Princetoniii Complaint
Case 3:19-cv-12577 Document 1 Filed 05/16/19 Page 1 of 122 PageID: 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY ---------------------------------------------------------------X JOHN DOE, : Civil Action No.:19-cv-12577 : Plaintiff, : : COMPLAINT v. : : THE TRUSTEES OF PRINCETON : UNIVERSITY, TIGER INN, : MICHELE MINTER, : REGAN HUNT CROTTY, JOYCE CHEN : SHUEH, and EDWARD WHITE, : : : Defendants. : ---------------------------------------------------------------X Plaintiff John Doe1 (“Plaintiff” or “Doe”), by his attorneys Nesenoff & Miltenberg, LLP, as and for his complaint against Defendants The Trustees of Princeton University (“Princeton” or “the University”), Tiger Inn (“TI”), Michele Minter (“Minter”), Regan Hunt Crotty (“Crotty”), Joyce Chen Shueh (“Shueh”), and Edward White (“White”) (collectively, “the individual defendants” and collectively with Princeton and TI, “Defendants”), respectfully alleges as follows: THE NATURE OF THIS ACTION 1. Plaintiff John Doe, a sophomore at Princeton University at all times relevant herein, was sexually harassed at Tiger Inn (“TI”)—one of Princeton’s “eating clubs” 2—and was 1 Plaintiff has filed herewith a motion to proceed by pseudonym. 2 Princeton’s “eating clubs” are essentially co-ed fraternities. According to the Princeton University website, “In the early years, the University did not provide students with dining facilities, so students created their own clubs to provide comfortable houses for dining and social life. Eating clubs are . the most popular dining and social option for students in their junior and senior years.” 1 Case 3:19-cv-12577 Document 1 Filed 05/16/19 Page 2 of 122 PageID: 2 sexually assaulted by one of the older club members on his “initiation” night. 2.
[Show full text]