Factual Background

Sam Sanghai (Sam) was born in 1963 in California. He grew up practicing yoga with his parents who emigrated from India and were themselves yoga instructors. When he became a teen, Sam began studying yoga with well-known yoga teachers including Bikram Choudhury, an Indian-born American yoga guru.ii Sam eventually became a yoga instructor and began building a career as such.

Over a period of years, Sam's popularity as a yoga teacher grew. He founded his first yoga studio in Chicago, and eventually created his own unique platform for yoga called "Sangha Power Vinyasa Yoga" which he marketed to aspiring yoga teachers in teacher trainings held in the U.S. Canada and Mexico. Sam formally organized his business as the Sam Sangha Yoga Institute ("SSYI"), incorporated in Arizona in 1995. He presently lives in Phoenix with his current partner and two children.

The SSYI business model includes at its core its yoga teacher trainings which are offered by Sam at least ten times every year in beautiful locations in Montana, New York, New Mexico, West Virginia, as well as in Vancouver, British Columbia and Baja, Mexico. The cost of a teacher training for a one-week immersion is $5,000 per person. No scholarships are available. There are three levels: Beginning Teacher (Novice); Intermediate Teacher (Accomplished); and Advanced Teacher (Leader). A person who completes all three invests upwards of $15,000 in yoga teacher education, plus the cost of transportation.

In 2018, Sam added an additional training which he offered only to yoga teachers who had completed the Leader training and were hand-picked by him. The "Faculty In Training" course, or "FIT", is completed during 7 long immersion weekends completed over the course of a year. FIT is marketed as the pathway to hosting SSYI yoga programs on one's own. The course promises participants the development of yoga teacher skills necessary to successfully be a SSYI program leader. It costs $17,500 for tuition. Not one of these teacher trainings is accredited and no governing body monitors these programs.

The first FIT cohort of students started their program in September of 2018. They came from 15 different states in the U.S. Upon arrival on location near Bozeman, Montana, the 20 hand-selected Leader level yoga teachers were divided into 5 groups. Sam assigned each group the task for the year of creating the curriculum for 5 individual programs, such as "teen yoga" and "yoga for detoxification and renewal". In essence, the FIT team of students were paying to create curriculum for Sam and the SSYI. No one received compensation for this work. There was no documentation of the relationship such as a contract assigning rights to these curricula to Sam or SSYI.

The second component of the SSYI business model is yoga teacher certification. Anyone who completes the first level, Novice, can apply to be a certified Sam Sangha teacher. The cost of certification is $150 USD for the first year and $75 USD every year thereafter. There are upwards of 750 certified Sam Sangha teachers globally.

The third component of the SSYI business model is yoga studio affiliations. Teachers who complete the Novice, Accomplished and Leader levels of teacher training are eligible to affiliate their yoga studio with the SSYI. For example, a yoga studio owner/teacher who owns a studio in Dallas, Texas, can complete the Leader level and thereafter apply to affiliate their studio with the SSYI. Affiliation costs approximately $15,000 USD per year. In exchange for the fee, the studio gains the privilege of calling itself a Sam Sangha affiliate. There are over 50 studio affiliates in the U.S., Europe, and Asia.

In connection with the expansion of affiliated studios and wanting to extend his reach outside of North America, Sam joined forces with one of his proteges, Denise Dubois, and in 2008 established a yoga studio and institute in Nigeria in the capital city of Abuja. This was no easy accomplishment as Nigeria is well-known for its corruption. Sam and Denise met with several government officials over the course of months. Ultimately, one of the Abuja legislators (Official A) offered to allow Sam and Denise to establish a yoga institute to train Nigerian youth in yoga in exchange for 5 Lamborghinis for himself and his staff. Sam and Denise agreed. In order to speed up the process of grants and licenses, Sam and Denise agreed to pay a lower-level government officer (Official B) a fee amounting to $10,000 USD. The money to pay these fees and for the cars was paid from the SSYI bank accounts in the U.S. In 2009 the doors of the first African SSYI affiliate studio and youth training center in Abuja opened. It is called Youth for Yoga in Africa.

Over his years of leading the SSYI, there were rumors that circulated at the teacher trainings, at the affiliate studios, and in the home offices in Arizona that Sam used his position of influence to sexually proposition students and volunteer assistants at the trainings, and even employees themselves, and that he was having sexual relations with sometimes 10 women at a time. It seemed like the staff that volunteered and was employed by the SSYI rotated almost annually without explanation, with a few loyalists

remaining who are still working for Sam today. There were never any official complaints filed to police or any civil lawsuits filed against Sam. Unlike his mentor, Bikram, he continued despite these rumors to generate enormous profits for the Institute and for himself personally. He even earned the status of "global ambassador" for a famous yoga apparel company.

The methodology applied in Sam Sangha Power Vinyasa Yoga is unique and hard to characterize. It does include the physical practice of yoga and that practice is perhaps one of the most challenging in the yoga world and practiced in a heated environment. Beyond the physical practice there is a philosophy that on its surface seems positive, but has been accused of lacking in any compassion. It has been called "bullish", "psychologically manipulative", "shaming" and even "cultish". Students, volunteers and employees are told to "be a YES", or leave. The immersion into Sam's programs and operations require participants to be openly vulnerable with their personal stories which can lead to a very human need to fit in and belong with one's newfound yoga friends. And in that space, one can be easy manipulated into believing just about anything, including that one is "special" to Sam in all ways imaginable. And in truth, there is no psychological safety net as not one of the employees, volunteers, or Sam himself is a certified psychologist. When program participants break down, they are told to essentially get it together and fast, or face public shaming in one's Sangha community.

In late 2020, some of the former staff, employees, volunteers and students who suffered trauma at the hands of Sam started connecting. Some had been sexually manipulated into consent to sexual relations. Some had suffered bullying, or public shaming. These women and men had left the Sangha community upon finally realizing the grave harm that was happening to them psychologically so long as they stayed. In their words, leaving the Sangha community felt like escaping a cult. They created a private Facebook group where they could share their stories with each other so that they could heal their trauma. Members are from all over North America. Some members of the group named themselves. Most did not as they are feeling ashamed or fear retaliation even in the private space.

Word did leak to the SSYI and one of Sam's loyal employees fraudulently posed as someone who suffered trauma in the Sangha community to gain access to the private group. That person provided to Sam the names of those Facebook group members who did name themselves. Shortly thereafter, Sam's attorney in Philadelphia sent letters to two of them, Emily and Justine, threatening to sue them for defamation unless they shut up. The stories of these two women follow.

EMILY

Emily is a twenty-six-year-old woman who resides in Washington, D.C. She is a part- time SSYI certified yoga teacher, full time nurse and mother of two young children. She

attended yoga classes at a SSYI affiliated studio in D.C. for a few years. At the encouragement of the studio owner (himself SSYI certified), Emily attended the Novice level training in West Virginia. The following year she attended the Accomplished level training in Montana and shared during that immersion with the group about her pending divorce and other personal challenges. She shared openly and vulnerably. After her sharing session but still during the training, she received a friend request from Sam on Facebook asking her to his room for further discussion. She was flattered and while still feeling a little vulnerable, accepted his invitation. When in his room, Sam propositioned Emily and she ultimately had sex with him. The next day, the program director for the Accomplished level training asked Emily to sign an NDA (nondisclosure agreement). The terms required her to keep secret any knowledge she gained about Sam professionally or personally for an undetermined length of time. Feeling embarrassed and confused, Emily agreed and signed the NDA. Sam thereafter encouraged Emily to register for the Leadership level training coming up in a few months in Mexico. She told him of her financial challenges, but he was able to convince her to sign up that day with him paying for her airfare to Los Cabos. Over the next several weeks Sam and Emily exchanged texts and when she arrived for the Leadership training, Emily attended as any other participant; however, she spent a few nights with Sam in his suite. While in Mexico Emily discovered that a new friend she made at training had started having a sexual relationship with Sam at this training and was staying in his suite on the nights she was not. Emily left the training and community heartbroken and in deeper debt.

JUSTINE

Justine is a forty-two-year-old woman who at one time was employed as the Operations Manager for the SSYI. She resides in Utah. When she started her job, she signed an NDA (nondisclosure agreement) promising to keep secret all she learned about Sam professionally or personally "during her employment and beyond". As Operations Manager, Justine's responsibilities included creating and collaborating with Sam to create content for his ten-plus trainings per year. In truth, Justine was the sole creator of the curriculum for these trainings. She was never acknowledged for that work and Sam continues to use that content today. She was also responsible to ensure maximum enrollment and attendance at the trainings themselves using social media marketing and marketing through the SSYI affiliated studios. Caps for enrollment are 250 students. In addition, Justine was, at Sam's request, creating the content for his new book as a ghostwriter who would not get any credit at publication. The book she wrote on Sam's behalf, "Woke", was published in 2020. Thousands of copies have been sold and Yoga Journal has named Sam "author of the year."

Justine travelled to the multiple trainings per year, both local and international. During the trainings she acted as his personal assistant which included passing Sam's cell number to multiple women at each and letting them know Sam wanted to connect with them one-on-one. Justine witnessed the women coming and going from his room at all hours.

At Sam's request, Justine invited and "love bombed"iii the women Sam was attracted to at trainings and trips, including to Nigeria for Youth for Yoga in Africa workshops. During these trips, Sam would attempt to seduce these women who were far away from home and believed their newfound community had their best interest at heart.

While working on site in Arizona at the SSYI, Justine was constantly pressured to work late hours and give up her weekends to get her work done. When she failed to meet deadlines, Sam chastised her in front of the other staff, and shamed her for taking so long commenting that she must be "hormonal and at that time of the month." This happened regularly as Justine's job was really that of two people.

Justine finally quit after a wellness center the SSYI was negotiating to purchase for its teacher trainings pulled out of the negotiations. Justine was responsible for "handling" the owners of the center. She was instructed by Sam to make the male ownership team feel "special" in ways that were similar to the love bombing technique she was instructed to use on the female students at yoga teacher trainings. When Sam found out the negotiations were terminated, he was enraged and in front of five of her co-workers called Justine "worthless and selfish". He said, "Justine, you are just all about yourself. You have always been just all about yourself."

As Emily's and Justine's experiences were unfolding, 5 of the FIT students from the 2018 cohort began complaining the Sam and the SSYI that although they completed FIT, they were not given any opportunities to lead SSYI programs as promised. Sam dismissed them each in turn, calling them incompetent and not worthy to be program leaders. However, Sam has been consistently using the curricula developed by these 5 at his programs across the U.S. and Canada.

Meanwhile in Nigeria 15 students of Youth for Yoga in Africa complained to their families that they had been subjected to sexual abuse at the hands of Denise Dubois, Sam's protege, who was the acting director of that studio. Each one of these young men was under the age of eighteen. Their families fear complaining to the government because of the corruption and because of Abuja's open support of the organization. They do not think they will get justice in Nigeria. With the victims' families' permission, a nonprofit in NYC, the Africa Justice Project, wants to file a lawsuit on their behalf in Federal District Court in NY claiming damages for that sexual abuse.

PART A

The 5 FIT students have come to you for help and legal representation. They live in five different states: Florida, Maine, Pennsylvania, Virginia and Wyoming. Advise them of any legal claims they may have against Sam and the SSYI; and also of any complications of pursuing justice in the courts in their home states. Make IRAC for any and all claims, and defenses that are relevant.