Date: February 23rd, 2016 6:08 PM
Author: mewling bawdyhouse shitlib
ALPHA:
69. In addition to John Doe 1’s aggressive behaviors directed at Leader, Leader also
witnessed and reported his capacity for violence towards others in public. On one
occasion, John Doe 1 accidentally lifted up Leader’s dress in front of a gathering of
friends, exposing her body to another male friend. After the male friend made a joke
about it, John Doe 1 became enraged and physically went after the male friend.
Similarly, John Doe 1 repeatedly started arguments with Leader at their mutual place of
work in Cabot House. He would repeatedly raise his voice at Leader while she stood
behind the counter and then walk away, leaving her upset, embarrassed and unable to
leave in front of customers.
70. Leader attempted to end her relationship with John Doe 1 multiple times but was
repeatedly convinced to begin seeing him again. Leader informed Defendants that the
relationship ultimately ended in earnest in mid-March 2014.
71. In September of 2014, Leader approached John Doe 1 to discuss his behavior during their
relationship. Leader informed investigators that she approached John Doe 1 with regards
to his new girlfriend. Leader asked John Doe 1 not to treat his new girlfriend the way he
had treated Leader. John Doe 1 indicated he would “never do that to her” as she had not
“set an expectation” like Leader by having a sexual encounter with him before they began
dating. Leader indicated that even if he did not care how his behavior affected others, his
conduct could still be against university policy. John Doe 1 then shouted at Leader that it
made no sense that he could be punished for sexual coercion when he could not take
action against someone “for being a bitch or teasing me.” After this conversation, Leader
Case 1:16-cv-10254-DJC Document 1 Filed 02/16/16 Page 15 of 29
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ceased communication with John Doe 1 beyond what was necessary as they shared a
dormitory and workplace.
72. After this conversation, John Doe 1 proceeded to harass Leader regularly. John Doe 1
would move aggressively towards Leader and make noises such as “huffing and puffing”
whenever he passed Leader in the hallway, despite her efforts to avoid and ignore him.
73. John Doe 1 would regularly show up at Leader’s shifts at work, at the dormitory café,
even after she scheduled shifts to avoid times she knew he would be in the café. John
Doe 1 would stand by the counter at the café, look at Leader and make comments such as
“You know, if you have to coerce someone, you’re doing it wrong.”
74. On one occasion, while Leader was in a nearly empty dining hall, John Doe 1 sat at a
table close to her and commented loudly, “Well, with the new Title IX policy, you can’t
do anything. It’s all rape!”
(http://www.autoadmit.com/thread.php?thread_id=3134075&forum_id=2#29899118)