Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 1 of 12 PAGEID #: 1

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION

CYNTHIA DOVE :
410 Lexington Avenue :
Newark, Ohio 43055 :
:
Plaintiff, : Case No. 2:17-CV-842
:
v. : Judge
:
OHIO CHRISTIAN UNIVERSITY : Magistrate Judge
1476 Lancaster Pike :
Circleville, Ohio 43113 : COMPLAINT
: (Jury Demand Endorsed Hereon)
and :
:
DR. MARK A. SMITH :
c/o Columbia International University :
7435 Monticello Road :
Columbia, South Carolina 29203 :
:
and :
:
DOUG SMITH :
2 Somersby Court :
Blythewood, South Carolina 29016 :
:
and :
:
JASON SHEETS :
c/o Ohio Christian University :
1476 Lancaster Pike :
Circleville, Ohio 43113 :
:
and :
:
RYAN WHISLER :
c/o Ohio Christian University :
1476 Lancaster Pike :
Circleville, Ohio 43113 :
:
Defendants. :
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 2 of 12 PAGEID #: 2

Plaintiff Cynthia Dove (“Plaintiff”), by and through undersigned counsel, states the

following as her Complaint for claims arising under Title IX of the Education Amendments of

1972 (“Title IX”), 20 U.S.C. §1681, and Ohio’s anti-discrimination laws, Ohio Revised Code

Chapter 4112, against Defendants Ohio Christian University (“Defendant OCU”), Dr. Mark A.

Smith (“Dr. Smith”), Doug Smith (“Mr. Smith”), Jason Sheets (“Defendant Sheets”), and Ryan

Whisler (“Defendant Whisler”):

JURISDICTION AND VENUE

1. The Court has jurisdiction over Count I pursuant to 28 U.S.C. §1331, because the claims

are set forth pursuant to the laws of the United States.

2. The Court has supplemental jurisdiction over Count II, Plaintiff’s state law claim,

pursuant to 28 U.S.C. §1367, because the claim arises out of the same set of operative

facts.

3. Venue is proper pursuant to 28 U.S.C. §1391, because the events giving rise to Plaintiff’s

claims occurred in Pickaway County, Ohio, within the Southern District of Ohio, Eastern

Division.

THE PARTIES

4. Plaintiff is a natural person residing in Licking County, Ohio.

5. Defendant OCU is an accredited institution of higher learning that maintains its campus

in Pickaway County, Ohio.

6. At all times relevant herein, Dr. Smith was the president of Ohio Christian University.

He resigned from Ohio Christian University in January 2017, and his resignation was

effective June 30, 2017. On or about July 1, 2017, Dr. Smith assumed the position of

president of Columbia International University in Columbia, South Carolina.

 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 3 of 12 PAGEID #: 3

7. At all times relevant herein, Mr. Smith was a student at Defendant OCU. Mr. Smith

worked in Defendant OCU’s Information Technology (“IT”) Department as a student

worker. Mr. Smith is the son of Dr. Smith.

8. At all times relevant herein, Defendant Sheets held the position of IT Director for

Defendant OCU.

9. At all times relevant herein, Defendant Whisler has held the position of Assistant Vice

President of IY for Defendant OCU.

FACTS

10. On or about August 24, 2015, Plaintiff met Defendant Sheets while attending the

orientation for Defendant OCU. After inquiring about IT student jobs, Defendant Sheets

provided Plaintiff with his business card. Shortly thereafter, Plaintiff emailed her résumé

and they scheduled a meeting to discuss employment opportunities.

11. On or about September 3, 2015, Plaintiff met with Defendants Sheets and Whisler to

discuss job opportunities. Defendant Whisler discussed the graphic design and marking

experience on Plaintiff’s résumé, noting that she could be utilized in those areas as well

as IT. The two hired Plaintiff at the September 3, 2015 meeting.

12. On or about September 9, 2015, Plaintiff began working at the BlazerTech Help Desk as

a Student Worker. Plaintiff worked approximately eight (8) hours per week, and she

reported to Defendant Sheets.

13. During Plaintiff’s first shifts working at the Help Desk, she was advised that Mr. Smith

was an experienced employee from whom she should seek assistance for training. It

quickly became obvious that Mr. Smith lacked the basic knowledge to work at the Help

Desk as he frequently told coworkers and customers that he did not know how to use
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 4 of 12 PAGEID #: 4

Windows computers because he only used Mac computers. Plaintiff observed Mr. Smith

frequently completing homework rather than working and he only worked when he felt

like it. Plaintiff quickly surmised that Mr. Smith was a favored employee, despite his

poor work performance and work ethic. Plaintiff learned that Mr. Smith was the son of

Dr. Smith.

14. During October 2015, Defendant Sheets emailed Help Desk employees a copy of a

department policy prohibiting media streaming, cell phone usage, and non-related work

activities while working. Despite Defendant Sheets’ reminder of company policy, Mr.

Smith repeatedly broke the policy by loudly streaming music with offensive lyrics. In

addition, Mr. Smith began to “prank” his coworkers.

15. Although Mr. Smith’s coworkers complained about his behavior, he was never

disciplined for his behavior and, as a result, Mr. Smith’s inappropriate work behavior

continued.

16. On or about October 28, 2015, a coworker accidently dropped a ladder. Mr. Smith yelled

at the coworker, “Stop being such a Jew!” Plaintiff told Mr. Smith that she was offended

by his remark and asked if he knew that she was Jewish. Mr. Smith ignored her.

17. On a different occasion, while discussing Hebrew classes at Defendant OCU, Mr. Smith

mocked the Hebrew language by pretending to speak it by making gibberish, nonsensical

sounds. Mr. Smith also made fun of Jewish culture.

18. During November 2015, Mr. Smith expressed disdain for African Americans and

Mexicans, stating, “I hate black people,” and “I hate Mexicans.” Alarmed, and assuming

Mr. Smith’s comments were nothing more than brash hyperbole, Plaintiff asked, “Why?”

Mr. Smith responded, “All black people act like they’re entitled to everything,” and
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 5 of 12 PAGEID #: 5

Mexicans are “always poor” and “dirty freeloaders.” For emphasis, Mr. Smith added that

he was “dead serious.”

19. On or about December 2, 2015, Mr. Smith stated that a coworker had been hired because

she was sexually promiscuous. Mr. Smith started to place his finger in Plaintiff’s mouth

before she stopped him. Then Mr. Smith turned to his supervisor, stating, “That was a

slut test. If they close their mouth, they’re a slut.” The targeted coworker got up from her

office chair and moved to a different room. While the coworker left, Mr. Smith insulted

her, stating that the coworker left a “huge ass” imprint on the office chair.

20. Another day in December of 2015, Mr. Smith stated that the targeted coworker was

“hot,” but he would never date her because she was a “bitch.”

21. Throughout November and December of 2015, Mr. Smith repeatedly sexually harassed

the targeted coworker:

a. Mr. Smith stated that the targeted coworker’s hair was “long enough to pull on.”

Given the context of his comments at that time, Plaintiff understood Mr. Smith’s

comment to mean that her hair was long enough to pull on during sexual

intercourse.

b. Mr. Smith stated that the targeted coworker’s jeans looked “painted on.”

c. Mr. Smith repeatedly attempted to covertly take pictures of the targeted

coworker’s buttocks.

d. Mr. Smith photographed the targeted coworker’s buttocks while she cleaned. He

posted or sent it on social media, posting, “This is why we hire women.” Plaintiff

understood Mr. Smith’s comment to mean that Defendant OCU hired women for
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 6 of 12 PAGEID #: 6

the purpose of viewing them as sexual objects. Many of Plaintiff’s male

coworkers openly discussed the photo.

22. During the winter break, beginning on or about December 14, 2015, Plaintiff worked full-

time at the Help Desk, along with Mr. Smith. Mr. Smith brought in gaming consoles and

played video games at work, while Plaintiff answered most of the calls to the Help Desk.

23. During or about the week of December 28, 2015, Plaintiff asked the targeted coworker if

she reported Mr. Smith’s sexual harassment. When the targeted coworker responded that

she had not reported Mr. Smith, Plaintiff questioned why. The targeted coworker

responded that she was too intimidated because Mr. Smith was Dr. Smith’s son. The

targeted coworker informed Plaintiff that many people had warned her that there was

nothing that could be done because he was the President’s son.

24. Plaintiff initially reported Mr. Smith’s sexual harassment, racist comments, anti-Semitic

comments, and all of his other inappropriate behavior to Melody Jarrell, Defendant

Whisler’s Administrative Assistant. Ms. Jarrell informed Plaintiff that Defendant Whisler

would want to hear Plaintiff’s complaints directly, and she scheduled a meeting with him.

Ms. Jarrell also asked whether Plaintiff had complained to Defendant Sheets. Plaintiff

responded, “No,” explaining that other people had complained but no steps had been

taken to remedy Mr. Smith’s behavior, which created a hostile work environment.

25. Plaintiff met with Defendant Whisler on the next business day to discuss her complaints

about Mr. Smith. Plaintiff provided a detailed account of Mr. Smith’s sexual harassment,

racist comments, anti-Semitic comments, and all of his other inappropriate behavior.

Defendant Whisler also asked if Plaintiff had discussed her complaints with Defendant

Sheets. Plaintiff stated that she had not discussed her complaints with Defendant Sheets
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 7 of 12 PAGEID #: 7

because other employees complained about Mr. Smith to him but he did not do anything

to stop Mr. Smith’s behaviors.

26. On or about January 11, 2016, the targeted coworker and Plaintiff had a meeting with Dr.

Rick Christman (“Dr. Christman”), Dean of Student Life. At the request of Dr.

Christman, Plaintiff emailed him a complaint detailing Mr. Smith’s harassment and

discrimination from her OCU email account. Plaintiff had a second meeting with Dr.

Christman. After the second meeting, Plaintiff sent another email to Dr. Christmas from

her OCU email account.

27. Despite enjoying her work on the Help Desk, on or about January 11, 2016, the targeted

coworker and Plaintiff transferred from the Help Desk to the Marketing/Graphics/Web

Department in order to avoid Mr. Smith’s harassment and discrimination. Plaintiff

worked in Marketing, and Sarah Cox (“Ms. Cox”), Marketing and Communications

Coordinator, supervised Plaintiff. The targeted coworker worked in the website

department because she had HTML coding experience.

28. During the first week of February 2016, Defendant OCU allegedly “disciplined” Mr.

Smith by transferring him to the Networking Department from the Help Desk. The

transfer placed Mr. Smith in the same room as the targeted coworker and Plaintiff,

despite their efforts to physically remove themselves from his presence by transferring to

a different department. In addition, although Mr. Smith’s transfer was allegedly a

“disciplinary measure,” it served as an opportunity for him to gain additional skills to

improve his résumé.

29. During late February 2016, Plaintiff complained to Ms. Cox about Mr. Smith being in

close proximity to Plaintiff and the targeted coworker. When Plaintiff explained her
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 8 of 12 PAGEID #: 8

concerns given Mr. Smith’s discrimination and sexual harassment, Ms. Cox informed

Plaintiff that she had only been advised that they could not work together because there

had been a “disagreement,” not that Plaintiff had complained about sexual harassment, a

hostile work environment, and discrimination. Ms. Cox expressed concern about Mr.

Smith being in such close proximity to Plaintiff and the targeted coworker.

30. Upon information and belief, Ms. Cox then complained to Defendant Whisler about Mr.

Smith working in such close proximity to Plaintiff and the targeted coworker.

31. During March 2016, Dr. Christman informed Plaintiff that Mr. Smith had allegedly been

fired as a result of Plaintiff’s complaints. Mr. Smith, however, told everyone that he was

putting in his two week notice. Mr. Smith then worked for another two weeks.

32. After Mr. Smith’s alleged termination, Plaintiff continued working in the

Marketing/Graphics/Web department with Ms. Cox supervising her. Plaintiff expressed a

desire to work full-time in the Department after graduation. Because the team was short-

handed with room to grow, Ms. Cox approached Defendant Whisler about creating a job

opening for Plaintiff upon her graduation. Defendant Whisler appeared receptive to

creating the position.

33. During March and April 2016, Ms. Cox and Defendant Whisler routinely praised

Plaintiff’s work. Ms. Cox taught Plaintiff how to perform many of her job duties.

Plaintiff approached Defendant Whisler about employment after graduation. Defendant

Whisler said that positions were competitive, but they needed assistance in the

department.

34. During or about April or May 2016, Jeremy Davis resigned and a full-time Social Media

Coordinator position became vacant. Although the job was open, Defendant OCU never
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 9 of 12 PAGEID #: 9

posted the position. Upon information and belief, Ms. Cox and Renee Handy (“Ms.

Handy”), Marketing Director, recommended Plaintiff for the Social Media Coordinator to

Defendant Whisler. Despite their recommendations, Plaintiff was never notified of the

job opening and, therefore, never applied. Knowing that Mr. Davis resigned and the

position would, therefore, be available, Plaintiff frequently checked the website for the

job opening and checked in with Ms. Cox to make sure Plaintiff did not miss the job

opening.

35. During the week of May 30, 2016, Defendant Whisler offered Plaintiff an eight (8) week

contract for a Marketing Automation position. Defendant Whisler encouraged Plaintiff to

take the job offer, noting that contract work would allow her to get the foot in the door to

obtain a full-time position. Based on Defendant Whisler’s assurances, Plaintiff accepted

the offer.

36. During late June or early July of 2016, Ms. Cox offered her letter of resignation. Ms. Cox

strongly recommended Plaintiff as her replacement. In response, Defendant Whisler

stated, “Cynthia will never be a full-time employee here because she’s burned some

bridges.” When Ms. Cox asked if Defendant Whisler was referring to the situation with

Mr. Smith, Defendant Whisler confirmed that Plaintiff’s complaints of discrimination

were the reason Plaintiff “burned bridges.” Ms. Cox advised Defendant Whisler to stop

“leading [Plaintiff] on” about being hired for a full-time position from a contract position

when he knew that Defendant OCU would never hire Plaintiff because of her complaints

about Mr. Smith.

Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 10 of 12 PAGEID #: 10

37. After Ms. Cox’s meeting with Defendant Whisler, Ms. Cox advised Plaintiff to look for

employment outside of Defendant OCU based on Defendant Whisler’s confirmation that

Plaintiff would never be hired full-time because she complained about Mr. Smith.

38. During July 2016, near the end of Plaintiff’s eight-week contract, she scheduled a

meeting with Defendant Whisler to discuss her continued employment. There was

enough work left for another contract and/or a full-time position. Plaintiff informed

Defendant Whisler that she could not financially afford another contract position, as

opposed to a full-time position. Plaintiff expressed her desire to work at Defendant OCU

full-time. Defendant Whisler stated that contract positions often lead to full-time

positions, even though he previously told Ms. Cox that Plaintiff would never be hired

full-time because of her complaints against Mr. Smith. Upon information and belief,

OCU hired an underqualified youth pastor to complete the work Plaintiff previously

performed.

39. Plaintiff intended to continue her education at Defendant OCU to obtain a Masters

Degree while working at Defendant OCU.

40. Plaintiff dual-filed a charge of discrimination with the EEOC on or about January 13,

2017.

COUNT I: RETALIATION, TITLE IX, 20 U.S.C. §1681

41. Plaintiff incorporates, as if fully restated herein, the foregoing paragraphs.

42. Plaintiff engaged in protected activity when she complained about Mr. Smith’s sexual

harassment and hostile work environment to Defendant OCU officials.

43. Defendant OCU had knowledge of the protected activity.

Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 11 of 12 PAGEID #: 11

44. Plaintiff suffered adverse actions when Defendant refused to hire her for multiple full-

time positions.

45. A causal connection exists between Plaintiff’s protected activity and the adverse actions.

46. Defendant OCU retaliated against Plaintiff in violation of 20 U.S.C. §1681.

COUNT II: RETALIATION, R.C. 4112.02(I)

47. Plaintiff incorporates, as if fully restated herein, the foregoing paragraphs.

48. Plaintiff engaged in protected activity when she complained about Mr. Smith’s sexual

harassment, racial discriminatory comments, anti-Semitic comments, and hostile work

environment to Defendant OCU officials.

49. Defendant OCU had knowledge of the protected activity.

50. Plaintiff suffered adverse actions when Defendant refused to hire her for multiple full-

time positions.

51. A causal connection exists between Plaintiff’s protected activity and the adverse actions.

52. Defendant OCU retaliated against Plaintiff in violation of R.C. 4112.02(I).

53. Defendants Mark A. Smith, Doug Smith, Jason Sheets and Ryan Whisler aided, abetted

and participated in the retaliation of Plaintiff in violation of O.R.C. §4112.02(J).

WHEREFORE, Plaintiff Cynthia Dove prays for judgment in her favor, injunctive

relief, reinstatement or front pay, back pay, compensatory and non-economic damages exceeding

$75,000, pain and suffering damages, punitive damages, liquidated damages, attorneys’ fees,

costs, pre- and post-judgment interest, and any other relief to which she may be entitled and

which this Court may deem appropriate and equitable.

Case: 2:17-cv-00842-JLG-CMV Doc #: 1 Filed: 09/25/17 Page: 12 of 12 PAGEID #: 12

Respectfully Submitted,

s/Laren E. Knoll
Laren E. Knoll (0070594)
The Knoll Law Firm, LLC
7240 Muirfield Drive, Suite 120
Dublin, Ohio 43017
Telephone: (614) 372-8890
Facsimile: (614) 452-4850
Email: lknoll@knolllaw.com
Trial Attorney for Plaintiff Cynthia Dove

JURY DEMAND

Plaintiff requests a trial by a jury of eight (8) persons on all issues triable by a jury.

s/Laren E. Knoll
Laren E. Knoll (0070594)
The Knoll Law Firm, LLC
 Case: 2:17-cv-00842-JLG-CMV Doc #: 1-1 Filed: 09/25/17 Page: 1 of 1 PAGEID #: 13
JS 44 (Rev. 0/16) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Cynthia Dove Ohio Christian University; Dr. Mark A. Smith; Doug Smith;
Jason Sheets; Ryan Whistler

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Laren E. Knoll, Esq., The Knoll Law Firm, LLC
7240 Muirfield Drive, Suite 120, Dublin, Ohio 43017
Telephone: 614-372-8890; Email: lknoll@knolllaw.com

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) &OLFNKHUHIRU1DWXUHRI6XLW&RGH'HVFULSWLRQV
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 840 Trademark u 460 Deportation
Student Loans u 340 Marine Injury Product u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY u 710 Fair Labor Standards u 861 HIA (1395ff) u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud Act u 862 Black Lung (923) u 490 Cable/Sat TV
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal Relations u 864 SSID Title XVI Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 751 Family and Medical u 891 Agricultural Acts
u 362 Personal Injury - Product Liability Leave Act u 893 Environmental Matters
Medical Malpractice u 790 Other Labor Litigation u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 791 Employee Retirement FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: Income Security Act u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Title IX of the Civil Rights Act of 1964, 20 U.S.C. 1681 et seq.
VI. CAUSE OF ACTION Brief description of cause:
Defendants retaliated against Plaintiff for complaints of discrimination
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 75,000.00 JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
09/25/2017 s/Laren E. Knoll
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE