STATE OF NORTH CAROLINA a de : it 1d rhe Gobeil oun QFuasice MECKLENBURG County (istrict bel Superior Court Division rare orPana WILLIAM SCOTT CAMERON ates s CIVIL SUMMONS loro 831 E, Morehead St, Suite650_ | JALIAS AND PLURIES SUMMONS (ASSESS FEE) iy Sas, |Charlotte, NC 28202 | VERSUS 6.8.18, Rules 3 ane aa Foe) ats Gal Sars ued UNIVERSITY OF NORTH CAROLIONA - CHARLOTTE, JEREMY FELDMAN et al [Datoja) Subsequent Summons(es) Issued ‘To Each Of The Defendant(s) Named Below: ame nd Adress OF Doran 7 Tams Ana tress OF Bean? JUNC-Charlotte Jeremy Feldman [Office of Legal Affairs Halton-Wagner Tennis Complex 9201 University City Blvd. 9201 University City Blvd. |Charlotte, NC 28223-0001 Charlotte, NC 28223 IMPORTANT! You have boon sued! These papers are legal documents, DO NOT throw these papers out! You have to respond within 30 days. You may want to talk with a lawyer about your case as soon as possible, and, if needed, speak with someone who reads English and can translate these papers! JIMPORTANTE! jSe ha entablado un proceso civil en su contra! Estos papeles son documentos legales. iNO TIRE estos papeles! ne que contestar a més tardar en 30 dias. ;Puede querer consultar con un abogado lo antes posible acerca de su caso y, de ser necesario, hablar con alguien que lea inglés y que pueda traducir estos documentos! ‘ACivil Action Has Been Commenced Against You! You are notified to appear and answer the complaint of the plaintiff as follows: 4. Serve a copy of your writen answer to the complaint upon the plaintif or plaiti's attorney within thirty (30) days after you have been ‘served, You may serve your answer by delivering a copy to the plaintf or by mailing ito the plainif's last known address, and 2. File the original ofthe written answer with the Cierk of Superior Court of the county named above. If you fal to answer the complaint, the plaintif will apply to the Court forthe relief demanded in the complaint. Tams RR OF PTS Ray na, PICS OTP [bie cae ; Tie A ‘Sean Wagner = “hs fig Ele Oem Wagner Hicks PLLC Snsie = 79 F 831 E. Morehead St, Ste. 650 Carats, NO 2802 aa esc [Asstt osc] ciated Suen Court Bats OF Eran Tine [ENDORSEMENT (ASSESS FEE) | Oa Cea This Summons was originally issued on the date indicated Sarai above and retumed not served. At the request ofthe plaintiff, the time within which this Summons must be served Is extended sixty (60) days. [oepuyesc — CJasssenrcsc Caer or superior cout NOTE TO PARTIES: Many countes have MANDATORY ARBITRATION programs in which most cases where the amount in controversy Is $26,000 or Jess are heard by an arbitrator before a trial. The parties willbe nctifed i this case is assigned for mandatory arbration, and, if 50, what procedure is o te folowed. (Over) AOC-CV-100, Row. 4/18 ‘© 2018 Adminsirabve Office of the CourtsSTATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE MECKLENBURG COUNTY SUPERIOR COURT DIVISION icy, SPE WILLIAM SCOTT CAMERON, ) ) Plaintiff, ) v. ) ) COMPLAINT ‘THE UNIVERSITY OF NORTH ) (Jury Trial Demanded) CAROLINA AT CHARLOTTE, et. al., ) ) Defendants. ) Plaintiff William Scott Cameron (“Plaintiff”), complaining of Defendants The University of North Carolina at Charlotte (“UNCC”); Philip L. Dubois; Michael Hill; Judy Rose; Darin Spease; Kim Whitestone; Scott Byrd; Jeanne Madorin; and Jeremy Feldman (“Defendant Feldman” or “Coach Feldman”) (collectively, “Defendants”), avers that: INTRODUCTION 1. This is a civil rights action arising from the unwarranted termination of Plaintiff's scholarship based on defamatory, fabricated allegations of bullying made by Coach Feldman. After Coach Feldman dismissed Plaintiff from the team for purportedly bullying another member of the team, it became clear that no bullying ever occurred or was ever reported to Coach Feldman. Even though Coach Feldman knew that Plaintiff never bullied his teammate, or anyone else, he maliciously informed Plaintiff's teammates that Plaintiff was suspended for bullying. 2. Following Plaintiff's dismissal from the team, members of the UNCC men’s tennis team, including the alleged victim of bullying, emphatically and repeatedly stated that Plaintiff never engaged in bullying. To the contrary, members of the team came to Plaintiff's defense and raised concerns toUNCC officials regarding physical and emotional abuse at the hands of Coach Feldman, Rather than take steps to investigate these issues, UNCC officials attempted to convince the students that they should not make the allegations because they would become “public” and encouraged the students to speak in “hypotheticals” so that no record of the complaint would have to be made. 3. Following his suspension, Plaintiff repeatedly asked that the allegations of bullying be adjudicated by UNCC officials and was informed that there was no process available to adjudicate and investigate the false allegations made by Coach Feldman. Despite numerous meetings with various UNCC officials, UNCC never conducted an investigation and, despite promises that UNCC would honor Plaintiff s scholarship, terminated Plaintiff's scholarship without due process of law. 4. Plaintiff’ was forced to bring this action to recover damages resulting from the Defendants’ wrongful conduct and complete disregard for the Plaintiff's constitutional and reputational rights. PARTIES 5. Plaintiff William Scott Cameron is a citizen and resident of Mount Pleasant, South Carolina, At all times relevant to this Complaint, he was a student duly enrolled at the University of North Carolina at Charlotte (“UNCC”). 6. Defendant The University of North Carolina at Charlotte (“UNCC”) is a public university which is a constituent institution in the University of North Carolina multi-campus system authorized and governed by Article 9, Section 8 of the North Carolina Constitution and Chapter 116 of the North Carolina General Statutes. UNCC is located in Mecklenburg County, North Carolina. Defendant UNCC is sued for damages and injunctive relief pursuant to applicable state statutes. 7. Defendant Philip L. Dubois is the Chancellor of UNCC and a citizen and resident of North Carolina. The Chancellor exercises complete executive authority over UNCC, subject to the direction of