Gerald F. Ragland, Jr.

“ 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. ”

“ 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 ”

“ 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. ”