IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF CONNECTICUT

CIVIL ACTION NO.

N 84 497 JAC

ALFRIEDA SLEE, Administratrix

Of the Estate of Jack Andrew Slee
Deceased,
1329 Rt. 163
Oakdale, Ct. 06370,

Plaintiff,

v.

WERNER ERHARD
765 California Street
San Francisco, California 94108,

And

WERNER ERHARD AND ASSOCIATES

A California Sole Proprietorship
765 California Street
San Francisco, California 94108,

And

STEVE ZAFFLIN
765 California Street
San Francisco, California 94108,

Defendants.

COMPLAINT IN TRESPASS FOR WRONGFUL DEATH

DEMAND FOR JURY TRIAL

(1), DOCUMENT NO. 18

GENERAL ALLEGATIONS

Plaintiff, by counsel, claims and alleges as follows:

1. Plaintiff ALFRIEDA SLEE, is Administratrix of the estate of JACK ANDREW SLEE,

deceased, pursuant to appointment by the State of Connecticut Court of Probate,
District of Montville, on June 21, 1984, and is an adult who is, and at all times
herein mentioned has been, a resident and citizen of the State of Connecticut.

2. JACK ANDREW SLEE, deceased, was a resident and citizen of the State of
Connecticut until his death.

3. Defendant WERNER ERHARD is an adult individual who is, and at all times herein
mentioned has been, a resident of the City of San Francisco, State of California,
and a citizen of California.
4. Defendant WERNER ERHARD AND ASSOCIATES is a sole proprietorship owned and
operated by defendant WERNER ERHARD with its principal place of business in the
City of San Francisco, State of California, and is a citizen of California.

5. Defendant STEVE ZAFFLIN IS AN EMPLOYEE OF WERNER ERHARD AND ASSOCIATES and is

the individual who conducted the est training refered to in paragraph 19 below.

6. Jurisdiction of this Court is based up on diversity of citizenship and amount

in controversy, 28 U.S.C. sec. 1332.

7. Plaintiff is informed and believes and thereon alleges that at all times
herein mentioned, each of the defendants was the agent of the other defendants,
and in doing the things hereinafter alleged, each was acting within the scope of
such agency and was acting with the permission and consent of the remaining
defendants.

8. At all times relevant to this complaint WERNER ERHART AND ASSOCIATES acted or
failed to act through its officers, agents, servants and/or employees acting
within the scope of their office, agency and/or employment.

9. Erhard Seminars Training was designed, developed, and implemented by defendant

WERNER ERHARD in approximately 1971.

10. The word �est� is an acronym for Erhard Seminars Training.

11. The est training is a �large group awareness training� presented to members
of the general public during four day-long sessions occurring on Saturday and
Sunday of two consecutive weekends.

12. The est training has been presented to large groups of members of the general
public in Connecticut and elsewhere on a semi-regular basis ever since it was
first developed by WERNER ERHARD in 1971.

13. From its inception, the basic form and content of the est training has
remained largely unchanged.

14. The basic form and content of the est training as it is presented in various
cities in the U.S.A. is the same.

15. From the time of its original development until the present, WERNER ERHARD
has maintained control over the content, administration, and delivery of the est
training.

16. Mr. JACK SLEE, plaintiff�s decedent, in response to representations and

inducements of agents of the defendants WERNER ERHARD and WERNER ERHARD and
ASSOCIATES, enrolled in the est training and agreed to pay a fee of $425.00 in
return for which the defendants agreed to deliver the est training to him.

17. JACK SLEE�S participation in these programs occured as a result of

recruitment, marketing and/or high pressure selling tactics originated by the
defendants and not because JACK SLEE independently decided to participate in the
est trainings.

18. In the recruitment, selling and/or marketing of the est training attended by
JACK SLEE the defendants either individually or acting through their officers,
agents, servants and/or employees acted in a coercive manner, made affirmative
representations either explicitly or by implication to JACK SLEE to the effect
that he needed said est trainings, that said est trainings were safe for him and
that he would benefit from said trainings, all of which were untrue.

19. On Saturday, August 13 and Sunday, August 14, 1983, JACK SLEE attended the
first two days of the est training sessions in New Haven, Conn., and was subjected
to the psychological methods, procedures, and processes which are standard
ingredients of the est training.

20. The est training attended by JACK SLEE was conducted by defendant Werner
Erhart and Associates by and through its employees and agents acting within the
course and scope of their employment and agency, including defendant STEVE ZAFFLIN
who was the trainer for this particular training.

21. WERNER ERHARD and other employees of WERNER ERHART AND ASSOCIATES were
responsible for training the trainers who conducted the est trainings and for
training the est trainer who delivered the est training to JACK SLEE.

22. The est training designed by WERNER ERHARD and delivered to members of the
general public for a fee, including JACK SLEE, was designed to, and did in fact,
subject participants to psychological principles, methods, procedures, and
�processes�, including techniques of psychotherapy, for the purpose affecting
emotions, feelings, beliefs, psychological states, attitudes and behavior.

23. During the est training attended by JACK SLEE the defendants and their
employees and agents inflicted intense amounts of physical and psychological
stress upon JACK SLEE and other participants, in reckless and outrageous disregard
of the safety of JACK SLEE and the other participants.

24. The infliction of emotional and psychological stress in est trainings is

intentional and is designed into the trainings by the defendants.

25. The techniques and practices utilized by defendants in conducting the est
training had caused psychological and other injuries to a substantial number of
participants both prior to the time JACK SLEE took the training and subsequently.

26. Through actual observation of the harmful effects which the est training had
on various participants, from reports of psychological injury to participants in
the training and from articles published in respected medical journals prior to
the time JACK SLEE took the training, the defendants knew or should have known of
the harmful effects of their training, that their training caused intense
emotional distress to many trainees and it was therefore reasonably foreseeable to
defendants that members of the general public, including JACK SLEE, would be
injured by the training as of the time the JACK SLEE took the training. Despite
this knowledge, defendants induced JACK SLEE and others to attend the est training
without informing them of the true nature of the est training, in reckless
disregard of their safety without warning them of the dangers of taking the
training and without employing adequate screening procedures to insure that the
training was safe and appropriate for those entering the training.

27. Prior to the est training the defendants failed to inform or warn JACK SLEE
about or regarding the conditions and stress to which he would be subjected,
misrepresented the nature of the programs and failed to disclose the training
methods and techniques which would be used.

28. None of the defendants who conducted the est training attended by JACK SLEE
were licensed by the State of Connecticut to practice psychology; the est training
attended by JACK SLEE constituted the unlicensed practice of psychology; and none
of the officers, agents, servants and/or employees who conducted or were otherwise
in any way responsible for the conduct of said est training were licensed or
otherwise qualified in Connecticut by generally recognized standards as
counselors, therapists, social workers, psychiatrists or psychologists.

29. During the est training referred to above JACK SLEE was subjected to
psychological pressures; group pressures which resulted from the manipulation of
other participants by defendant�s personnel in charge of the training sessions;
mind control techniques which caused him to lose his ordinary psychological
defenses; emotional confrontations which caused him to become emotionally
distraught and which lead to physical reactions resulting in his death; and
sensory and bodily deprivation through limitation of access to food, bathroom
facilities, sleep; and general control of the training environment.

29. During the est training JACK SLEE exhibited unusual behavior and
psychological and physical distress to which defendants failed to promptly and
effectively respond, in part because of the large numbers of persons enrolled in
the program and because the program followed a set and established pattern not
tailored to the individual needs of the participants.

30. After JACK SLEE became physically distressed as a result of an emotional and
psychologically confrontive est process, the defendants individually or acting or
failing to act through their employees or agents, failed to adequately respond to
his medical emergency and otherwise delayed the receipt of prompt medical care,
all in reckless disregard of the health and safety of JACK SLEE.

31. As a direct and proximate result of the conduct of the defendants and their
agents as alleged herein, JACK SLEE collapsed into unconsciousness during the
second day of est training, and was taken to Yale New Haven Hospital where he was
pronounced dead.

32. JACK ANDREW SLEE�S death was caused by the est training, which was designed,
administered, monitored and otherwise an agency under the exclusive control of
defendants.

33. As a result of his death JACK SLEE, his estate and his beneficiaries have
suffered damages including, inter alia, medical expenses, funeral expenses, pain,
suffering, loss of future earnings and future earning capacity and loss of the
enjoyment of life�s pleasures.

COUNT ONE
NEGLIGENCE

Plaintiff incorporates by reference paragraphs 1 through 33 of this Complaint as

though fully set forth herein.

All damages sustained by plaintiff and plaintiff�s decedent were directly and
proximately caused by defendants� negligence, recklessness and carelessness as
described below:

34. In designing the content, supervising the presentation and conducting the est
training attended by JACK SLEE, defendants were negligible in that they failed to
exercise reasonable care to avoid foreseeable injury to members of the general
public attending the training, including JACK SLEE.

35. In supervising the marketing techniques and representations made to members

of the general public, which techniques and representations were used to attract
JACK SLEE and other members of the general public to attend the est training,
defendants failed to exercise reasonable care to avoid foreseeable injury to
members of the general public attending the training, including JACK SLEE.
36. In training the est trainer who conducted the training attended by JACK SLEE,
defendants WERNER ERHARD and WERNER ERHARD and ASSOCIATES were negligent in that
they failed to exercise reasonable care to avoid foreseeable injury to members of
the general public attending the training, including JACK SLEE.

37. In addition to the foregoing, defendants and their agents were careless and
negligent in the design and administration of the est training attended by JACK
SLEE in that said defendants:
a. Incorporated into the est training and applied to JACK SLEE unreasonably
powerful manipulative psychological processes and techniques posing an
unreasonable risk of severe mental, emotional, or physical distress to JACK SLEE.
b. Failed, despite notice and knowledge of injuries caused by est training,
to adequately study defendants� methods and processes to ascertain the nature and
degree of the danger posed by est trainings and to modify techniques and processes
used in conducting the est training in order to make est trainings safe for
participants;
c. Failed to have trained, skilled individuals observing participants
during est trainings in order to detect signs of undue mental or physical stress
or symptoms of psychological decompensation;
d. Failed to adopt adequate screening procedures so as to exclude or
withdraw from the est training participants, including JACK SLEE, whom defendants
knew, or should have known, were susceptible to mental, emotional or physical
injury as a result of the est training.
e. Failed to design and conduct est trainings with the same degree of skill
as is exercised by mental health professionals in applying the same psychological
processes and techniques as used in est trainings;
f. Failed to recognize the magnitude of JACK SLEE�S distress resulting from
the est training and failed to facilitate prompt professional intervention.
g. Delayed the receipt of prompt medical care to JACK SLEE.
h. Were otherwise negligent under the circumstances.

COUNT TWO
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Plaintiff incorporates by reference paragraphs 1 through 37 of this Complaint as

though fully set forth herein.

38. All damages sustained by plaintiff and plaintiffs� decedent were directly and
proximately caused by defendants� intentional acts of infliiction of emotional
distress as previously described.

COUNT THREE
IMPLIED WARRANTY

Plaintiff hereby incorporates by reference all previous paragraphs of this

Complaint as if fully set forth herein.

39. The facts as set forth herein stste a cause of action for breach of implied
warranty since the defendants� training programs were not reasonably fit for the
purposes for which they were offered to the public. As a result of said breach of
implied warranty of fitness JACK SLEE sustained injuries which resulted in his
death and plaintiff claims damages from the defendants for the previously
described damages.

COUNT FOUR
EXPRESS WARRANTY
Plaintiff hereby incorporates by reference all previous paragraphs of this
Complaint as if fully set forth herein.

40. The facts as set forth herein state a cause of action for breach of express
warranty. As a result of said breach of express warranty JACK SLEE sustained
injuries which resulted in his death and plaintiff claims damages from the
defendants for the previously described damages.

COUNT FIVE
FRAUD

Plaintiff hereby incorporates by reference all previous paragraphs of this

Complaint as if fully set forth herein.

42. In that defendants acted in an outrageous manner and with reckless disregard
for the safety of JACK SLEE and other training participants, the facts as set
forth herein state a cause of action for punitive damages in favor of plaintiff
pursuant to Connecticut law.

COUNT SEVEN
STRICT LIABILITY

Plaintiff hereby incorporates by reference all previous paragraphs of this

complaint as if fully set forth herein.

43. Based upon the facts as set forth herein the defendants are strictly liable
to plaintiff for damages flowing from their provision of an inherently dangerous
product, service or activity.

COUNT EIGHT
UNFAIR TRADE PRACTICE

Plaintiff hereby incorporates by reference all previous paragraphs of this

Complaint as if fully set forth herein.

44. Based upon the facts as set forth herein the defendants are liable to
plaintiff for compensatory and punitive damages as well as reasonable attorney�s
fees and costs for violating the Connecticut Unfair Trade Practices Act.

WHEREFORE, plaintiff, ALFRIEDA SLEE, Administratrix of the estate of JACK ANDREW

SLEE, deceased, by her counsel, Gerald F. Ragland, Jr. hereby demands a trial by
jury of the issues raised herein and prays for a judgment for compensatory damages
in the amount of $2,500,000.000 (two and one half million dollars) and for
punitive damages in the amount of $2,500,000.000 (two and one half million
dollars) and for such other relief and additional monetary judgement as is deemed
appropriate in this case.

[signature]
GERALD F. RAGLAND, JR.
Counsel for Plaintiff
Suite 601, Widener Building
Philadelphia, Pa. 19107
(215) 563-2626

Connecticut Counsel:

[signature]
ELIZABETH A. GALLAGHER
Gallagher and Gallagher
1377 Boulevard
New Haven, Connecticut 06509
(203) 624-4165