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... See more

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.

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,... See more