The legal document for HHF Onionhead lawsuit

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a) Beginning in 2007, Defendants flew the founder and leader of Harnessing
Happiness / Onionhead—a woman who lived in Mount Shasta, California, and went by
the name “Denali”—to the New York worksite to conduct mandatory group meetings and
one-on-one sessions with employees regarding the Harnessing Happiness / Onionhead
belief system. Defendants would bring Denali to the New York worksite on at least a
monthly basis to conduct these meetings and sessions. But even when Denali was not in
New York, other managers would use her teachings to lead additional Harnessing
Happiness / Onionhead meetings.
b) When Defendants’ owner first brought Denali to the worksite, he introduced her
as the company’s “spiritual advisor.” Denali is the aunt of Defendants’ owner. She was
a member of upper management and had the power to hire, fire, and discipline
Defendants’ employees.
c) The materials associated with the Harnessing Happiness / Onionhead belief
system, which Defendants provided the employees and required them to use at work,
describe various religious tenets of the system:
i. “Upon entering the world, we are infused with the Universe’s unlimited potential
and intense joyful energy.”
ii. “When we become exposed to traumatic events, our soul goes into hiding and our
ego, which is connected to the dark side, takes over.”
iii. “Our souls are seekers. They strive for unity, scream for harmony and speak only of love.”

v. “When we access our higher wisdom and fill our life with love, we harness a
happiness that resonates to the blissful vibration of….as above – so below.”
[ellipsis in original]
v. “When we respond to our problems in the presence of our true spirituality, our
Divine Spark ignites, diminishing darkness.”
vi. “We declare our Divinity.”
vii. “We know we can part the sea and make one fish into five thousand.”
d) The materials associated with the Harnessing Happiness / Onionhead belief
system also contain religious symbols and iconography:
i. The materials contain imagery of a golden hummingbird. The golden
hummingbird is described as a “totem of happiness” that “carries a heart over the
fire in the cup because our true happiness is sparked from the radiant energy of
love.” The materials also describe “The Hummingbird’s A-Z Path to a Happy
Life,” which lists various rules for living.
ii. The materials contain imagery of the golden hummingbird carrying a heart in its
beak, as well as imagery of the golden hummingbird flying over a flaming, golden
chalice that is flanked by white wings.
iii. The materials also contain imagery of a golden dove, which the materials refer to
as “The Golden Dove.” The Golden Dove is described as being “designed with
sublime wisdom” and “a powerful totem which enables us to fly while in our
material world.” The materials also describe “The Golden Dove’s Flight Plan to
an Elevated Life,” which lists various rules for living.

On a regular basis, Defendants have required employees to participate in religious
practices under the Harnessing Happiness / Onionhead belief system.
a) Ontaneda, Pennisi, Pabon and other aggrieved individuals felt pressured and
coerced into participating in various religious practices at work and endured a hostile
work environment as a result.
b) On a regular basis, Defendants required employees to pray, hold hands in a prayer
circle, read spiritual texts, light candles, burn incense to remove bad energy, listen to
meditation music playing throughout the workplace, and use low lighting in their offices
because, according to Denali, demons came through the overhead lights.
c) On a daily basis, Defendants required employees to select a card from a stack of
“Universal Truths Cards,” to keep the card next to their computer monitors, and to
“contemplate the truth” of the message on the card throughout the day. The cards
covered topics such as Divinity, Destiny, Faith, Miracles, Sacredness, and Enlightenment.
d) According to the materials associated with these religious practices, the purpose
of the “Universal Truths Cards” was to “shed truths in order to reunite us with our
potential, power and purpose,” which would result in “signs of transmutation” that
signified “the awakening of our bliss because we become imbued with our original DNA
blueprint.” “The purpose of the Universal Truth Cards is to shed Light, in order to
reunite you with the ecstatic Universal Realm.”
e) On a daily basis, Defendants required employees to wear and display Onionheadrelated
pins on their person.
f) On a regular basis, Defendants’ managers sent employees work-related emails
and instant messages that included references to Onionhead-related religious tenets like “energetic force fields of spirit” and “universal consciousness joining with other sun
universes.”
g) On a routine basis, Defendants required employees to thank God for their
employment, and say “I love you” to colleagues and management.
h) On a weekly basis, Defendants required employees to take part in group staff
meetings where managers led discussions of religious issues.
i) At multiple staff meetings, Defendants required employees to hold hands in a
prayer circle. On some occasions, even though the customer service phones were
ringing, the phones were left unanswered, as everyone had to remain in the circle holding
hands until each employee said a prayer and gave thanks to God.
j) Denali assigned some of Defendants’ employees to work on developing
Onionhead-related material on company time.
k) At mandatory weekly and monthly group staff meetings led by Denali and at least
one other upper manager, and at required monthly one-on-one sessions between Denali
and individual employees, Defendants pressured employees to share personal and private,
non-work-related matters, including a friend’s suicide, parental issues, family and marital
strife, the death of loved ones, and the employee’s serious health conditions such as
breast cancer. At least one employee ran out of a group meeting crying because of the
personal and painful, non-work-related issues she was forced to discuss.
l) At these mandatory meetings and sessions, Denali would issue coaching and
directives about the employees’ personal lives, including that the employee should
divorce her husband or that the employee should discipline her child differently.
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m) At mandatory weekly and monthly meetings and sessions, Defendants required
employees to read and discuss literature about “divine plans,” “moral codes,” and
“enlightenment,” and issued homework on these topics for them to complete at home
outside work hours.
n) If employees did not schedule a one-on-one session with Denali, she would
schedule one for them and notify them, for example, “You need to talk to me, come by
around 3:00.”
o) After employees discussed their private matters in one-on-one sessions under
Denali’s guarantees of confidentiality, Denali frequently revealed the private matters to
other employees, including family members of the sharing employee. Denali would often
use the private, confidential information to pit employees against each other.
p) Denali would often move desks in the office allegedly in reaction to negative
energy.
q) Even when Denali was in California, she kept abreast of the events and personal
matters in New York by using co-worker informants as her eyes and ears at the office,
requiring them to notify her of any expression of opposition to the religious practices so
that she could work to ensure that the complaining employee maintained compliance.
r) On at least one occasion, Denali required employees to gather around her and
chant loving things to her as part of a meeting that lasted until 1:30 a.m.
14. Defendants’ managers pressured employees to participate in the religious
practices, and regularly disciplined, demoted, or terminated employees that did not participate.