713 F.Supp. 14
United States District Court, District of Columbia. Frieda SHAMLOO, Plaintiff, v. LIFESPRING, INC., et al., Defendants. Civ. A. No. 88-2932. April 11, 1989.
Plaintiff brought action seeking compensation for injuries allegedly received as a result of her participation in a psychological training program run by nonprofessionals. On defendants' motion for judgment on the pleadings, and plaintiff's motion to amend the complaint, the District Court, Revercomb, J., held that: (1) "discovery rule" exception to statute of limitations was available to plaintiff, even though defendants were not licensed psychologists or psychiatrists; (2) when plaintiff's cause of action accrued under discovery rule was jury question; and (3) allegation of negligent infliction of emotional distress failed to state a claim, in absence of allegation of physical injury.
Defendants' motion denied in part and granted in part; plaintiff's motion granted.
Gerald F. Ragland, Alexandria, Va., for plaintiff. Dan Mayers, David Donovan, and Wilmer, Cutler & Pickering, Washington, D.C., for defendant.