Plaintiff alleges that a specific teaching of Siri Yogi held that women were inferior to men, and must be submissive to men. Plaintiff was specifically indoctrinated with these teachings of "female submissiveness." Furthermore, Siri Yogi told plaintiff that her "personal, spiritual and psychological … problems were centered in her ovaries, and that they therefore must be cut… ."

The Complaint relates that "on or about the month of December, 1976, plaintiff was personally directed by Siri Yogi to have an operation called a laparoscopic tubal ligation," which she had performed. As a result of the procedure, plaintiff claims she was made irreversibly sterile.

The order given by Siri Yogi to have the operation was made during a thirty-day food fast, also ordered by Siri Yogi, which fast continued through the day of surgery…

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