Case 1:21-Cv-01565-CRC Document 1 Filed 06/09/21 Page 1 of 46
Case 1:21-cv-01565-CRC Document 1 Filed 06/09/21 Page 1 of 46 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA ------------------------------------------------------------------------------x Docket No.: STEVEN FLORIO, PATRICK COSTELLO, WILLIAM MILLIOS, TIMOTHY MALLACH, SCOTT PLUMMER ROGER KRAFT, JOEL BARISH, BRANDON R. HILL, JAMES BELDON, JR., and ERNEST WILLMAN, Plaintiffs, COMPLAINT against Plaintiffs Demand Trial By Jury GALLAUDET UNIVERSITY, THE BOARD OF TRUSTEES OF GALLAUDET UNIVERSITY, ROBERTA CORDANO, and WP COMPANY LLC d/b/a THE WASHINGTON POST, Defendant. ------------------------------------------------------------------------------x COME NOW the Plaintiffs Steven Florio, Patrick Costello, William Millios, Timothy Mallach, Scott Plummer, Roger Kraft, Joel Barish, Brandon R. Hill, James Beldon, Jr., and Ernest Willman, who by and through their counsel state their Complaint against the Defendants Gallaudet University (“Gallaudet”), The Board of Trustees of Gallaudet University (“The Gallaudet Board”), Roberta Cordano (“President Cordano”) and WP Company LLC d/b/a The Washington Post, (“The Post”) as follows: INTRODUCTION 1. In the aftermath of the tragic death of George Floyd on May 25, 2020 and in the midst of the resulting Black Lives matter protests, the problem of systemic racism in America was brought to the forefront of the American psyche. Many governments and their agencies, private and public businesses, and organizations of all kinds including educational institutions and their leaders were quick to engage in self assessment, recognize the problem of systemic racism within, and then undertake to acknowledge and accept responsibility as the first step towards Case 1:21-cv-01565-CRC Document 1 Filed 06/09/21 Page 2 of 46 confronting and addressing this serious problem.
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