Case 2:20-cv-10614-VAR-EAS ECF No. 32 filed 09/14/20 PageID.862 Page 1 of 92 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JOHN DOE MC-13, Case No. 2:20-cv-10614 Plaintiff, Hon. Victoria A. Roberts vs. Magistrate Judge Elizabeth A. THE UNIVERSITY OF MICHIGAN, Stafford THE REGENTS OF THE UNIVERSITY OF MICHIGAN (official capacity only), Jointly and Severally, Defendants. Michael A. Cox (P43039) Jackie J. Cook (P68781) THE MIKE COX LAW FIRM, PLLC Attorneys for Plaintiff 17430 Laurel Park Dr. N., Ste. 120E Livonia, MI 48152 734.591.4002
[email protected] David J. Shea (P41399) Ashley D. Shea (P82471) SHEA LAW FIRM PLLC Attorneys for Plaintiff 26100 American Dr., Ste. 200 Southfield, MI 48034 248.354.0224
[email protected] FIRST AMENDED COMPLAINT AND JURY DEMAND NOW COMES Plaintiff, John Doe MC-13, by and through his attorneys, Michael A. Cox, Jackie Cook and The Mike Cox Law Firm, PLLC, as well as David 1 Case 2:20-cv-10614-VAR-EAS ECF No. 32 filed 09/14/20 PageID.863 Page 2 of 92 J. Shea, Ashley D. Shea and Shea Law Firm PLLC, and for his Complaint against The University of Michigan (“UM”) and the Regents of the University of Michigan (“Regents”), collectively referred to as “Defendants,” states as follows: I. INTRODUCTION 1. While employed as a physician by UM from the early 1960s until 2003, Dr. Robert Anderson (“Anderson” or “Dr. Anderson”) used his position to sexually assault university students, many of whom were athletes.