ENDORSED FILED ALAMEDA C 1 E. John Vodonick Ph.D. (SB#063089) OUNTY Vodonick Lawfirm SEP 1 8 2019 PO Box 763 2 CLERK OF Nevada City. California 95959 THESU.PERlOR COUR By 3 Telephone 530 478 1078 : ERICA BAKER Deo Facsimile 530 687 6304 utv
4 Attorney for: Plaintiff 5
6 SUPERIOR COURT OF THE STATE OF CALIFORNIA
7 IN AND FOR THE COUNTY OF ALAMEDA
8 STANLEY KRIPPNER, Ph.D. ) Case No. G 9 0 3 5 7 :J8 ) 9 Plaintiff, ) VERIFIED COMPLAINT FOR BREACH OF ) CONTRACT, STATUTORY VIOLATION 10 vs. ) (LABOR CODE §§201, 203, 218.5), ) WRONGFUL TERMINATION (FAIR 11 SAYBROOK UNIVERSITY a California ) EMPLOYMENT AND HOUSING ACT, Non-Profit Corporation, TCS ) CALIF. GOVT. CODE §12900-12996) 12 EDUCATION SERVICES an Illinois ) WRONGFUL TERMINATION IN Not-for-Profit Corporation, ) VIOLATION OF PUBLIC POLICY, 13 NATHAN LONG ) INFRINGEMENT OF COMMON LAW Does 1 through 100, ) COPYRIGHT, INTENTIONAL 14 inclusive, ) INTERFERENCE WITH PROSPECTIVE ) ADVANTAGE, INVATION OF PRIVACY 15 Defendants. ) ( FALSE LIGHT) , · APPROPRIATION OF ) LIKENESS (CALIF. CIV. CODE 16 ) §3344), UNFAIR COMPETIOTN ) (Calif. Bus. & Prof Code. 17 ) §17200) ) 18 ) ) 19
20 For Cause of Action Plaintiff STANLEY KRIPPNER, Ph.D. alleg�s as 21 follows. 22 GENERAL AND COMMON ALLEGATIONS 23 1. Plaintiff Stanley Krippner, Ph.D. (hereinafter "Plaintiff u is 24 an individual resident in the County of Marin City of City of San 25
1 1 Rafael.
2 2. Defendant Saybrook University (hereinafter "Saybrook") is a
3 California corporation with principal place of business and doing
4 business in Pasadena, California and throughout the world.
5 3. TCS Education Services (hereinafter "TCS") is a Illinois not
6 for profit Corporation doing business in California but which is
7 not qualified to do business in California, has never been
8 qualified in California and has never paid California Franchise
9 Tax since at least 2013. TCS has manipulated the facts of its
10 existence and operations in order to attempt to avoid being under
11 the oversite and jurisdiction of the California State Attorney
12 General pursuant to Calif. Govt. Code§ 6910. TCS purports to be a
13 "charitable corporation" as the same is defined and applied by and
14 in Calif. Govt. Code§§ 1258.1, 12582.1.
15 4. TCS originally was founded as Santa Barbara Graduate Institute,
16 A nonprofit public benefit corporation in January 2002 and was
17 renamed as the Santa Barbara Graduate Institute Center for
18 Clinical Studies and Research a California nonprofit public
19 benefit corporation in October, 2002. In July 2009 it was
20 converted from a public benefit corporation to TCS Education-Santa
21 Barbara, LLC. On May 22, 2012 TCS Education-Santa Barbara, LLC
22 dissolved by the filing of a Certificate of Cancellation with the
23 Secretary of State of California.
24 5. In 2013 TCS (which describes itself as an "entrepreneurial,
25 nonprofit higher education system"), entered into a contractual
2 1 relationship by which TCS purported to administer the business
2 affairs of Saybrook in areas that included admissions, marketing,
3 online education services, finance, accreditation, compliance, and
4 human resources. At or about the same time Plaintiff is informed
5 and believes and thereupon alleges that TCS also entered into
6 similar contracts with the Santa Barbara and Ventura Colleges of
7 Law, Pacific Oaks College and Pacific Oaks Children's School, all
8 located in California
9 6. Plaintiff is informed and believes that Defendant Nathan Long
10 (hereinafter "Long") is a resident of the State of California,
11 County of Los Angeles. Long currently occupies the office of the
12 President of Saybrook. The acts and omissions of Long were taken
13 and engaged in pursuant to the actual and ostensible
14 authority granted to him by Saybrook, TCS and does 1 through 100
15 inclusive.
16 7. Plaintiff is unsure of the true names or capacities of the
17 defendants named herein as Does 1 though 100 inclusive and
18 therefore sues said defendants by such fictitious names. Plaintiff
19 will amend this complaint when the true names and capacities of
20 said defendants have been ascertained.
21 8. At all times material and mentioned herein, each and every
22 defendant was the agent, servant and employee and in doing the
23 things and making the omissions alleged was acting within the
24 actual or apparent scope of said agency, service or employment
25 and/or under the direction, control or ratification of a corporate
3 1 director or management level employee.
2 8. At all times material and mentioned herein each and every
3 defendant caused and/or contributed to the injuries, wrongful acts
4 and damages alleged herein.
5 9. Saybrook was founded in 1971 as the Humanistic Psychology
6 Institute a California Nonprofit Corporation located at the
·7 California State University at Sonoma by the noted Psychologists
8 Eleanor Camp Criswell, Rollo May, Clark Moustakas, and James
9 Bugental. In 2005 Saybrook changed its name to Saybrook Graduate
10 School and Research Center and in 2009 further changed its name to
11 Saybrook University. Since its inception as the Humanistic
12 Psychology Institute Saybrook has become the preeminent center for
13 the teaching, research and advancement of Humanistic Psychology
14 together with other departments and colleges created by Saybrook
15 including the Department of Organizational Systems, Mind-Body
16 Medicine or acquired by Saybrook such as the LIOS Graduate School.
17 10. The actions of TCS in its relationship with Saybrook have
18 resulted in the complete domination of the Board of Trustees of
19 Saybrook which has no independence from TCS. All decisions made by
20 the Officers and Board of Trustees of Saybook {including Defendant
21 Nathan Long) are made for the express or implied purpose of
22 directing cash flow to TCS while at the same time reducing
23 courses, departments, colleges and teachers (including Plaintiff).
24 11. Plaintiff was not one of the original organizers of Saybrook
25 but became a leader of the Humanistic Psychology Department of
4 '· '-
1 Saybrook soon after it was formed. Plaintiff is one of the leading
2 thinkers and practitioners of Humanistic Psychology and has a
3 world-wide reputation as such. Prior to his termination Plaintiff
4 was a member of the faculty of the Department of Psychology at
5 Saybrook University for almost 50 years, and the former Director
6 of the Dream Laboratory, Maimonides Medical Center in Brooklyn,
7 NY. Plaintiff has received lifetime achievement awards from the
8 Parapsychological Association, the International Association for
9 the Study of Dreams, and the Society for Humanistic
10 Psychology. Plaintiff is the past president of all three groups
11 as well as the Society for Psychological Hypnosis which awarded
12 him its 2002 Award for Distinguished Contributions to Professional
13 Hypnosis. Krippner is a Fellow of the Society for the Scientific
14 Study of Religion, the Society for the Scientific Study of
15 Sexuality, and five divisions of the American Psychological
16 Association, which granted him its 2002 Award for Distinguished
17 Contributions to the International Development of Psychology.
18 Plaintiff is co-author of the award-winning book Personal
19 Mythology, and co-editor of the award-winning book Varieties of
20 Anomalous Experience, and has published over 1,000 peer-reviewed
21 articles or reviews. A true and correct copy of Plaintiff's
22 Curriculum Vitae is hereunto affixed as exhibit "A" and made a
23 part hereof as if set forth in full.
24 12. For almost fifty years and continuing Saybrook has utilized 25 Plaintiff's reputation, academic standing and impact in the
5 1 Humanistic Psychology community to attract and mentor students of 2 psychology, and related fields. During that time Saybrook has 3 utilized Plaintiff's image, books, lectures and presence to 4 advance its particular and unique form and process of psychology 5 and had become preeminent in that field primarily due to its
6 relationship with Plaintiff and throughout that time developed a
7 special relationship of trust and confidence with Plaintiff.
8 13. On or about April 18, 2018 Plaintiff and Defendants Saybrook,
9 TCS and Does 1 through and including 100 entered into a contract
10 in writing that provided for Plaintiff's Faculty Appointment. Said
11 contract was entered into in the County of Alameda, City of
12 Oakland, California. A true and correct copy of Plaintiff's
13 Faculty Appointment Contract is hereunto affixed as exhibit "B"
14 and made a part hereof as if set forth in full. Plaintiff has
15 performed all duties assigned to him by such contract. Among other
16 things Plaintiff's Faculty Appointment contract was in force and
17 effective from June 2, 2018 through and including May 31, 2019
18 until terminated by Defendants and each of them as alleged below,
19 the acts and omissions alleged herein occurred in the County of
20 Alameda, City of Oakland unless specified to the contrary.
21 14. At all times material and mentioned herein Defendants and
22 each of them had and maintained a policy and procedure to accord
23 faculty a policy of formal resolution of grievances for
24 disciplinary actions taken by Defendants and each of them in
25 relationship to faculty. Said policy and procedure were expressly
6 1 and/or impliedly contained within the employee handbooks of
2 Defendants and each of them.
3 15. At all times material and mentioned herein Defendants and
4 each of them had adopted a policy and procedure to pay to an
5 employee a sum equal to at least eight weeks of salary upon
6 termination. Said policy and procedure was expressly and/or
7 impliedly contained within the employee handbooks of Defendants
8 and each of them.
9 16. Saybrook and TCS provided plaintiff with a computer to be
10 used by Plaintiff in connection with his duties as a faculty
11 member of Saybrook and TCS. In addition, Plaintiff was invited and
12 encouraged to use computers so provided for research purposes, to
13 contact students and to publish academic papers, reviews of
14 papers, books, articles and related material and to use the
15 computer and library access to create those original works.
16 Materials created by Plaintiff were not work for hire but remained
17 the intellectual property of Plaintiff regardless of the fact that
18 the computer itself remained the property of Saybrook and TCS. At
19 all times material and mentioned plaintiff was assured in the
20 safety, security and confidentiality of the intellectual property
21 that Plaintiff so created, the communication and relationships
22 documented by him, and the research documented by him.
23 17. Approximately twelve years ago Plaintiff was granted
24 sabbatical leave of one year with full pay. At that time Plaintiff
25 and Saybrook agreed that he would take one half of his sabbatical
7 1 at that time and the other half upon his retirement. Subsequently
2 Defendant Nathan Long confirmed that agreement and further agreed
3 that upon his retirement Plaintiff would be accorded the title of
4 Professor Emeritus a title that is rarely accorded and therefore,
5 is highly valuable, academically and financially.
6 FIRST CAUSE OF ACTION
7 Breach of Contract against Defendants Saybrook, TCS, Nathan Long
8 and Does 1 through and including 100
9 (First Count-Damages_
10 18. Plaintiff incorporates by this reference each and every
11 allegation appearing in paragraphs 1, though and including 17 as
12 if set forth in full at this point.
13 19. Beginning on May 28, 2018 and continuing Defendants and each
14 of them breached Plaintiff's faculty Contract by:
15 A. terminating Plaintiff's employment on that day,
16 B. refusing to return the computer with Plaintiff's
17 intellectual property, contact information for his students,
18 research, documents and original work being edited by Plaintiff
19 and other original, and/or derivative and/or work that Plaintiff
20 had a proprietary and/or contractual and or private interest
21 therein,
22 C. failing and refusing to remit and pay to Plaintiff
23 severance in the minimum amount of eight weeks salary,
24 D. failing and refusing to remit and pay to Plaintiff
25 annual salary pursuant to the negotiated sabbatical previously
8 1 awarded to Plaintiff,
2 E. failing and refusing to accord to Plaintiff the title of
3 Professor Emeritus, a title only rarely bestowed and therefor of
4 extreme honor and economic value,
5 F. cancelling and terminating his health insurance,
6 G. refusing to allow Plaintiff to participate in the
7 institutional grievance process after demand therefore,
8 H. cancelling and deleting his email address, refusing to
9 forward any email directed to that address to Plaintiff and
10 refusing to provide further addresses upon inquiry, and
11 I. by perpetrating other things and acts and inactions
12 intended and calculated to inflict economic harm and Plaintiff's
13 reputation,
14 20. Plaintiff has been generally damaged in the amount of ten
15 million dollars ($10,000,000) or as according to proof.
16 21. Plaintiff has been specially damaged in the amount of two
17 hundred thousand dollars for lost severance and other wages
18 ($200,000) or as according to proof together with interest thereon
19 at the legal rate.
20 (Second Count- Unjust Enrichment, Accounting)
21 22. For almost 50 years Plaintiff has been instrumental in
22 building the Academic reputation of Saybrook, attracting students
23 and building the tradition of Humanistic Psychology.
24 23. Plaintiff performed such duties over and above his contractual
25 faculty obligations but pursuant to the express and/or implied
9 1
1 requests of Defendants and each of them. As part (but not all of
2 such activity Plaintiff performed the following:
3 A. Plaintiff was instrumental in acquiring accreditation from
4 the Western Association of Schools and Colleges and created the
5 standard required course modules,
6 B. Plaintiff included Saybrook's name on all his publications
7 and professional presentations,
8 C. Plaintiff listed Saybrook as co-sponsor of several
9 international forums and conferences,
10 D. Plaintiff brought internationally known speakers to
11 Saybrook for public forums in Oakland that included Dmitri
12 Leontiev, the most prominent Russian existential psychologist and
13 psychotherapist, and Bia Labate and Clancy Clavier to launch their
14 book on ayahuasca psychotherapy,
15 E. Plaintiff chaired or served on committees for dozens of
16 dissertations, giving Saybrook a positive reputation in terms of
17 academic rigor,
18 F. Plaintiff traveled extensively both nationally and
19 internationally lecturing in the field of Humanistic Psychology
20 referencing Saybook as the center of that school of thought,
21 G. Plaintiff recruited numerous students and faculty to
22 Saybook,
23 H. Plaintiff was interviewed numerous times for publications
24 and other media upon the generally subject of psychology and more
25 particularly Humanistic Psychology and during such occasions
10 l
1 always mentioned Saybrook,
2 I. Plaintiff influenced the arts, music and film with his
3 teaching and lectures,
4 J. Plaintiff served as the focus of the faculty of psychology
5 and mentor to junior faculty, and
6 K. Plaintiff contributed to the reputation, academic standing
7 and growth of Saybook in numerous other ways.
8 24. Plaintiff did so in complete reliance upon the promises of
9 the Defendants and each of them and the trust that he reposed in
10 the administration of Saybrook.
11 25. By the work, labor and skill of Plaintiff's Defendants and
12 each of them have become unjustly enriched and in particular
13 Defendants TCS and Does 1 through 100 have become enriched at the
14 expense of Plaintiff in an unknown sum.
15 26. It is appropriate that Defendants and each of them account to
16 Plaintiff in the amount that they have become unjustly enriched
17 and that the Court enter judgment in Plaintiff's favor upon such
18 amount.
19 SECOND CAUSE OF ACTION
20 STATUTORY VIOLATION (Calif. Labor Code §§201, 203, 218.5) against
21 Defendants Saybrook, TCS, Nathan Long and Does 1 through and
22 including 100
23 27. Plaintiff incorporates by this reference each and every
24 allegation appearing in paragraphs 18, though and including 24 as
25 if set forth in full at this point.
11 1 28. Defendants and each of them failed and refused to immediately
2 pay to Plaintiff the amounts due as wages for severance and for
3 sabbatical immediately upon termination as aforesaid.
4 29. Plaintiff has employed E. John Vodonick, Ph.D. attorney at
5 law to represent his interests in this matter. Plaintiff has
6 received a "Right to Sue" letter. A true and correct copy of such
7 letter is attached as exhibit �c" as if set for in full.
8 30. Plaintiff is entitled to his reasonable attorney fees
9 pursuant to California Labor Code §218.5.
10 THIRD CAUSE OF ACTION
11 WRONGFUL TERMINATION (Fair Employment and Housing Act, Calif.
12 Govt. Code §12900-12996). against Defendants Saybrook, TCS, Nathan
13 Long and Does 1 through and including 100
14 31. Plaintiff incorporates by this reference each and every
15 allegation appearing in paragraphs 27, though and including 30 as
16 if set forth in full at this point.
17 32. At the time he was terminated Plaintiff was 86 years old./.
18 Defendants and each of them terminated Plaintiff and
19 discriminated against him due to his age and for other
20 impermissible and wrongful reasons.
21 33. Plaintiff is entitled to future pay according to proof
22 34. The acts an omission of the Defendants and each of them
23 directly and proximately caused Plaintiff to suffer extreme and
24 enduring emotional distress and caused him to be hospitalized for
25 an extended period of time and will continue to case him extreme
12 1 and enduring emotional distress all to Plaintiff's general damages
2 in the amount of ten million dollars ($10,000,000.)
3 35. The acts and omissions of the Defendants and each of them
4 were perpetrated intentionally, purposefully and with implied and
5 express malice wherefore Plaintiff is entitled to additional
6 damages in an amount sufficient to set an example to Defendants
7 and each of them.
8 36. Plaintiff is entitled to his reasonable attorney fees
9 pursuant to California Labor Code §218.5.
10 FOURTH CAUSE OF ACTION
11 WRONGFUL TERMINATION IN VOLLATION OF PUBLIC POLICY, against
12 Defendants Saybrook, TCS, Nathan Long and Does 1 through and
13 including 100
14 37. Plaintiff incorporates by this reference each and every
15 allegation appearing in paragraphs 31, though and including 36 as
16 if set forth in full at this point.
17 38. Within two years last past Defendants and each of them urged
18 Plaintiff to sign and endorse a statement to be published on the
19 Saybook website and to be otherwise published to the effect that
20 Saybrook was a wonderful and enriching place to teach and in
21 particular was a wonderful and enriching place to teach Humanistic
22 Psychology and related disciplines. Plaintiff declined to do so
23 inasmuch as he did not believe in the truth of that statement and
24 in reliance upon his rights guaranteed to him by the First
25 Amendment to the United States Constitution and Section One,
13 1 Article One of the California Constitution and otherwise.
2 39. Within two years last past Defendants and each of them
3 insisted that Plaintiff endorse an academic change that moved the
4 process of editing student papers, theses and dissertations fr�m
5 independent editors to a "writing center" which Plaintiff is
6 informed and believes is under the direction, control and
7 ownership of TCS. Plaintiff refused to endorse this practice and
8 change of procedure in reliance upon his rights guaranteed to him
9 by the First Amendment to the United States Constitution and
10 Section One, Article One of the California Constitution and
11 otherwise.
12 FIFTH CAUSE OF ACTION
13 VIOLATION OF COMMON LAW COPYRIGHT, against Defendants Saybrook,
14 TCS, Nathan Long and Does 1 through and including 100
15 40. Plaintiff incorporates by this reference each and every
16 allegation appearing in paragraphs 37, though and including 39 as
17 if set forth in full at this point.
18 41. Within one-year last past despite the trust that Defendants
19 and each of them invited Plaintiff to place in them and despite
20 the assurances that his intellectual property stored upon the
21 computer provided to him by Saybrook would be safeguarded and
22 returned to him.
23 42. Defendants and each of them violated Plaintiff's common law
24 copyright by refusing to return all his intellectual property to
25 him in the form in which it was stored, removed drafts, papers and
14 1 documents under edit, research notes and all work in progress and
2 the form and format in which it was recorded and at all and in
3 fact significant data on his computer was intentionally removed
4 and destroyed.
5 43. Plaintiff has been specially damaged in the sum of ten
6 million dollars ($10,000,00) or as according to proof.
7 SIXTH CAUSE OF ACTION
8 INTEREFERENCE WITH PROSPECTIVE ADVANTAGE, against Defendants
9 Saybrook, TCS, Nathan Long and Does 1 through and including 100
10 44. Plaintiff incorporates by this reference each and every
11 allegation appearing in paragraphs 40, though and including 43 as
12 if set forth in full at this point.
13 45. Plaintiff stored all of his contact information with his
14 current, past and potential students as well as academic
15 institutions, lecture series organizers, publishers, research
16 centers, treatment centers and other persons and entities
17 following Plaintiff's work and interested in his projects and
18 teaching methods. Defendants and each of them have destroyed all
19 such records and have refused to make any available to Plaintiff.
20 46. within one year last past Defendants and each of them have
21 refused to provide any person contacting Saybook to inquire of
22 Plaintiff's contact information with his email address, telephone
23 number, physical address or any other way of contacting him
24 despite the fact that all of such are well known to Defendants and
25 each of them. Defendants and each have taken other and further
15 1 actions to impede and disrupt contacts between Plaintiff and
2 present and future students.
3 47. Each and every contact that was destroyed and /or impeded and
4 refused to make available to Plaintiff, was an economic
5 relationship that was likely to benefit Plaintiff.
6 48. Defendants and each of them well know of the existence of
7 such relationships and the likely economic benefit to Plaintiff.
8 45. Defendants and each of them intended to interfere with such
9 relationships and/or were substantially certain that such
10 interference would be the result.
11 49. The acts and omissions of Defendants as alleged were
12 independently wrongful in addition to destroying Plaintiff's
13 destroying Plaintiff's contact information and refusing to provide
14 the same to him in that:
15 A. It arose from the violation of his common law copyright,
16 B. It arose from a breach of trust,
17 C. It arose from the breach of contract,
18 D. It arose from other conduct forbidden by constitutional,
1,9 statutory, regulatory or other determinable legal standards.
20 50. As a direct and proximate result Plaintiff has been damaged
21 in the amount of ten million dollars ($10,000,000.) or as
22 according to proof.
,23
24
25
16 1
2 SEVENTH CAUSE OF ACTION
3 CONVERSION, against Defendants Saybrook, TCS, Nathan Long and Does
4 1 through and including 100
5 51. Plaintiff incorporates by this reference each and every
6 allegation appearing in paragraphs 44, though and including 50 as
7 if set forth in full at this point.
8 52. Prior to his termination Plaintiff loaned to Saybrook
9 original artwork created in response to his psychological project,
10 teaching methods and his presence. Plaintiff's purpose in loaning
11 such art to Saybrook was to enhance the academic reputation of
12 Saybrook.
13 53. Within two years last past Defendants and each of them have
14 refused to deliver Plaintiff's artwork to him and have converted
15 the same to their own use and benefit.
16 54. As a direct and proximate result Plaintiff has been damaged
17 in the sum of fifty thousand dollars ($50,000) or as according to
18 proof.
19 EIGHTH CAUSE OF ACTION
20 FALSE LIGHT INVASION OF PRIVACY, against Defendants Saybrook, TCS,
21 Nathan Long and Does 1 through and including 100
22 55. Plaintiff incorporates by this reference each and every
23 allegation appearing in paragraphs 51, though and including 54 as
24 if set forth in full at this point.
.25 56. On or about June 3, 2019 Defendants and each of them
17 1 published in social media under the signature of Defendant Long a
2 letter that represented:
3 "I want to assure the Saybrook community that this decision was not made lightly or with haste. Rather, the 4 decision was only made after a lengthy and detailed investigation into allegations against Dr. Krippner 5 conducted by an independent law firm retained by the University. Consistent with Saybrook's policy, Dr. 6 Krippner was given notice of the concerns, was interviewed on two occasions and was given multiple 7 opportunities to provide information. During the course of the investigation, Dr. Krippner acknowledged multiple 8 violations of University policy. The law firm confirmed the violations. Because this is an employment issue, and 9 to protect the privacy of other persons, we cannot provide any further detail about these violations." 10 57. The said publication was false and misleading and cast 11 Plaintiff in a false light. The true facts were that Plaintiff did 12 not acknowledge any violations of University policy, that 13 Plaintiff was not advised that he had the right to have counsel 14 present during any investigation, that he was not advised of the 15 nature of the inquiry regarding his actions or non-actions either 16 orally or in writing. 17 58. The false allegations so made were and are highly offensive to 18 any reasonable person and cast Plaintiff in a false light. 19 56. Defendants and each of them knew of the falsity of such 20 statements and/or acted in reckless disregard of the truth or 21 falsity of such statements. 22 59. As a direct and proximate result of such publication 23 Plaintiff has been specially damaged though the loss of 24 employment, consulting relationships and contractual tutoring of 25
18 1 various students and otherwise all to his damage in excess of five
2 hundred thousand dollars ($500,000).
3 EIGHTH CAUSE OF ACTION
4 APPROPRIATION OF LIKENESS (Calif. Civ. Code §3344), against
5 Defendants Saybrook, TCS, Nathan Long and Does 1 through and
6 including 100
7 60. Plaintiff incorporates by this reference each and every
8 allegation appearing in paragraphs 55, though and including 59 as
9 if set forth in full at this point.
10 61. On or about August 14, 2019 Defendants and each of them
11 knowingly appropriated Plaintiff's likeness in an advertisement
12 disseminated by social media and email for commercial purposes for
13 selling Saybrook's program of Residential Conferences and course
14 study of Humanistic Psychology and in connection with that
15 likeness represented that potential students would be able to meet
16 with (indeed, dance with) Plaintiff as one of the leading teachers
17 of Humanistic Psychology as faculty.
18 62. Plaintiff has been specially damaged in the amount of three
19 hundred thousand dollars ($300,000).
20 63. Plaintiff has suffered additional severe and enduring
21 emotional distress and caused him to be hospitalized for an
22 extended period of time and will continue to case him extreme and
23 enduring emotional distress all to Plaintiff's general damages in
24 the amount of ten million dollars ($10,000,000.) as Defendants
25 profits for the use of his likeness and representing him as
19 1 faculty,
2 64. Plaintiff is entitled to his reasonable attorney fees
3 pursuant to Calif. Civ. Code. §3344(a).
4 NINTH CAUSE OF ACTION
5 UNFAIR COMPETIOTN (Calif. Bus. & Prof Code. §17200), against
6 Defendants Saybrook, TCS, Nathan Long and Does 1 through and
7 including 100
8 65. Plaintiff incorporates by this reference each and every
9 allegation appearing in paragraphs 60, though and including 64 as
10 if set forth in full at this point.
11 66. At all times material and mentioned herein TCS and Does 1
12 though 100 failed and refused to comply with the provisions of
13 Calif. Govt. Code §§ 12582.1, et seq. and Defendants and each of them
14 failed and refused to comply with, disregarded and violated Calif. Govt.
15 Code§ 12599.6.
16 67. Defendants and each of them have engaged in a practice of
17 removing, terminating and replacing older and experienced
18 professors and instructors with younger persons with little or no
19 experience in the subjects that they were assigned to teach.
20 68. Defendants and each of them have engaged in a practice of
21 increasing the number of courses that teachers and instructors are
22 required to engage in.
23 69. Defendants and each of them have engaged in a practice of
24 ceasing to offer courses and/or departments that had been
25 developed through great effort to the detriment of students who
20 1 §had been attracted to Saybrook expressly for those courses and/or
2 departments.
3 70. Defendants and each of them have engaged in a practice of
4 diverting and draining student tuition and revenue to the benefit
5 of TCS and Does 1 through 100 and to otherwise.
6 71. Defendants and each of them have engaged in a practice of
7 advertising and engaging students and potential students through
8 false and deceptive practices.
9 72. The acts and omissions of Defendants and each of them are in
10 violation of Calif. Bus. &. Prof. Code. § 17200 in that they are
11 false, deceptive and unfair and in violation of Calif. Bus. &.
12 Prof. Code. § 17500.
13 73. Plaintiff brings this action on his own behalf and on behalf
14 of the general public and therefore it is appropriate for the
-15 Court to enjoin Defendants and each of them from further
16 conducting business in the State of California without compliance
17 the Government code as specified, as qualified to business in the
18 State of California and to cease and desist from the false, untrue
19 and unfair statements and conducts engaged in and to appoint a
20 receiver over the assets of Defendants and each of them to ensure
21 that said Defendants make restitution to Plaintiff and others
22 including past students for the sums acquired by Defendants and
23 each of them by such unfair business practices all pursuant to
24 Calif. Bus. &. Prof. Code. § 17203.
25 74. Plaintiff is entitled to his reasonable attorney fees
21 1 pursuant to Calif. Code. Of Civil. Proc. § 1021.5.
2
3 WHEREFORE, Plaintiff prays judgment against Defendant and
4 each of them Jointly and Severally as follows:
5 1. General damages for breach of contract in the amount of ten
6 million dollars together with interest thereon at the legal rate.
7 2. Special damages for breach of contract in the amount of two
8 hundred thousand dollars together with interest thereon at the
9 legal rate.
10 3. For Defendants and each of them to account to Plaintiff for
11 all sums by which they have been unjustly enriched and that
12 Plaintiff have judgment upon such sums against Defendants and each
13 of them jointly and severally.
14 4. For Judgment in the amount found to be wages, severance and
15 sabbatical wages due and for waiting period damages.
16 5. For general damages for wrongful termination for unlawful
17 discrimination in the amount of ten million dollars against
18 Defendants and each of them jointly and severally.
19 6. For special damages for emotional distress wrongful
20 termination for unlawful discrimination in the amount of ten
21 million dollars against Defendants and each of them jointly and
22 severally.
23 7. For general damages for wrongful termination for violation of
24 public policy in the amount of ten million dollars against
25 Defendants and each of them jointly and severally.
22 1 8. For special damages for emotional distress or wrongful
2 termination for violation of public policy in the amount of ten
3 million dollars against Defendants and each of them jointly and
4 severally.
5 9. For special damages for wrongful termination for violation of
6 common law copyright in the amount of ten million dollars against
7 Defendants and each of them jointly and severally.
8 10. For general damages for interference with prospective
9 advantage in the amount of ten million dollars against Defendants
10 and each of them jointly and severally.
11 11. For general damages for conversion in the amount of fifty
12 thousand dollars against Defendants and each of them jointly and
13 severally.
14 12. For special damages for invasion of privacy and holding
15 Plaintiff in a false light in the amount of five hundred thousand
16 dollars against Defendants and each of them jointly and severally.
17 13. For special damages for appropriation of Plaintiff's likeness
18 in the amount of one million damages against Defendants and each
19 of them jointly and severally.
20 14. For general damages for invasion of privacy and holding
21 Plaintiff in a false light in the amount of ten million dollars
22 against Defendants and each of them jointly and severally.
23 15. That the Court enjoin Defendants and each of them from
24 further conducting business in the State of California without
25 compliance the Government code as specified, as qualified to
23 1 business in the State of California and to cease and desist from
2 the false, untrue and unfair statements and conducts engaged in
3 and to appoint a receiver over the assets of Defendants and each
4 of them to ensure that said Defendants make restitution to
5 Plaintiff and others including past students for the sums acquired
6 by Defendants and each of them by such unfair business practices.
7 16. For Plaintiff's reasonable attorney fees.
8 17. For Costs of Suit.
9 18. For such other and further relief as the Court deems proper.
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24 VERil'ICATION 1 2 I, Stanley Krippner, declare: 3 I am the Plaintiff in the above-entitled action. I have 4 read the forgoing Complaint and know the contents thereof. The 5 same are true of my own personal knowledge except as to those 6 matters stated on information and believe and as to those matters, 7 I believe them to be true. 8 I declare under the penalty of perjury of the laws of the 9 State of California that the foregoing is true and correct and that 10 this Verification was executed on· 9/13/2019 at San Rafael, 11 California. 12
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25 26 r, 28 CURRICULUMVITAE STANLEYKRIPPNER SanRafael, California, USA email:[email protected] Education NorthwesternUniversity, Evanston, IL, M.A., 1957; Ph.D., 1961. UniversityofW1SCOnsin, Madison, WI, B.S., 1954.
Employment SaybrookUniversity, San Francisco/Oakland, CA; Professorof Psychology, 1972-2019. MaimonidesMedical Center, Brooklyn, NY; Director,Dream Laboratory, 1964-1972. KentState University, Kent, OH; Director,Child Study Center, 1961-1964.. RichmondPublic Schools, Richmond, VA; speechtherapist, 1955-19S6, 1960. Cornrn1�Public Schools, Warren, IL; speechtherapist, 1954-1955. Publieations Author:
HumanPossibilities: Mind Research in theUSSR andEastern Europe. Garden City, NY: Anchor1980. Books, Songof the Siren: ..4 Parapsychologlcal Odyssey. New York: HarperRow, & 1976. Shamlet:The Traglcall Hlstorle ofHamlet, Princeof Denmark.New York:Exposition Press, 1-971. Co-Author: Sexand Love In the 2111 Century:An Introductionto Sexologyfor YoungPeople (withJennifer Djas).Austin, TX: SentiaPublications, 2017. The Voice ofRollllig Thunder: A MedicineMan's Wisdom for Walkingthe Red Road(with Sidi8JlM:oming Star Jones). Rochester, VT: Bear/Inner Traditions, 2012. Post-TraumaticStress Disorder (Biographies of Disease)(with Daniel Pitchford and Jeannine Davies).Santa Barbara, CA: ABC-CLIO/Greenwood,2012. DemystifyingShamans Their and World:An Interdisciplinary Study (with Adam Rock). Charlotteville,VA: Imprint Academic, 2011. HauntedBy Combat: UnderstandingPTSD in War Veteran[updated edition](with Daryl S. Paulson).umbarn, MD: Rowman & Littlefield, 2010.
EXHIBIT"A" PersonalMythology: UsingRitual, Dreams, andImagination to Discover YourInner Story,3rd ed.(with David Feinstein). Santa Rosa, CA: EnergyPsychology Press/Elite Books, 2008. HauntedBy Combat: UnderstandingPTSD in WarVeterans Including Women, Reservists, and 'I'hoaeComing Backfrom Iraq (with Daryl S. Paulson).Westport, CT: Praeger, 2007. TheMythic Path, 3rd ed. (with David Feinstein). SantaRosa, CA: EliteBooks, 2006. Becoming Psychic:Spiritual Lessons for FocusingYour Hidden Abilities (with Stephen Kierulft).Franklin Lakes, NJ: CareerPress, 2004.
DreamTelepathy: &periments in Nocturnal i:SP, 3rd ed.(with Montague Ullman and Alan Vaughan).Charlottesville, VA: HamptonRoads, 2002.
ExtraordinaryDreams and How to Work with Them{with Fariba Bogzaran and Andre Percia de Carvalho).Albany, NY: StateUniversity ofNew York Press,2002. SonhosExoticos: Como Utillzaro Slgnlftcadodos SeusSonhos ( withAndre Percia de Carvalho). SaoPaulo, Brazil: Summus Editorial, 1998.
TheMythic Path (with David Feinstein); 2nd ed. of Personal Mythology.New York:Jeremy P. Tarcher/Putnam, 1997.
A Psychiatristin Paradise: TreatingMental Rlness in Bali(with Denny Thong and Bruce Carpenter).Bangkok, Thailand: White Lotus Press, 1993. SpiritualDimensions of Healing: From TribalShamanism to ContemporaryHealth Care (with PatrickWelch). New York:Irvington Publishers, 1992.
!)reamTelepathy: Experiments in NocturnalESP, 2nd ed. (withMontague Ullman and Alan Vaughan).Jefferson, NC: McFarlandPublishers, 1989. PersonQJMythology: The Psychology of Your Evolving Self(with David Feinstein). Los Angeles: JeremyP. Tarcher, 1988. Dreamworlclng:How to Use YourDreams for CreativeProblem-Solving (with Joseph Dillard). Buffalo,NY: Bearly Ltd., 1988. ,ZwlschenHimmel und Erde: Spiriluelles Heilen der Schamanen, Hexen, Priester undMedien (withPatrick Scott). Dussilgen, Germany: Chiron Verlag, 1987. HealingStates (with Alberto Villoldo). New York:Fireside Books/Simon & Schuster, 1987. LaScience et le1Pouvoirs Psychiques de l'Homme (with Jerry Sol fvin).Paris: San� 1986. •
TheRealms of Healing (with Alberto Villoldo). Millbrae,CA: CelestialArts Pres.1, 1976; rev. ed.,1977; 3rded., 1986. DreamTelepathy: Experiments in NocturnalESP (with Montague Ullman and Alan Vaughan). NewYork: Macmillan, 1974. Editor:
Dreamlimeand Dreamwork: Decoding the Languageof the Night. LosAngeles: Jeremy P. Tarcher,1990.
Advancesin ParapsychologicalResearch, Vols. 4, S, 6, 7, 8. Jefferson,NC: McFarland Publishing,1984, 1987, 1990, 1994,1997.
Advances inParapsychological Research, Vols. 1, 2, 3. New York: Plenum Press, 1977, 1978, 1982.
PsychoenergeticSystems: TheInterface of Consciousness, Energyand Matter. New York: Gordon& Breach, 1979. Co-Editor:
1'heShamanic Powers ofRolling Thunder (with Sidian Morning Star Jones). Rochester,VT: Bear& Company,2016.
Wor/clngwith Dreams and PTSD Nightmares: 14 Approachesfor Psychotherapists and Counselors(with Jacquie E. Lewis).Santa Barbara, CA: Praeger,2016. Varietiesof A.no,nalous Experience: Examining the ScientificEvidence, 2-'ed (withEu.el Cardeftaand Steven J. Lynn).Washington, DC: AmericanPsychological Association, 2014. Advancesin parapsychological research, 9 (withA Rocle,J. Beischel, H.L.Friedman, and C.L. Fracasso).Jefferson, NC: McFarland,2013.
DebatingPsychic &perience: Human Potential or HumanRluslon? (with Harris L. Friedman). Santa.Barbara,CA: Praeger, 2010.
MysteriousMinds: TheNeurobiology of Psychics, Mediums, andOther Extraordinary People (withHarris L. Friedman).Santa Barbara, CA: Praeger,2010.
Perclumceto Dream: TheFrontiers of Dream Psychology (with Debbie JoffeEllis). New York: NovaScience 2009. HealingTales: ThsNarrative Arts in SpiritualTraditions (with Michael Bova, Leslie Gray, and AdamKay).Charlottesville, VA: Puente,2007. •
HealingStories: The Use ofNarrative in Counselingand Psychotherapy (with Michael Bova andLeslie Gray). Charlottesville, VA: Puente,2007. ThePsychological Impact o/War Traumaon Civilians:An InternationalPerspective (with TeresaM. McIntyre). Westport, CT: Praeger, 2003.
Yarletiesof Anomalous &perience: Examining the Scientific Evidence (with Etzel Cardena and StevenJ. Lynn).Washington, DC: AmericanPsychological Association, 2000.
Mythology, Medicine, andHealing: TransculturalPerspectives. Yearbookof Cross-Cultural Medicineand Psychotherapy, 1998-1999(with Holger Kalweit).Berlin: Verlag fur Wissenchaft undBildunlt 2000. Dreamscaplng:New and Creative Ways to Work with YourDreams (with Mark Waldman). Los Angeles:Lowell House, 1999. BrokenImages, Bro/amSelves: Dissociative Narratives in Clinical Practice (withSusan Powers).New York:Brunner/Mazel, 1997.
futureScience: Life Energies andthe Physicsof Paranormal Phenomena (with John White). GardenCity, NY: Anchor Books, 1977.
77,eEnergies of Consciousness: Explorations in Acupuncture, Auras, andKirlian Photography (withDaniel Rubin). New York: Gordon& Breach,1975. 11,eKirlianAura: Photographing the Galaxies ofLife (with Daniel Rubin). Garden City, NY: AnchorBooks, 1974. Galaxiesof Life: TheHuman Aura in Acupuncture and Kirlian Photography (with Daniel Rubin).Gordon & Breach,1973. Authoror co-authorof over1,000 articles, chapters, and bookreviews appearing in scholarlyor ar-ademicpublications. Bonon Awards: TheLifetime Achievement Award, International on Network PersonalMeaning, Vancouver, Canada,'2014. Human Award,Treasure The Society forClinical and Experimental Hypnosis, 2013. Awardfor Distinguished Lifetime Contributions to HumanisticPsychology, American PsychologicalAssociation (Division 32), 2013. •
IntegrativeAchievement Award, The Center for IntegrativePsychology, San Diego, California, 2013. ProfessionalJourney Consciousness in Award, International Congress on Scienceand Spiritualiey,Puebla, Mexico� 2013. TheCharles Honorton Integrative Contn"bution Award, Parapsychological Association, 2011. HonoraryPresident, Center for Hmnanisticand Transpersonal Studies, Guangzhou, China, 2010. AdvancedAlcohol and Other Drug Abuse Counselor, International Certification and Reciprocity Consortiumfor Alcoholand Other Drug Abuse, and the Mexican Certification Board for Profeaionalson Addictions,Alcoho� and Tobacco, 2010. TheRuth-Inge Heinze Memorial Lecture Award (first recipient), 25th Annual Shamanism Conference,The Santa Sabina Retreat Center at DominicanUniversity, San Rafael, California, · 2008. TheWays oflCn.Qwing Award: Exploring Culturally Based HealingTraditions and Practices, LifeScience Foundation and the University of MinneapolisCenter for Spiritualityand Healing, · 2008. Certificateof Recognitionfor Longstanding Contributions for theLast Ten Yearsto the Developmentof MentalHealth and Educational Programs in Mexico, PoliplamMedica Center, CiudadJuarez, Mexico, 2008. Junta,MexicanaCertificadora Para Profesionales en Addiciones, Alcoholismo,& Tabaco[Mexican Certificate Program in Addicition,Alcoholism, and Tobacco for Professionals],from the International President of EducationalPrograms, Ciudad Juarez, Mexico,2008. TheWoodfish Prize (co-recipient), "for the joint creation of a NativeAmerican/Euro-American socialproject," San Francisco, California, 2007. LifetimeAchievement Award, International Association for theStudy of Dreams, 2006. TheExcellence Award, from Excellence The Awards Institute, Barcelona, Spain, 200S. HonoraryMember, Chcle of theFoundation for Shamanic Studies, Mill Valley, CA, 2005.
QuincelltennialMedal, Masonic Lodges of EasternBrazil, 11 for promulgatingthe appreciation of B,aziJiauculture," Recife, Brazil, 200S. HonoraryMember, Centro de EstudiosOnfricos de Chile,Santiago, Chile, 2004. TheAshley Montagu Peace Award (g iven on behalfof CommonBond Institute, Harmony Institute,the Association for HumanisticPsychology, and the Annual International Conference on ConflictResolution), St Petersburg,Russia, 2003. Awardfor DistinguishedContributions to ProfessionalHypnosis, AmericanPsychological Association- Division30 (PsychologicalHypnosis), 2002. Awardfor Distinguished Contributions to the International Advancement of Psychology, AmericanPsychological Association, 2002. TheDr. J.B. RhineAward for Life-Tune Achievement in Parapsychology,Andhra University, Prof.K. Ramakrishna Rao Endowment, Visakbapatnem, India, 2002. TheSenior Contnoutor Award, American Psychological Association - Division 17 (Co,mseHng Psychology),2000. HonoraryAssociate, The B1'8Zi1ian Federation of Umbandaand Candombl6, Brasilia, Brazil, 1999. TheContnoution to Latin American Parapsychology Award, Association for Ibero-American Parapsychology, 1998. TheOutstanding Career A ward, Parapsychological Association, 1998. ThePathfinder Award, Association for Humanistic Psychology, 1998. Member,The Council of Sages,California Institute of IntegralStudies, San Francisco, CA, 1998.
HonoraryMember, Fundacion Latinoamericana de Parapsicologiay Psicotonica,Bogota, Col�1994. TheDan Overlade Memorial Award, Center for Treatment and Research of Experiencesin AnomalousTrauma, Hastings-on-Hudson, NY, 1994. TheCharlotte and Karl Buhler Award, American Psychological Association - Division 32 (BnrnanisticPsychology), 1992. HonoraryMember, Pemambuco Institute of PsychobiophysicalResearch, Recife, Pemambuco, Brazil, 1990. Doctorof Science(honorary), The Open lntemational University, Colombo, SriLanka, 1989. Associate,Center for a Post-ModemWorld, Santa Barbara, CA, 1987. Recipient,Bicentennial Medal, University of Georgia,Athens, GA, 198S.
Diploma,Ministerio de Educacion, Instituto de Investigaciones Psicologicas y Parapsicologicas, Quito,Ecuador, 1984.
Doctorof HmuaueLetters (honorary), University of Humanistic Studies, SanDiego, CA, 1982.
MembershipService Award, National Association for GiftedChil� 1981.
Colleague,Creative Problem-Solving Institute, Buffalo, NY, 1980.
TheVolker Medal, South A:&ican Society for PsychicalResearch, Johannesburg, South Africa, 1980.
DoctorHonoris Causa Parapsycologia, en Instituto de Ciencias Parapsycologicas Hispano Americana,Granada, Spain, 1977.
Certificateof Recognition,Office of theGifted and Talented, U.S. Departmentof Healthand HumanServices, 1976.
Citationof Merit,National Association for CreativeChildren and Adults,1974.
Citationof Merit,National Association for GiftedChildren, 1972.
TheService to Youth Award, Young Men's Christian Association, Richmond, VA, 1959.
Distinguished Professor:
Califomialnstituteof IntegralStudies, SanFrancisco, CA, AssociatedDistinguished Professor, Integraland Transpersonal Psychology.
Institutode MedicinaTecnologia y Avauzada de la Conducts,Ciudad Juarez, Mexico, Coordinatordel Programa.
CaliforniaInstitute of HumanScience, Encinitas,CA, Distinguished Adjunct Professor.
InstituteResearch for in Biopsychophysics, Dr. Be7.eml de Menezes IntegralCenter for Higher Education,Curitl1' Parana, Brazil, Pro fessorBenemerito.
VisitingProfessor:
ColoradoSchool Professional of Psychology, Colorado Springs, 2006 (DistinguishedVisiting . Professor).
Institutefor Medicineand Advanced Behavioral Technology t CiudadJuarez, Mexico, 2000- present. Departmentof Psychology,John F. KennedyUniversity, Orinda, CA, 1980-1982.
Departmentof Psychology,State University of West Georgia,Carrollton, GA, 1976.
Institutefor Psychodrama and Psychotherapy, Caracas, Venezuela, 1975.
Collegeof Life Sciences,Bogota, Colombia, 1973.
Departmentof Psychology,Sonoma State University, Rohnert Park, CA, 1972-1973.
Departmentof Psychology,University of PuertoRico, San Juan, PR, 1972.
AdjunetProfessor (past or present)
BrooklynCollege. Brooklyn, NY; Center for Psychological Studiesand Services, Visakhapatnam,India; Fordham University, New York;New York University,New York; OntarioCurriculum Institute, Toronto; Rosary Hill College, Buffalo,NY; St. John'sUniversity of StatenIsland, NY; University of CalifomiBtIrvine, Los Angeles,and San Francisco, CA; WagnerCollege, Staten Island, NY; YeshivaUniversity, New York.
Leeturer:
Departmentof Psychology,Minais Gerais University, Belo Horizonte,Brazil, 1986-1987.
Academyof Sciences, Beijing, China, 1981.
Academy of PedagogicalSciences, Moscow, Russia, 1971.
Diplomate:
AmericanBoard of Sexology.
InternationalAcademy of BehavioralMedicine, Counseling, and Psychotherapy.
Certifieate:
AdVinCedAlcohol and Drug Counselor, number 704610
Fellow:
AmericanAcademy of ClinicalSexologists, Founding Fellow andClinical Fellow.
AmericanAssociation of Appliedand Preventive Psychotherapy, Fellow.
AmericanEducational Research Association, Fellow.
AmericanPsychological Association, Fellow of Divisions: 30 (Societyfor Psychological "'!' •
Hypnosis),32 (}lummistic,Psychology), 36 (Psychologyof Religion),48 (PeacePsychology), andS2 (InternationalPsychology).
Associstio11for PsychologicalScience, Charter Fellow.
AmericanSociety of ClinicalH �nosis, Fellow.
Societyfor the Scientific Study of Religion,Fellow.
Society for theScientific Study of Sexuality,Fellow.
Societyof Clinicaland Bxperimental Hypnosis, Fellow.
WesternPsychological Association, Fellow.
MedicinaAlternativa Institute, Colombo,Sri Lanka, Fellow.
Memberand U.tipp Member: Acadeinyof Spirituality and Paranormal Studies; American Anthropological Association; AmericanAssociation for theAdvancement of Science;American Association for theStudy of MentalImageey; American Counseling Association; American Creativity Association (Charter Member);American Educational Research Association; American Psychological Association (CouncilMember, 1978-1980; President,Division 32, 1980-1981;President, Division 30, 1997- 1998, Memberof Divisions 17, 30, 32, 36, 48, 52); AmericanSociety for PsychicalResearch (Trustee, 1987-1997);American Society of ClinicalHypnosis; Association forApplied _ Psychophysiologyand Biofeedback; Association for Humanistic Psychology (President,1974- 1975);Association for PsychologicalScience; Association for theScientific Study of Consciousness;Association for Transpersonal Psychology; Brazilian Association of theScientific Study of Consciousness; Centerfor Shamanic Studies; Centro de EstudiosOnfricos deChile (Honorary Member); Committee for SkepticalInquiry (Associate Member); Councilfor ExceptionalChildren; General Evolution Research Group; Healing Council of theInternational Societyfor the Study of SubtleEnergies and Energy Medicine; Institute for the Advancement of Health;Interamerican Psychological Association; International Alliance for Leaming; InternationalAssociation for theStudy of Dreams(President, 1993-1 994); InternationalCouncil ofPsychologists; International Society for GeneralSemantics; International Society for Hypnosis;Int.emational Society for Shamanistic Research; International Society for theStudy of Dissociation(Charter Member); International Society of Transcendentology(Founding Member);International S�iety for SystemsScience; International Union of Anthropologicaland BthnologicalSciences; Medicina Altemativa (Life M ember);Joseph Campbell Foundation (Fonodi:ngWember); National Association for GiftedChildren (Vice President, 1976-1977); ParapsychologicalAssociation (President, 1982); Psychologistsfor Social RespoDS1oility; Sleep ResearchSociety; Societyfor theAnthropology of Consciousness; Societyfor ChaosTheory in Psychologyand the Neural, Hwmm, and Social Sciences; Societyfor Clinicaland Experimental •
Hypnosis;Society for ConsciousnessStudies (Founding Member); Society for the MultidisciplinaryStudy of Consciousness;Society for PsychicalResearch; Society for Scientific Exploration;Society for the Scientific Study of Religion; Societyfor the Scientific Study of Sexuality;Society for ShamanicPractitioners; SwedishSociety for Clinical and Experimental Hypnosis;Western Psychological Association; World Future Society; World Health Foundation forPeace. Member,Board of Direetors,Advisory Board, or AdvisoryCommittee:
AlbertHofmann Foundation, Los Angeles; AmericanBoard of SportPsychology, New York; Alvarado/ZingroneInstitute for Research and Education (AZIRE), Charlottesville, VA; AmericanCenter for theIntegration of SpirituallyTransformative Experiences, San Diego, CA; TheBeckley Foundation, Oxford, England; Center for Spiritual Healing, Fairfax, CA; Centerfor theStudy of EmpathicTherapy, Ithaca, NY; Committeefor the Study of AnomalisticResearch, Ypsilanti,Ml; The Darwin Project, Pacific Grove, CA; Existential-BnmanisticInstitute, San Francisco;Foundation for IntegrativeAIDS Research,New York; Foundationfor Mind Research,Pomona, NY; Friends of theCzech Unitaria, New Yorkand Prague; Fundacion Internacionalpara la lnvestigacion de la Naturalezadel Hombre(Presidente, Division Internacional),Ciudad Juarez, Mexico; Global Leadership Academy; Institute for Authentic ProcessHNJing, New York; Institute for DreamStudies (South Plam Court, SC); Institutefor TransformativeMedicine, West Palm Beach, FL; Instituteof AppliedConsciousness Science, Wtlderville,OR; InstitutoInternacional de SexualidadHumana (Consejo Directivo ), Ciudad Juarez,Mexico; International Institute for Survival Studies, Pembroke Pines, FL;International Schoolfor Psychotherapy, Counseling, and Group Leadership, St. Petersburg;International Societyfor theStudy of Ghostsand Apparitions; The Joseph Plan Foundation, Los Angeles; MindVi� Baligalore,India; Peace University of Potsdam,Germany; Portals of Wonder,New York;Rhine Research Center, Durham, NC; Rhythmfor Life,Tempe, AZ; Rivka Bertisch Foundation,New York and Buenos Aires; Rollo May Centerfor HumanisticStudies, San Francisco;Transpersonal University, Puebla and Veracruz, Mexico; The Soul Rider Fund, San Francisco,CA; University of theUniverse, Mt Shasta,CA; Wasiwaska Research Center for the Studyof PsychointegratorPlants, Visionary Art, and Consciousness, Florianopolis, Brazil Member,Editorial or AdvisoryBoard:
Alternative Therapiesin Health and Medicine; AmericanJournal of Clinical Hypnosis-, .Anthropologyof Consciousness; TheBehavioral and Brain Sciences; DreamNetwork Journal; Dreaming:Journal of the InternationalAssociation for theStudy of Dreams;Entheos: Journal of PsychedelicSpirituality; International Journal for Counseling, Psychology, Psychiatryand Psychotherapy;Journal of the AmericanBoard of Sport Psychology,· Journal ofHumanistic Psychology;Journal of Indian Psychology, Journal of International Society of LifeInformation Science,·Journal of Mental Imagery;Journal of Mlndbody States,· Journalof Mind and Behavior,Journal of Psychoactive Drugs; Journal ()/Shamanic Practice: ExploringTraditional andContemporary Shamanism; Journal of Trans-Human Consciousness;Journal of 7'ranspersonalPsychology; Journal of UnifiedPsychotherapy and Clinical Science; Paranmmal,·Psychology of Consciousness,· Re Vision,· RevistaArgentina de Psicologi, Science andConsciousness; TheHumanistic Psychologist; World Futures: 11,eJournal of New ParadigmResearch.
Listings:
AmericanMen and Women ofScience; Cambridge Who's Whoamong Executives, Professionals andEntrepreneurs; Encyclopedia of Parapsychology and Psychical Research; International Who�Who of Intellectuals; Leaders in AmericanScience; OutstandingTeachers in Exceptional Education; Who�Who In America; Who's Whoin the BlobehavioralSciences; Who's Whoin the West; Who's Who in FrontierSciences and Technology; Who's Whoamong Human Service Professionalr, Who's Whoin Medicine and Healthcare; Who's Whoin Scienceand Engineering; Who's Whoin theWorld. , . a
SAYBROOKUNNERSllY
FACULTYAPPOINTMENT CONTRACT
Saybrook University ("Employer")and Stanley Krippner ("Faculty'') each hereby agree to the terms and conditionsof appointment establishedby this FacultyAppointment Contract ("Contract").
1. APPOINTMENTTERM
Employer herebyappoints Stanley Krlppner as Facultyto Saybrook University, upon the terms and conditions of this Contractfor a period commencing on 06/01/2018 through 05/31/2019. Furthermore, the Faculty member and University agree to an appointment at a . 75 Full-Time Equivalency(75%) (30 hours per week). The Faculty member, her or his Dean and Department Chair shall determinethe appropriate workloadfor each academicterm throughout the year. Furthermore,the terms of theappointment will be reviewed by the Provost and ChiefAcademic Officerto ensure alignment withbudgetary, curricular and programmatic needs.
FACULTYENGAGEMENT: • Facultyare expected to log onto their online courseat least three (3) times per week and provide substantivecontributions and respond to studentposts. • Saybrook Facultyare expectedto respondto studentsby using their Saybrook email address, Canvaslnbox, or by phone within two (2) businessdays no matter where they are located. • In addition to scheduled studentappointments, Faculty are expected to post and provide sixty minute (60) drop-in officehours via GTM twice a month. Theseare to be offered outside of normal 9-5 business hoursas this is criticalfor working, adult students.
Membersof the Facultyare expectedto abide byall currentand future polldesand procedures of this document as well as College supplemental documents,and the Saybrook Faculty/Staff handbook and Saybrook FacultyHandbook. We ask that all Saybrook employees who are benefit eligible regardSaybrook University as their primaryemployment and professional identification. Thisincludes listing Saybrook as their primaryaffiliation on all presentations, publications, flyers, and other public appearances. Facultywho are benefit eligible must also complet�the Outside Employment Notification Form (Appendix A) which will be sent to you by a separate email.
Financialsupport for Professional Development will be available based on the yearly budget and performance. Revised4-12-2018
EXHIBIT"B" FacultyAvailability: Faculty members are active participants in their scholarly and professional worlds. This can necessitate absencesfrom theiroffices duringthe academic term. It is also expectedthat Faculty will notifytheir students in advance of such absencesso studentsmay anticipate any impact this might have on their plans to submit work and meet deadlines. Faculty members are activeand continuously engaged In teaching and advising studentsduring the Residential Conferences.
FacultyTime Offis to be negotiated between the Faculty member, the Department Chair and the Dean.
Note: Due to enrollments,budgetary considerations, and other institutional needs, workload assignmentsmay need tobe adjusted, including but not limited to additionalcourse assignments, serviceactivities, and conferenceattendance, if necessary/applicable.
·2. COMPENSATION
Employer will pay Faculty, by way of remuneration forsuch services, an annualized salaryof $61,875 or an approximate bl- weekly pay rate of $2,379.81, less all legal deductions unless this Contractis terminated or revised during the term of this appointment.
3. DUTIES
The duties and responsibilities of Facultyshall be those described in the Job Description found attachedto thiscontract.
4. BENEFITS
Except as otherwise expresslystated In this Contract, Faculty shall be entitled to all privileges, benefits,and policies as set forthby the University'sSole Member- TCS ES - and the Faculty Handbook of Saybrook University, in effect at the inception of this Contractor as it may be revised fromtime to time during the term of this Contract.
5. TERMINATION
All employees of Saybrook University are at-will. Nevertheless,the Universitywill seek to ensure that in most cases, termination of this Contract coincides with the term of this appointment.
Earlytermination by the Employer prior to that endpoint may occur due to failureby Facultyto meet performanceexpectations or financial exigency. It is expectedthat other than circumstances relatedto financial exigencyor termination forcause, the EMPLOYER will provide the Faculty member Witha minimum of eight (8) weeks' notice, unless the extenuating life altering event dictatesotherwise.
Termination by the Faculty prior to that endpoint may occur due to extenuating life altering events, such as butnot limited to illness, transfer of a spouse/partner. It is expectedthat in cases of
Revised4-12-2018 ' 0 extenuatinglife altering event, Facultywill provide the Employer with a minimum of eight (8) weeks notice, unless the extenuating life altering event dictates otherwise.
6. WAIVER OR MODIFICATIONINEFFEcrtVE UNLESS IN WRITING
It Is furtheragreed that no waiver or modification of this Contractshall be valid unless in writing and agreed to by both parties.
7. ENTIREAGREEMENT
This contractand Appendix A constitute the entire Employment Agreementbetween the parties and shall be governed by californialaw.
8. NOTICES
Any and all noticesrequired or permittedto be given under this Contractwill be sufficientif furnishedin writing, sent by certified mail, return receipt requested, to his/her lastknown residence in case of Faculty, or to itsprinciple office in the caseof the Employer.
9. SEVERABIUTY
Should any portionof this Contractfor any reason be deemed _to void or unenforceable, such provision shall be deemed to be severed from this Contract, and the remaining portionsof this Contractshall remain in fullforce and effect.
EXECUTEDat Oakland, Californiathis 18th day of April, 2018
Signing-this appointment Contract alongwith the completion of Appendix A, indicates your commitment to and approvalof this Contractand job description.
Revised4-12-2018 Salaried Faculty
Under thedirection of theDeparbnent Chair, the facultymember will engage studentsthrough discussion and assignments as outlinedin the course syllabi, provides students with substantive feedback,and responds to student questionsand concernsin a timelymanner. The instructor will also maintain communicationwith department administration, faculty, and students.
• Responsiveand timelycommunication with Department Chair Position• Newresponsibilities Student Orientation include, and but Residential/Educationalare not limited to: Conferences o Supporton-boarding of new students o Presentcourses, workshops and/or course introductions o Attend meetings (Faculty, Program, College, University) and Facultytrainings which could Include Canvas, IRB, student record system, etc. • Mentoring Students o Actively supportthe socialization ofstudents into the programand profession o Monitorstudent recruibnent. retention and mabiculation • Instruction, Course Development and Syllabus Review/Updating o Deliverhigh qualityInnovative campusand/or on-line coursesthat foster critical thinking o Ensure rigorousacademic standardsand qualityaligned with programgoals o Coordinatecourse offerings and catalog documentation o Design dynamiccourses utilizing the latest developments and trends in classroominstruction and digitaltechnology • Governance o Activelyparticipate In degree and departmental meetings o Representprogram on university-widecommittees as warranted o Participate In the accreditationand, when appropriate, budget process a Contributeto strategic planning and programmaticgrowth o Maintain effectiveprofessional and communityinvolvement and/or affiliations as ambassadorfor the university
AllFacultyfaculty Engagement members at Saybrook Universityare expectedto be available and responsive to students. Faculty engagement expectationsinclude:
• Facultywill respondto emails, Canvas lnbox, and phone callsand acknowledge receivedassignments within two (2) businessdays. • In additiQllto scheduled student appointments, facultyare expectedto post noticeof and providesixty (60) minute drop-In officehours via GTM twicea month. These areto be offered outsideof normal 9-5 businesshours as thisis criticalfor working adult students.
Revised 4-12-2018 • For Individually mentored courses, facultywill schedule with each student regular online and off-linecommunication. • Fawltywill beable to demonstrate how they are engaging students in a consistent and meaningfulway acrossthe semester or term. • Facultywill returnstudent papers withfeedback for course assignments submitted throughCanvas withinthe followlng guidelines (applicable to coursepapers, candidacy essays, MAtheses/projects , and dissertations): • 1 week for workless than 5 pages in length, • 2 weeksfor work up to25 pages in length, • 3 weeksfor work 26-50 pagesIn length (and forfinal thesis/project), • 4 weeksfor work over 50 pages in length (Including the dissertation).
Position Requirements: • Doctorate or field'stermlnal degree from regionally-accredited institution • Demonstrated scholarshipand/or accomplishments in thefield • Relevant supervision and teaching experience at the doctorallevel, including supervision of dissertation research • Commitmentto multicultural and humanisticprinciples • Experiencewith ethnically diverseand/or other specialpopulations • Some travelmay be required
Position Quallflcations: • Strongcommitment to the goals and vision of Saybrook University • Committedto excellencein teaching, practice, and research (experiences with on-line instruction Is desirable) • Able to offeron-line instruction regarding topicsand skills within his/herareas of expertise. • Creates a senseof unityand commonpurpose and manages change effectively • Abilityto build teams and effective workingrelationships • Promotesinterdisciplinary work within and beyond theDepartment
PersonalAttributes: • Criticalthinker • Thinks strategicaUyand works collaboratively • Affectivelyhonest and open, witha high level of personal integrity • Communicates effectively • Consultswith colleaguesat all levels • Well organized and able to meet complex workloaddemands • Strongcommitment to equity, diversity, and multiculturalismin education and faculty employment.
SaybrookUniversity is an Equal Opportunity Employer
Revised 4-12-2018 Saybrook Universityoffers a generous compensationand benefits package. Some of our key benefitsinclude: paid time-off, medical and dental coverage, company-paid life and disability insurance, retirement plan, and multiple flexiblespending accounts(FSA), Saybrook Universityis an Equal Opportunity Employer that celebrates diversityand inclusion.
About Saybrook University: Saybrook Universitywas founded over 40 yearsago by some of the greatest minds of the 20th centuryand continuesto inspirea new generationof innovators.A non-profit regionallyaccredited university known for itscommitment to humanistic studies and rigorous researcf\ Saybrook University's academic model puts the student at thecenter of everythingwe do toprovide a unique, transformational, learning experience. Saybrookoffers advanced degrees in ·organizationalsystems, psychology, mind-body medicine, and counseling, all in flexible learning fonnats to help students continue to be active contributorsto the fieldsthey work in' while they advance their education. Saybrook Universityis proud to be a diverse, inclusive community of creative, compassionate innovators dedicated to pursing new ways of thinking and doing for our professions, organizations, and communities.
For moreInformation, visit www.saybrook.edu. Your ele.ctronlcsignature on theFaculty Contract along with thecompletion of Appendix A lndlcatt!Syaur commitment to and approval of thisContract and job description.
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Revised4-12-2018 Stanley Krippner 2018-2019 Salaried Faculty Contract AdobeSign DocumentHistory 04/23/2018
Created: 04/1812018
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"Stanley Krippner 2018-2019 Salaried Faculty Contract" History e Documentcreated by Connie Shulman ([email protected]) 04/18/2018- 5:22:36PM PDT- lP address:40.133.239.114
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:r-;;:r_��:ff:·�.-�.:"'� T. •. �. �-: �-:-•. L._ ·�-� "\ - /4'�� STATEOf CAUfORNIAt Business consumerseryjces ang Ho11§ingAgency · • GAVIN NEWSOM GOVERNOR � DEPARTMENT OF FAIR EMPLOYMENT & HOUSING KEVIN KISH, DIRECTOR W.� t:l 2218 Kausen Drive, Suite 100 I Elk Grove I CA I 95758 ,lj�ili (BOO) 884-1684 (Voice) I (BOO) 700-2320 (TTY) I California's Relay Service at 711 ..,..� http://www.dfeh.ca.gov I Email: [email protected]
September 4, 2019
John Vodonick • California
RE: Notice to Complainant's Attorney DFEH Matter Number: 201909-07442804 Right to Sue: Krippner / Saybrook University et al.
Dear John Vodonick:
Attached is a copy of your complaint of discrimination filed with the Departmentof 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 must serve the complaint separately, to all named respondents. 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. A courtesy "Notice of Filing of Discrimination Complaint" is attached for your convenience.
Be advised that the DFEH does not review or edit the complaint form to ensure that it meets procedural or statutory requirements.
Sincerely,
Department of Fair Employment and Housing
EXHIBIT "C"