Hannah Noelle Brackett Defamation Lawsuit

IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF
MISSOURI
SPRINGFIELD MISSOURI DIVISION
AHMED SALAU,
P. O. BOX 6008,
PRINCETON, WV 24740.
Case No.
)
Plaintiff, pro se
)
)
vs.
COMPLAINT
)
HANNAH BRACKETT,
725 NORTHPOINT AVE.,
LIBERTY, MO 64068
JURY TRIAL DEMANDED
)
Defendant.
COMPLAINT
Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:
NATURE OF THE CAUSE
This is an action for defamation, intentional infliction of emotional distress

arising out of defamatory Statements made by the Defendant about Defendants
dealings with Plaintiff. As detailed herein, Plaintiff is entitled to actual damages,
compensatory and punitive damages, damages for pain and suffering as a result of
Defendants actions, exemplary damages, special damages and other damages. All
events giving rise to Plaintiffs cause of action occurred in Missouri, such that
Missouri substantive law applies to Plaintiffs claims. Plaintiff requests a jury decide
these claims.
JURISDICTION AND VENUE

This Court has subject matter jurisdiction over this action based on
diversity of citizenship pursuant to 28 U.S.C 1332(a).
Venue is proper pursuant to 28 U.S.C 1391(b) because a substantial

part of the events or actions giving rise to Salaus claims arose in this district.
Salau has incurred harm in this district as a result of Bracketts tortious
conduct, and Brackett expressly aimed her tortious conduct at this district.
THE PARTIES
1. Plaintiff, Ahmed Salau is a natural person and is a resident of

Princeton, West Virginia. Plaintiff majored in chemistry and psychology
and had a minor in women and gender studies. Plaintiff is also a
professional research associate, co-author, co-investigator on a number
of ongoing scientific projects that have been published in peer-reviewed
journals published by reputable organizations like the American
Chemical Society among others. Plaintiff also had another job as a student
customer service assistant at the University of Missouri Campus Dining
Services. Plaintiff was also involved and/or is a member of numerous
groups on campus including but not limited to STOP TRAFFIC, BAPTIST
STUDENT UNION, ON THE ROCK, AUTISM SPEAKS, PSI CHI, THE
FOOD BANK, GREEN DOT, Foundation for the International Medical
Relief of Children (FIMRC),among other organizations. Plaintiff is also
the Founder, President and Chief Executive Officer of PARIS Angels a
mentoring program for at-risk youth.
2.
Defendant, Hannah Brackett is a natural person and is a resident of

Liberty, Missouri.
STATEMENT OF FACTS
3.
On or about Friday, September 7th 2012, Plaintiff exchanged numerous

text messages with Defendant.
4.
In one of the text messages, Plaintiff and Defendant agree to meet on

Saturday, September 8th 2012 in the afternoon to attend the football
game.
5.
On Saturday, September 8th 2012, at/or about 3pm, Plaintiff text

messages Defendant that she has arrived on campus and she is ready
to be picked up.
6.
At/or about 3:15pm, Defendant arrives at Plaintiffs dormitory in

company of five of his friends and meet with Plaintiff and two of her
friends as they head towards one of Defendants friends tailgate.
7.
On the way to the Defendants friends tailgate, one of the group

members Defendants friend Abby Corkins (hereinafter Abby)
recognizes a friend from her University Rowing Team at a different
tailgate and we all went with her.
8.
9.
The group never made it to Plaintiffs friends tailgate.

While at Abbys friends tailgate, some members of the group left early
for the football game while other members stayed and had alcoholic
beverages.
10.
At/or about a half hour from our arrival at Abbys friends tailgate,
everyone at the house headed towards the stadium to join the
festivities.
11.
The members of our group decided to go to Lot X to check out the view
and join the rest of the tailgaters at the top level.
12.
Some members of the group did not have tickets so at/or about an
hour after our arrival at Lot X, the group dispersed with Plaintiff, Abby,
and Defendant going to the football game together. The time was about
5:30pm.
13.
The group stayed at the football game until the game was decided
at/or about 9pm.
14.
The group subsequently headed towards the residence halls where

Abby headed back to her room.
15.
Defendant and Plaintiff proceeded to head downtown to get some food

and for some dancing.
16.
While downtown, Defendant and Plaintiff go to The Blue Fuque Bar

(hereinafter called the bar).
17.
Defendant and Plaintiff showed their identification cards to get into

the bar.
18.
19.
Defendant and Plaintiff ordered drinks and listened to a live band play.
At/or about 10pm, Defendant grew bored of the band since they were
a crappy band so Defendant and Plaintiff both played several
games of Ping-Pong before leaving the bar.
20.
Defendant and Plaintiff left the bar and proceeded to the speakers
circle on campus to complete one of the University rituals.
21.
Defendant and Plaintiff finished the ritual, shared a few kisses and
headed away from the speakers circle.
22.
On the way back to the Defendants dormitory, Defendant and Plaintiff

talked about a previous conversation they had about Chinese tradition,
history and Government. During this conversation, Plaintiffs collection
of Chinese books and artifacts came up and an excited Defendant
requested to check them out.
23.
When Defendant and Plaintiff arrived at Plaintiffs office, Defendant

checked out the Chinese lore for a few minutes before requesting that
the Plaintiff change the music because she did not like the country
music that was playing. Plaintiff then subsequently changed the music
to The
Beatles.
24.
Defendant and Plaintiff began to dance to The Beatles and

subsequently kissed and had consensual intercourse.
25.
After intercourse, they departed Defendants office as Plaintiff

proceeded to walk Defendant back to Defendants dormitory. Upon
arrival at Defendants dormitory, Defendant invites Plaintiff in and
swipes him in the building. Defendant requested to take the stairs up
to her room in order to avoid detection by her Residence Assistant.
26.
This revelation troubled Plaintiff so he questions Defendant as to why

she was trying to avoid her Residence Assistant to which she responds
that her Residence Assistant is always nosy and she wanted to avoid
coming in contact with her.
27.
Upon arrival at Defendants room, Plaintiffs roommate Rachel

Ouellette (hereinafter called Rachel) is laying on the bed asleep.
Defendant and Plaintiff subsequently kiss and have intercourse as they
fell asleep in Defendants bed.
28.
On Sunday, September 9th 2012, at/or about 9am, Defendant and

Plaintiff wake up, get dressed, and head downtown for breakfast at
Ernies caf.
29.
During breakfast, Defendant and Plaintiff had general conversations

about politics, and the large number of patrons present for breakfast
with their server Brooke. During breakfast, Defendant bragged about
owning and using a fake identification card which she showed Plaintiff.
30.
Plaintiff noticed a friend of his Peter Conn (hereinafter called Peter)

come in to meet his parents as they took the seat next to Plaintiff and
Defendants.
31.
After finishing breakfast, Plaintiff paid for both meals and

acknowledged Peter and his parents as he and Defendant left Ernies
caf.
32.
While Defendant and Plaintiff were walking back, Defendant asked

Plaintiff if he was clean to which Plaintiff responded in the
affirmative even adding that he was a regular blood and plasma donor
for the Red Cross.
33.
When Defendant and Plaintiff arrived at Defendants dormitory they

bade each other goodbye.
34.
At/or about 5pm on Sunday, September 9th, 2012, Plaintiff was

conducting research at his office in the Chemistry Building when the
University Police Department came to inquire about an incident that
occurred in an office in the Chemistry Building.
35.
Plaintiff co-operated with the University Police Department and went

down to the Police Station to talk about it.
36.
Plaintiff was interrogated for a few hours and was escorted back to his
Office for a search of his Office.
37.
Plaintiff complied with the search and detectives confiscated Plaintiffs

computer, phones, memory card, among other items for analysis.
38.
On/or about Tuesday, September 11th, 2012, Defendant applies for an

Order of Protection against Plaintiff in which she falsely, states as fact
that the Plaintiff stalked her, got her drunk, and raped her.
39.
On/or about Tuesday, September 25th, 2012, Plaintiff received

information from the University Office of Student Conduct that they
had received a report stating as facts that Plaintiff, continued to
give alcohol to a person in a drunken state, provided alcohol to a

minor
, got her into the bar , had nonconsensual sexual behavior
with a person all attributed to Defendant.
40.
On/or about Wednesday, September 19th, 2012, Plaintiffs Advisor in

the Women and Gender Studies Department learns about the
incidents. 41.
On/or about Friday, September 28th, 2012, Plaintiffs
Advisor in the
Chemistry Department and Principal Investigator on his research projects
Dr. Rainer Glaser (hereinafter called Chemistry Advisor) learns about
the incidents.
42.
On/or about 5:10pm on September 26th, 2012, Plaintiff attends a

previously scheduled Stronger against relationship and sexual
violence
(STARS) event called What is a Clothesline Project?
43.
On/or about September 26th, 2012, Plaintiff finds out that Defendant
has continued to state as facts her distorted, false, and diabolical
version of the events to the public knowledge of everyone at the
STARS Program and at the Relationship and Sexual Violence
Prevention (RSVP) thereby sharing this information with third parties.
44.
On/or about Wednesday, October 3rd, 2012, Plaintiff received

information from the University Office of Student Conduct summarily
expelling him and permanently separating him from the University.
45.
On/or about Thursday, October 4th, 2012, at about 5pm Plaintiff was
working at the Rollins Dining Hall when Defendant showed up at his
work station and called him a rapist loud enough for third parties to
hear.
46.
Plaintiff subsequently alerted a co-worker to witness the incident that

followed.
47.
Defendant got on the phone to call the University Police Department to

try to get Plaintiff arrested for violating an Order of Protection.
48.
During the ensuing incidents, Plaintiff alerts his supervisor Jeffrey J.

Lee (hereinafter called supervisor) to these incidents.
49.
At/or about 5:30pm, the Defendant continues to state as fact that the
Plaintiff raped her. These utterances were loud enough for Plaintiffs
friends to hear her and loud enough for Defendants co-workers to
hear her.
50.
Plaintiffs supervisor advises him that Plaintiff would no longer

work at Rollins Dining Hall and that we would try to find you another
location.
51.
On/or about 9:53am, Friday, October 5th, 2012, Plaintiff is notified by

his Supervisor that, ...this morning we received word from our
administration that we have to terminate you
52.
On/or around, Friday, October 5th, 2012, Plaintiff noticed that his
access to the Chemistry Building had been restricted and that his key
card could not access it.
53.
On/or about 2:30pm on Wednesday, October 10th, 2012, Plaintiff is

approached by Detective Kingsbury after Plaintiffs Women and
Gender Studies meeting with Plaintiffs Women and Gender Studies
Advisor.
54.
On/or about 2:30pm on Wednesday, November 28th, 2012, Defendant

continued to repeat her false and disproved defamatory statements at
Room 232, Memorial Union North at the University of Missouri.
55.
Plaintiff is informed by Detective Kingsbury that he is barred from the

Hudson/Rollins/Gillette Residence Halls and Dining Hall for a period
of One Year. Plaintiff is further informed that he has been expelled.
56.
Several members of STOP TRAFFIC and Women and Gender Studies

students have heard Defendants Statements.
57.
Several members of Plaintiffs church The Baptist Student Union have

heard Defendants Statements.
58.
Several co-workers and supervisors have heard Defendants

Statements.
59.
Plaintiffs Advisors have heard Defendants Statements.
60.
Members of PSI CHI have heard Defendants Statements.
61.
Members of Green Dot have heard Defendants Statements.
62.
Members of On the Rock have heard Defendants Statements.
63.
Plaintiff never stalked or attempted to stalk Defendant at any time.
64.
Plaintiff never provided alcohol to minor.
65.
Plaintiff never provided alcohol to Defendant in a drunken state.
66.
Plaintiff never got her into the bar with regards to Defendant.
67.
Plaintiff never engaged in nonconsensual sexual behavior with

Defendant.
68.
Plaintiff never raped Defendant.
CLAIMS FOR RELIEF

FIRST CLAIM FOR RELIEF
(Slander Per Se Injury to Professional Reputation)
68.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 67 as if fully set forth at length herein.
69.
Defendants Statements and publications described herein

(hereinafter called Statements) concerned Plaintiff and were false.
70.
Defendants Statements were widely published and not privileged in

any manner.
71.
Defendants Statements were made with reckless disregard of their

truth or falsity and/or with malice.
72.
Defendants Statements were slanderous per se because they injure

Plaintiffs professional reputation.
73.
Defendant falsely and as a matter of fact charged the Plaintiff with

stalking her asserting as fact, no prior interaction with him, he stalked
me that night, contrary to and inconsistent with time stamped
photographs that show otherwise and her subsequent actions.
74.
Defendant false and as a matter of fact charged the Plaintiff with

raping her asserting as fact, he raped me that night, contrary to
and inconsistent with the events that followed and time stamped
photographs.
75.

getting her drunk and raping her asserting as fact that, he kept
refilling my drinks at the bar and raped me while me judgment was
impaired, contrary to and inconsistent with the statements of the bar
manager and her subsequent actions.
76.
Defendants statements forever falsely taint and permanently damage

Plaintiff in the eyes of The University of Missouri at large, The
Chemistry Department of the University of Missouri, The Psychology
Department of the University of Missouri, the Women and Gender
Studies Department at the University of Missouri, STOP TRAFFIC, The
Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In
addition individuals will be less likely to associate with Plaintiff as a
result of his tainted reputation. In addition individuals will be less

likely to associate with
Plaintiff as a result of his tainted reputation.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

against Defendant awarding compensatory damages in the amount of
$1,100,000.00 plus punitive damages in an amount that will fairly and
reasonably punish Defendant for their conduct, and further ordering
Defendant to pay consequential and incidental damages, pre-judgment and
post-judgment interest costs of suit and attorneys fees, and further equitable
relief as this honorable Court deems just.
SECOND CLAIM FOR RELIEF
(Slander Per Se Injury to Personal Reputation)
77.

78.
Defendants Statements concerned Plaintiff and was false as a matter

of fact.
79.

any manner.
80.

81.
Defendants Statements were slanderous per se because they injure

Plaintiffs personal reputation.
82.

83.

photographs.
84.

refilling
my drinks at the bar and raped me while me judgment was impaired,
contrary to and inconsistent with the statements of the bar manager and
her subsequent actions.
85.

Plaintiff in the eyes of The University of Missouri, The Chemistry
Department of the University of Missouri, The Psychology Department
of the University of Missouri, The Women and Gender Studies
Department at the University of Missouri, STOP TRAFFIC, The Baptist
Student Union, On the Rock Church, PSI CHI, and Green Dot. In

result of his tainted reputation. The Defendant had dedicated
significant time and effort into to the City and community of Columbia.
Defendants statements permanently damage Plaintiffs reputation in
Missouri and all over the world. Plaintiff will soon have to leave the
world of academia and will likely face difficulties in obtaining
employment at another university as a result of Defendants false and
defamatory statements.

THIRD CLAIM FOR RELIEF

(Slander Per Se Accusations of Criminal Conduct)
86.

87.
Defendants statements concerned Plaintiff and were false.
88.
Defendants statements were widely published and not privileged in

any manner.
89.
Defendants statements were made with reckless disregard of their

truth or falsity with malice.
90.
Defendants statements were slanderous per se because they allege

Plaintiff was engaged in criminal conduct.
91.
Defendants statements accused Plaintiff of engaging in a pattern of

behavior that is criminal and punishable with up to 30 years of
incarceration at the Missouri Department of Corrections.
92.

93.

photographs.
94.


95.

Plaintiff in the eyes of The University of Missouri at large, The
Chemistry Department of the University of Missouri, The Psychology
result of his tainted reputation. In addition individuals will be less
likely to associate with

FOURTH CLAIM FOR RELIEF

(Slander By Implication)
96.

97.
Defendants Statements concerned Plaintiff and indicates the existence

of other facts which are defamatory.
98.

any manner.
99.

100. Defendant has no reasonable grounds for believing the truth of her
Statements.
101. Defendant falsely and as a matter of fact charged the Plaintiff with
102. Defendant false and as a matter of fact charged the Plaintiff with
photographs.
103. Defendant falsely and as a matter of fact charged the Plaintiff with
104. Defendants statements forever falsely taint and permanently damage
Plaintiff in the eyes of The University of Missouri at
large,
The Chemistry Department of the University of Missouri, The Psychology

result of his tainted reputation. In addition individuals will be less likely
to associate with Plaintiff as a result of his tainted reputation.

FIFTH CLAIM FOR RELIEF

(Slander Reckless Disregard/Malice)
105.
Plaintiff repeats and re-alleges the allegations set forth in

paragraphs 1 to 104 as if fully set forth at length herein.
106.
Defendants Statements concerned Plaintiff and was false.
107.
Defendants Statements were widely published and not privileged

in any manner.
108.

109.

stalking her asserting as fact, no prior interaction with him, he
stalked me that night, contrary to and inconsistent with time
stamped photographs that show otherwise and her subsequent
actions.
110.

photographs.
111.

refilling my drinks at the bar and raped me while my judgment was

impaired contrary to and inconsistent with the statements of the
bar manager and the Defendants subsequent actions.
112.
Defendants statements forever falsely taint and permanently

damage Plaintiff in the eyes of The University of Missouri at
large, The Chemistry Department of University of Missouri,
The Psychology Department of University of Missouri, the Women
and Gender Studies program at the University of Missouri,
STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI,
and Green Dot. In addition individuals will be less likely to associate with
Plaintiff as a result of his tainted reputation. In addition individuals will
be less likely to associate with Plaintiff as a result of his tainted
reputation.

SIXTH CLAIM FOR RELIEF

(Libel Per Se Injury to Professional Reputation)
113.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to

112 as if fully set forth at length herein.
114.
115.
Defendants Statements were widely published and not privileged in any

manner.
116.
Defendants Statements were made with reckless disregard of their truth or

falsity and/or with malice.
117.
Defendants Statements were libelous per se because they injure Plaintiffs

professional reputation.
118.
Defendant falsely and as a matter of fact charged the Plaintiff with stalking
her asserting as fact, no prior interaction with him, he stalked me that
night, contrary to and inconsistent with time stamped photographs that
show otherwise and her subsequent actions.
119.
Defendant false and as a matter of fact charged the Plaintiff with raping her
asserting as fact, he raped me that night, contrary to and inconsistent
with the events that followed and time stamped photographs.
120.
Defendant falsely and as a matter of fact charged the Plaintiff with getting
her drunk and raping her asserting as fact that, he kept refilling my drinks
at the bar and raped me while me judgment was impaired, contrary to and
inconsistent with the statements of the bar manager and her subsequent
actions.
121.

Plaintiff in the eyes of The University of Missouri at large, The Chemistry
Department of the University of Missouri, The Psychology Department of
the University of Missouri, the Women and Gender Studies Department at
the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On
the Rock Church, PSI CHI, and Green Dot. In addition individuals will be
less likely to associate with Plaintiff as a result of his tainted reputation.
In addition individuals will be less likely to associate with

SEVENTH CLAIM FOR RELIEF

(Libel Per Se Injury to Personal Reputation)
122.
Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to

121 as if fully set forth at length herein.
123.
Defendants Statements concerned Plaintiff and was false as a matter
of fact.
124.
Defendants Statements were widely published and not privileged in any

manner.
125.
Defendants Statements were made with reckless disregard of their truth or

falsity and/or with malice.
126.
Defendants Statements were libelous per se because they injure Plaintiffs

personal reputation.
127.
128.
129.
her drunk and raping her asserting as fact that, he kept refilling
my drinks at the bar and raped me while me judgment was impaired,

contrary to and inconsistent with the statements of the bar manager and
her subsequent actions.
130.

Plaintiff in the eyes of The University of Missouri, The Chemistry Department
of the University of Missouri, The Psychology Department of the University
of Missouri, The Women and Gender Studies Department at the University
of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church,
PSI CHI, and Green Dot. In addition individuals will be less likely to associate
with Plaintiff as a result of his tainted reputation. The Defendant had
dedicated significant time and effort into to the City and community of
Columbia. Defendants statements

EIGHTH CLAIM FOR RELIEF

(Libel Per Se Accusations of Criminal Conduct)
131.

132.
Defendants statements concerned Plaintiff and were false.
133.
Defendants statements were widely published and not privileged in any

manner.
134.
Defendants statements were made with reckless disregard of their truth or

falsity with malice.
135.
Defendants statements were libelous per se because they allege Plaintiff was
engaged in criminal conduct.
136.
Defendants statements accused Plaintiff of engaging in a pattern of behavior

that is criminal and punishable with up to 30 years of incarceration at the
Missouri Department of Corrections.
137.
138.
139.
her drunk and raping her asserting as fact that, he kept refilling my drinks
at the bar and raped me while me judgment was impaired, contrary to and
inconsistent with the statements of the bar manager and her subsequent
actions.
140.


reasonably punish Defendant for their conduct, pre-judgment and
postjudgment interest and further ordering Defendant to pay consequential
and incidental damages, costs of suit and attorneys fees, and further
equitable relief as this honorable Court deems just.
NINTH CLAIM FOR RELIEF

(Libel By Implication)
141.

142.
Defendants Statements concerned Plaintiff and indicates the

existence of other facts which are defamatory.
143.

any manner.
144.

145.
Defendant has no reasonable grounds for believing the truth of her

Statements.
146.

actions.
147.

photographs.
148.

149.


TENTH CLAIM FOR RELIEF

(Libel Reckless Disregard/Malice)
150.

151.
152.

any manner.
153.

154.

actions.
155.

photographs.
156.


157.


ELEVENTH CLAIM FOR RELIEF

(Intentional Infliction of Emotional Distress)
158.

159. Defendants Statements and conduct were extreme and outrageous.
So outrageous as to shock any marginally literate persons
sensibilities.
160.
Defendants Statements and conduct have caused Plaintiff to suffer

severe emotional stress.
161.

actions.
162.

photographs.
163.


164.
Defendant knew and intended that Plaintiff would suffer severe

emotional distress as a result of her Statements and conduct.

reasonably punish Defendant for their conduct, pre-judgment and postjudgment interest and further ordering Defendant to pay consequential and
incidental damages, costs of suit and attorneys fees, special damages,
exemplary damages and injunctive relief that the Defendant refrain from
further defaming Salau and further equitable relief as this honorable Court
deems just.
Respectfully submitted,
___________________________
Ahmed Salau
Plaintiff Pro Se
P O Box 6008
Princeton, WV 24740
Phone) 5403151147 Fax) 5403016034 ahmed@ahmedsalau.com
Dated Princeton, West Virginia November 24th, 2014.

Hannah Noelle Brackett Defamation Lawsuit

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IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF

725 NORTHPOINT AVE.,

JURY TRIAL DEMANDED

NATURE OF THE CAUSE

This is an action for defamation, intentional infliction of emotional distress

JURISDICTION AND VENUE

Venue is proper pursuant to 28 U.S.C 1391(b) because a substantial

1. Plaintiff, Ahmed Salau is a natural person and is a resident of

Defendant, Hannah Brackett is a natural person and is a resident of

On or about Friday, September 7th 2012, Plaintiff exchanged numerous

In one of the text messages, Plaintiff and Defendant agree to meet on

On Saturday, September 8th 2012, at/or about 3pm, Plaintiff text

At/or about 3:15pm, Defendant arrives at Plaintiffs dormitory in

On the way to the Defendants friends tailgate, one of the group

The group never made it to Plaintiffs friends tailgate.

The group subsequently headed towards the residence halls where

Defendant and Plaintiff proceeded to head downtown to get some food

While downtown, Defendant and Plaintiff go to The Blue Fuque Bar

Defendant and Plaintiff showed their identification cards to get into

On the way back to the Defendants dormitory, Defendant and Plaintiff

When Defendant and Plaintiff arrived at Plaintiffs office, Defendant

Defendant and Plaintiff began to dance to The Beatles and

After intercourse, they departed Defendants office as Plaintiff

This revelation troubled Plaintiff so he questions Defendant as to why

Upon arrival at Defendants room, Plaintiffs roommate Rachel

On Sunday, September 9th 2012, at/or about 9am, Defendant and

During breakfast, Defendant and Plaintiff had general conversations

Plaintiff noticed a friend of his Peter Conn (hereinafter called Peter)

After finishing breakfast, Plaintiff paid for both meals and

While Defendant and Plaintiff were walking back, Defendant asked

When Defendant and Plaintiff arrived at Defendants dormitory they

At/or about 5pm on Sunday, September 9th, 2012, Plaintiff was

Plaintiff co-operated with the University Police Department and went

Plaintiff complied with the search and detectives confiscated Plaintiffs

On/or about Tuesday, September 11th, 2012, Defendant applies for an

On/or about Tuesday, September 25th, 2012, Plaintiff received

give alcohol to a person in a drunken state, provided alcohol to a

On/or about Wednesday, September 19th, 2012, Plaintiffs Advisor in

On/or about Friday, September 28th, 2012, Plaintiffs

On/or about 5:10pm on September 26th, 2012, Plaintiff attends a

On/or about Wednesday, October 3rd, 2012, Plaintiff received

Plaintiff subsequently alerted a co-worker to witness the incident that

Defendant got on the phone to call the University Police Department to

During the ensuing incidents, Plaintiff alerts his supervisor Jeffrey J.

Plaintiffs supervisor advises him that Plaintiff would no longer

On/or about 9:53am, Friday, October 5th, 2012, Plaintiff is notified by

On/or about 2:30pm on Wednesday, October 10th, 2012, Plaintiff is

On/or about 2:30pm on Wednesday, November 28th, 2012, Defendant

Plaintiff is informed by Detective Kingsbury that he is barred from the

Several members of STOP TRAFFIC and Women and Gender Studies

Several members of Plaintiffs church The Baptist Student Union have

Several co-workers and supervisors have heard Defendants

Plaintiffs Advisors have heard Defendants Statements.

Members of PSI CHI have heard Defendants Statements.

Members of Green Dot have heard Defendants Statements.

Members of On the Rock have heard Defendants Statements.

Plaintiff never stalked or attempted to stalk Defendant at any time.

Plaintiff never provided alcohol to minor.

Plaintiff never provided alcohol to Defendant in a drunken state.

Plaintiff never engaged in nonconsensual sexual behavior with

Plaintiff never raped Defendant.

CLAIMS FOR RELIEF

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

Defendants Statements and publications described herein