Farzinpour, Peyman vs. Alali, Mina et al

1 This case arises out of the false statements made publicly by Defendants Alali and

Dogs 1-50, in conjunction with false allegations of sexual harassment made against Plaintiff

Farzinpour, a former employee of Berklee College of Music (“Berklee” or the “College”), by Mina

Alali, a 2020 graduate of the College and former student of Plaintiff Farzinpour.

Defendant Alali has publicly broadcast her false allegations to publicly shame and

hu iliate Farzinpour, label him as a sexual deviant, cast him publicly in a false and negative light,

bolster her own profile for personal gain, and destroy Plaintiffs reputation, occupation, and

professional accomplishments.

3 As a result of Defendants’ extreme and defamatory behavior, Plaintiff Farzinpour

has Heen subject to widespread humiliation, denigration, mental and emotional anguish, social

stigma, threats, professional shunning, and occupational losses.

In light of Defendants’ campaign of public humiliation and social media outrage

aeail st Plaintiff, which has been ongoing for almost a year, Plaintiff seeks judicial intervention to

preserve and reinstate his previously unblemished professional and personal reputation.