cause of action To asi youn complaing the sheet, example of the eases (al belong under each case iype in lem tare prowded below. A cover sheet must be fled only wih your ial paper. Faire to flea cover sheet wih the fest paper fed in'a cul ease may eubec 9 party. tz counsel, or oth to sancons under res 2.30 and 8.220 ol the Cabos Rules of Court To Parties in Rule 2.740 Collections Cases. A “calectons case" under le 3.740 fs dtd as an action for recovery of money ‘wed in 8 tum sled tobe certain thal snot more than $28,000, excise of nersl and etorney’ fees, arising rom a Taneacton which propery, cores, or money was aequived on ered. A caleeions case does ol indude an acon seeking Ie fallowing, (1) tort Gamages, (2) puntve damages, (3) recovery of real property, (8) recovery of personal propery, oF (5) a prejudgment writ of sttachment.The identfcalon of a case asa tue 3.740 callectons case on tis form meant ta wl be exer om the Generel Smeforseric requirements and case management res, unless a defendant flea responsive pleasing, A rule 3740 cobecons aso wilbe subject tote requrements fr serdes and obaining a judgment ne 3.740 To Parties in Complex Cases. In complex cases ony, pares must also use the Civ Case Cover Shea o designate whether the cave is complex. Is plintifbeieves the case fs complex under rule 3.400 ofthe Calforia Rules of Cour, this must be indicated by ompleing he appropriate boxes inlems tard 2. Ifa plan designates a case as complex, De cover sheel must be served wi the omplain on all pares to the acon. A defendant may fle and serve no later than the ime of is frst appearance a jonder inthe plans designation, a counterdesgnation ha the case nol complex or, the pani hae made no designalon, «designation tht the case is complex. ‘CASE TYPES AND EXAMPLES ‘Auto Tor Contract Provisionally Complex Civil Litigation (Cal. er eas cree etree) vase ea ites tt ee comarca eeeonets eae celled meester a eee See foe wget Ea imap en ep cooaaionten fees teen Sey Noe any ene os ie Smee coe: vee rane eto pote rt roe econ ete moe anes aoe ee vanes a caer " vordatlany taneron manne See ot sted Intentional Infietion of, ‘Wri of Possession of Real Property Inonctve Relief Onty thon Emotional Distress ‘Mortgage Foreclosure ns “harassment) one Fire Saran conto pee enters fener oa onan rata eee mata cel Sion Practice (07) ‘Commercial (31) Miscellaneous Civil Petition Defomaton (eg sande, bel xe eek a er Pein (ot ected cae cence facies Pe eeccerceaes earl “ fe eene coe 5 7" Wrongful Termination (36) Other Judicial Review (39) oo we one Sana) eaten ea e flout ‘Commissioner Appeals A Ree tr 2007) CIVIL CASE COVER SHEETeet ® e BC 6 00925 Clerkin v. Bikrem's Yoga College of India, LP BY. FAX CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION i (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to LASC Local Rule 2.0 in all new civil case filings in the Los Angeles Superior Court. Tem I. Check the types of hearing and filin the estimated length of hearing expected for his case: surytrit? [4] yes ciass action? Lives unmreo case? Clyes time esrmateo For rria.3-3__C] HOURS) #1 DAYS Itein Il, Select the correct cistrict and courthouse location (4 steps — If you checked “Limited Case", skip to tem Ill, Pg. 4 Step 1: Aer first completing the Civil Case Cover Sheet Form, find the main civil case cover sheet heading for your case in the left margin below, and, tothe right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check one Superior Court type of action in Column B below which best describes the nature of this case. Step 3: in Column C, circle the reason forthe court location choice that applies to the type of action you have checked. For any exception to the court location, see Los Angeles Superior Court Local Rule 2.0. ' Applicable Reasons for Choosing Courthouse Location (see Column C below) |. Clase Acton must Radin te County Couttonse, Cena Datiet ,Lecalono proper permanently garaged vie | Maybeftegtn Gonea (Sha esvny one Saaly pay Eropery Bama Leeson were petra ees: + 5 Cota where use of acton arose: ited ice! & Location uhereie detendantrespondent funcions whol. i Seaton where badly iy, death o damage ocr. Leeson ure one rimgre oa ares rose 5: Location where performance required or defendant resides. 4p. Location of Cabor Commissioner Ofice ‘Step 4: Fillin the information requested on page 4in Nem Il; complete lem !V. Sign the declaration A B c Civ Case Cover sheet | Type of Action ‘Applicable Reasons - es | eategory No (Cheek only one) Bee Stop 3 Above ce ut (2) Cl A7100 Motor Vetiie- PerzonalrjuryiProperty Damagenrengtl Death | 4, 2.4 | uninsured Metorst 46) | Cl_A7110 Persona InePrapery OamageMirongtl Death = Uninsured Motor | 1, 2.4 1 A670 Asbestos Property Damage 2 ze Asberton (04) I A721 Asbestos - Persona injryiirongtal Death 2 ge, ES. | Prosvertisoiry 2 | 1 7260. Proce Libiy (ol asbesoe or oxclenveonments) 1.208048 6a 3S" | cic tapracze 5) | ©) A7210 Media Malpractice Prion & Surgeons 1204 2: 1 7240. Other Prtessonal Heath Care Malpracice nels Bs 7250 Premises Labiy (eg. sp anda) 7 eae 7250 Inentiona Sey nuryPxoperty Damogelvrong Desh (e.g . et |e ose asa, vandalam te) apn 2 £1 | "Wronttdean 7270 Internat fiction of Emotional Disess aon : e 7220 omer Personal nunyPropeny OamageWrangl Death aio zm EE] | Busness ton (07 | 6 soz0 one ConmecialiBusiness Tort (no ravlbesch of contact) 1.2.3 EE)[ canon 1 A6005 cat RighsOscrmination 1.2.3 = 53, ESI | Datamation 19) 1 As010 etmation andere 1,28 EE) pmevo Tora Fwd coma) aa 3B gE 36 ‘lv 109 03-04 Re. 0378) CIVIL CASE COVER SHEET ADDENDUM LASC, rule 20 7 Cas approved AND STATEMENT OF LOCATION Page 1 of 4Non-Personal injury/Property Damage! Wrongful Death’Tort (Cont’d:) — _______Employment Contract Clerkin v. Bikram’s Yoga College of India, LP chicane q 7 vl Case Cover “ype of Acton ‘Applicable Reasons Sheet Category No. (Cheek ont one) “See Step 3 Above Petes A007 Lega Malpractice oe egigence 1.2 2) C6050. Other Professional Malaracce (ot meicalarlega) : other 5) 1D A6025 omer Non Persona InuniPropery Damage ort 23 \WronghtTerminston 7 Wrong Termination 1.2 ns DA8037- wong Termin 3 Cer Employment |) Ago26 Ober Employment Compan Case Os 8109 Later Commissioner Appeals a Breach of Contac | C)_ASOD4 Breach of Rental ease Contac (nt nowt! Delainer or wrongtulavicton) 2. Waroety 86008. ContractWaranty Breach Seles Paint (no frausnegigence) 2.5 (ootinsrance) A009. Negligent Breach of ContacuWannty (no aus) 1.206 A608 Other Breach of ConractWarranty (nt rad or negligence) Bre po TD A6002 Cottons Case-Sellor litt 2.5.8 03) 1 Asot2 Other Promissory NotefColectons Case 2.8, Insurance Coverage Insurance Coverage (nat complex) ro OD asors Coverage (no complex) 1.2.5.8 (ther Contac CAs000 Contracta Fraud ar vate 6031 Tortious interterence 1423, 8, l_A8027 other Conrot Disputlnat eachinsurancertoudnegigence) 4.288, oe 3 DomsiniCondernnaion Number of parcels a 17900 Eminent DomainiConde Number of 2 condemnation (14) Wrongful Eviction ee a C1 8023. wrong Eton 2.6. Ciner Rea Propeny | Cl ABOI® Morgage Foreiosure 2.6. 5) G A6052 ule Tie ae GA6060 cine Rea! Property (rat eminent domain, lanclocdenan,erecosure) ae eee 021 Unlawful Detainer Commerc (nt drags or wrong vieton Unlaful Deiaines | C)_go21_UnlowflDetaine {001 dug oF wrngtleveion) 2.6. oe steiner Residemal ot gs or wrongful eon ene T8020 Unlowtl Deine escent (not drugs or wong eveton) 2.6. ‘naw Detain. ony eee 6022. Uniawl Detaine-Orug 2.6. Asset Foire (05) | CASIO Asset Fodite Case 2.6. Pelion = Wivaton TT] A61%6 Pein o ConpelontemVacae Arian 2.5. Civ 1090306 Rev. 08106) CIVIL CASE COVER SHEET ADDENDUM LASG, le 20 LASC Approves AND STATEMENT OF LOCATION Page 2 of 4Clerkin v. Bikran's Yoga College of India, LP 3 rN B c © | citcase Coversheet Type of Action Aoplicable Reasons - é Category Ho. (Check ony one) See Step 3 Above z ) ASISi Wat Administrative Mancoms 28 g itor Mandate C1 As152 Wit: Mandames on ted Cut Case Mater 2 é ) A615 Wit- Other Lime Court Case Review : & | coe nacanesen in 7 a 1 As%80 oer Wat Hui Review 2.8 Aoirsrase eee 18003 Antrsitrae Reston 1.28 ConsmuctonDtec(10) |} agoa? Consirvton defect 120 | Chins inching nase ee : 5 ching © A8006 Clainsinvoing Mass Tor : | Secures Lingaion 26) C6035 Securities Ligation Case tae. 2 : Tose Ton eT 6096 Tose TontEonmenta 1.2.8.8 insurance Coverage 2 As014 surance Covergetsvrogton compen case ot) 1.2.8.8 Claims rom Complex ease i) Taster Str Sse Judgment 2.8 oe ee eens i psts0 Abarat of Judgment Bo A ot dren 1 As107 Conessin of Judgment (on domestic reatons) Ap 8 i 1 Ast40 Adminave Agony Avandia) ae 53 Aste Peivonceriat for Enty of Judgment on Unpaid Tax : 53 Cl nst¥2_ Ober Escemertt Jodgment Case 2.8.9 ICO zr) i As0%8 Racketerng RICO} Case an og 32 1 As0a0 Dedraton Ree Only 128 38 | omerconpisnts Asoo jencive Ree! Ory (a omesicarassmert) 2.8 EE | Wotsoecies bore) | C ngor1 omer Commercial Conlon Cae (nontrtnon comple) 128 BC (2) Gi A000 otner Civ Compint(nor-torinon-complex) 4.2 = Parnersip Coperton | C] A619. Parnerhip and Capote Governance Cate 2.8 + Gowtance ge TD A6%21 Gxa Harassment 2.8.0 = A612 Wortlace Harassment Ap Be Gl nsi2e eiderDependent Adult Abure Case Fp 3 ter Petitons . Be} ktarRettons | Ch nst90 election contest : 3 GB 6110 Petition for Change of Name a & (43) 2 2,7. 3 1 A6170 Pelton fr Reet fom Late Chaim Low 8 " 2.3408 - 16100 Ober Cv Peton ° [PIV 109 03-04 (Rev. 03/06) CIVIL CASE COVER SHEET ADDENDUM LASC, rule 2.0 LASC Approved AND STATEMENT OF LOCATION Page 3 of 4Clerkin v. Bikram's Yoga College of India, LP Htem Il Statement of Location: Enter the address ofthe accident, party's residence or place of business, performance, ‘ther circumstance indicated in Item I, Step 3 on Page 1, as the proper reason far ling in the court location you selected OF REASON: CHECK THE NUMBER UNDER COLUMN C pone WHICH APPLIES IN THIS CASE Bikram's Yoga College of India, LP 01. 62. 03. 04. 05. 6. 07. 08. Os. 510. Siseeeeeeaseamteteeee ae Los Angeles cA 90064 Rem 1V. Declaration of Assignment: | dectare under penaly of perjury under the laws ofthe State of California thatthe foregoing is true and correct and that the above-entitled matter is property filed for assignment to the Stanley Mosk central ‘subd. (b), (c} and (d). Dated: Novenber 11, 2015 courthouse in the District of the Los Angeles Superior Court (Code Civ. Proc., § 392 et seq., and LASC Local Rule 2.0, SERATORE OF RTTORRE FER PARTY PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CAS! Original Complaint or Petition. | 2. If filing a Complaint, a completed Summons form for issuance by the Clerk. 4. Gil Case Cover Sheet form cN.O%0, 4. Complete Addendum to Ctl Case Cover Sheet frm LASC Approved CV 109 03.04 (Rev. 0806) 5. Paymentin ifthe fing fe, unless fees have been waived | 6. Signed order appointing the Guardian ad Litem, JC form 982(a)(27), if the plaintiff or petitioner is a minor \ under 18 years of age, or if required by Court 7. Adiional copies of documents tobe conformadby Ie Clerk, Coples ofthe cover shee! ad this addendum | 7 Rest eoaswee sath tne summons na contain or shat ang soslog iste care ' eh ‘ 3 8 eA PIV 109 03-04 (Rev. 03706), CIVIL CASE COVER SHEET ADDENDUM LASC, rule 2.0 “ LASC Approved AND STATEMENT OF LOCATION Page 4 of 4