3 Whitcomb Summit

Drury, Massachusetts 01343

413-248-7622
berkshirelegal@gmail.com
Ms. Toya Camacho
Assistant Vice President for Institutional Diversity
Equity/Title IX Coordinator
Williams College, Hopkins Hall
Williamstown, MA 01267
VIA EMAIL
April 13, 2016

Dear Ms. Camacho:

Please accept this letter as a Title IX complaint against Williams College, Dean Bolton, and
{Susan Smith} on behalf of my client, whose name has been redacted herein but was provided to
you in the cover email. I will refer to my client as John Doe from herein as I will be requesting
that the federal District Court grant leave to file under pseudonym and protective order in a
pending Complaint that shall be filed if the College decides to expel John after his appeal hearing
tentatively scheduled for the end of this month.
On the night of December 5, 2015, John attended a party on the Williams campus. While
dancing with another woman, Johns former girlfriend, {Susan Smith} confronted him for
dancing with someone other than herself as she wanted to dance with him. When John walked
away, {Smith} followed John. The time was sometime at approximately midnight on December
6, 2015. {Smith} followed John all the way to his dormitory. {Smith} grabbed and took Johns
phone. At this point, John pointed out {Smith}s wrongdoing, that she had violated the terms of
her employment by attending a student party, as {Smith} holds the position of Alumni
Coordinator at Williams. In response, {Smith} slapped John who then retreated to his room.
{Smith} escalated the situation even further afterwards by telephoning Johns sister, Lady Doe.
At 12:14 a.m. December 6, 2015, {Smith} telephoned Lady Doe, admitting that she had smacked
John. During the phone call, {Smith} kept repeating he's gonna report me for assault and I'm

EXHIBIT O

Title IX Complaint to Williams Title IX Coordinator

gonna lose my job!! They're gonna fire me!! {Smith} kept repeating to Lady Doe, my life is
over and that she wants to kill herself.
At 2:27 a.m. December 6, 2105, one hour after the phone call with Lady Doe ended, {Smith}
emailed Defendant Bolton claiming that she ({Smith}) had written essays for John in violation of
the Colleges Honor Code.
I am attaching a letter I sent to {Susan Smith}, an employee of Williams College, and bcced to
Dean Bolton. It was emailed and received by both on the afternoon of March 13, 2016.
On April 7, 2016, Dean Bolton informed John that the College was putting a no-contact order in
place between employee {Smith} and John. John had not contacted {Smith} in any way since
March 4, 2016, as described above, nor was he ever the harassing or assaultive party in the
relationship with {Smith}. Therefore, the no-contact order presumably was human resources,
the Deans, and/or other College officials manner of handling {Smith}s assault, which
constitutes dating violence in violation of College policy, and harassment of John.
Also on April 7, 2016, Dean Bolton requested that John not participate in a College dance team
performance scheduled for that upcoming weekend so as to accommodate {Smith} who was
coordinating the event. Despite the fact that {Smith} was the aggressor, it was John who faced
[even further] punishment and again was denied educational opportunity based on his gender.
As you are well aware, Title IX, Education Amendments of 1972 901, 20 U.S.C. 1681(Title
IX) prohibits discrimination based on sex in any educational program or activity that receives
federal funds. Under Title IX, discrimination includes conduct which denies or limits a students
ability to benefit from a schools programs or activities on the basis of that students sex. 34
C.F.R. 106.31(a). Title IX requires schools to respond prompt[ly] and effective[ly] to sexual
harassment and assault in order to mitigate the effects of the hostile learning environment and to
safeguard all students right to an education free from sex-based discrimination and violence.
Office for Civil Rights, U.S. Dept of Educ., Revised Sexual Harassment Guidance: Harassment
of Students by School Employees, Other Students, or Third Parties (2001).
The above facts exemplify a pattern of numerous facts beginning in April 2012 that are sufficient
to give rise to an inference that Dean Bolton intentionally, through differential treatment and
selective enforcement, discriminated against John in part because of his gender.
Without going into details about those other facts that are the subject of the pending litigation
against Dean Bolton and Williams College, this complaint deserves attention severally. I look
forward to learning the outcome of the investigation and resolution of this complaint.
Please do not hesitate to contact me if you need further information.
Yours Sincerely,

Stacey Elin Rossi, Esq.

EXHIBIT O

Title IX Complaint to Williams Title IX Coordinator