Preview
FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023
Exhibit K
FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023
Exhibit 28
FILED: INDEX NO. 159964/2023
FILED : NEW
NEW YORK
YORK COUNTY
COUNTY CLERK 10/11/2023 11:51 PM
CLERK INDEX No. 100389/2013
05/01/2013|
NYSCEF
NYSCEF DOC.
DOC. NO.
No. 13
21 RECEIVED NYSCEF: 10/11/2023
RECEIVED NYSCEF: 05 /01/2013
PRELIMINARY DRAFT PROPOSAL
To Columbia University Administration
Document"
("Working Subject To Further Review & Change As Required;
First Draft: 3/04)
"Yes" "No"
(NEEDS Basically A OR Answer And OR Meaningful Discussion;
NO Need To Discipline Or FIRE Somebody For Merely Clarifying A
Civil Rights & NLRA Rights Related University Policy)
Association"
"Minority Employees
Of Columbia University
(Proposed Name: Racial Equality Struggles For Columbia University Employees
Association Or (RESCUE Legal Defense) Fund)
Proposed By
Mr. Randy S. Raghavendra, M.Engg, M.B.A.,
(Columbia University's Senior Management Analyst Until September 2005)
Mission Statement
Association"
The ultimate mission of the proposed Employees of
"Minority
Columbia or the RESCUE Association or (Legal Defense) Fund is to
University
evolve into a (potentially-elected) Columbia employee-managed civil
University
rights and constitutional rights organization that would promote realistic equal
beyond fake racial tokens and or racial window-dressing and or
opportunity, any
deceptive affirmative action programs, and enhance the quality of life for faculty,
and students at Columbia with particular focus on
administrators, staff, University
who are Hispanics, and of other nationalities of
those African-Americans, (Black)
color who have suffered racial discrimination and harassment, including
traditionally
of kinds. Victims of anti-Semitism and other forms of
sexual harassment, varying
illegal discrimination at Columbia will also be vigorously supported in all
University
Association."
possible ways the proposed "Minority Employees
by
At the appropriate time and after sufficient positive change has been
Association"
the proposed Employees is expected to change
accomplished, "Minority
Association/Fund"
its proposed "RESCUE name to more appropriately
initially
role and to meet the needs of the racial
reflect its changing appropriately changing
minorities who have suffered illegal discrimination and or
and other traditionally
University. Therefore. the proposed Employees
harassment at Columbia "Minority
Page I of9
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Association"
is expected to accomplish its stated objectives in two distinct phases as
follows:
Phase I:
the proposed Association"
Initially, "Minority Employees of Columbia is
University
expected to be a very active civil rights support and watch-dog with the primary
group mission and
"true"
objective of promoting Equal Opportunity and ending illegal discrimination and harassment
and to stop, by appeals to reason and conscience if necessary, to law
and, by appeals (including
Class Action litigation, if necessary), the discrimination, harassment and or intimidation of the
Blacks, Jews, and other racial and ethnic minorities
employment who aspire
at all levels, to seek
including as faculty or senior administrators (senior grade, decision-making or those who
levels)
want to engage in academic pursuits and research (as undergraduate, or post-doctorial
graduate,
students) at the prestigious Columbia University.
Association"
This initial Phase I mission of the proposed "Minority Employees of
Columbia University is expected to be similar to that of the United Coalition Against Racism
(UCAR), a campus anti-discrimination group at the University of Michigan in the 1980s, and that of
other national civil rights organizations such as the Anti-Defamation League (ADL) and the
National Association For The Advancement of Colored People (NAACP) in the 1950s and 1960s.
Opportunity"
In 1987, the UCAR had promoted "Equal and opposed institutionalized racial
discrimination and harassment at the University of Michigan by announcing that it intended to file a
class action civil rights suit against the University for "not maintaining or creating a non-racist
atmosphere"
on campus and under the watch of Mr Lee C. Bollinger who was apparently the Dean
of Law School and or their leading First Amendment Rights Scholar at that time. Initially, the ADL
and the NAACP had also aggressively litigated and promoted the fair treatment of all citizens alike
and ending racial/ethnic inequalities, unjust and unfair discrimination against and ridicule of the
Blacks, Jews, and other racial minorities across the United States primarily during the 1950s, 1960s
and 1970s.
Phase II:
Association"
Once the proposed "Minority Employees of Columbia University has
"true"
achieved its initial objectives of Equal Opportunity, beyond fake racial tokens and or racial
window dressing and deceptive affirmative action programs, for individuals of all races and
ethnicities at Columbia University, the proposed RESCUE (Legal Defense) Fund/Association is
expected to continue as a civil rights and constitutional rights watch-dog group similar to the Black
Employee (Faculty, Administrators, and Staff) Associations that have been in existence for decades
at the various other prestigious universities across America and or the ADL and the NAACP of
today.
(1MPORTANT NOTE: Even though originally proposed by Mr. Randy S.
Association"
Raghavendra, the proposed "Minority Employees of Columbia
University will, however, NEVER represent him (Mr. Raghavendra himself)
in any individual racial discrimination litigation against Columbia University
and or any of its executives that was initiated by him individually.)
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important Reasons For Seeking The Establishment Of The
Association"
Proposed "Minority Employees Of Columbia University
At The Present Time Include But Not Limited To:
l. Despite continuing problems of institutionalized racial discrimination and harassment,
employees'
Columbia University does not have any independent managed association or
forum that could assist in any meaningful resolution of the issues of racial discrimination,
anti-Semitism, harassment (including sexual harassment), and intimidation of Blacks and
other racial and ethnic minorities. Black Faculty, Administrators, and Staff Associations are
common at many prestigious universities including but not limited to Harvard University,
University of Pennsylvania, New York University, Dartmouth College, College of William
& Mary, University of Michigan, and Clemson University.
2. According to the Journal of Blacks in Higher Education (JBHE), this New York's
most prestigious University has had the worst Black student enrollment record and trends
among the Ivy League Universities, with Black student enrollment dropping a whopping
32% during the past 13 years. Previously, a Columbia Assistant Vice President (Ms. Karen
Fry) described an article concerning Affirmative Action in student admissions written by
"inflammatory"
even its own President to be too and prohibited its public display in a
Columbia office
3. In December 2002, Ms. Zenobia White-Farrell, Columbia's own recent Head (or Guardian)
of so-called Equal Opportunity, and a Black woman herself filed a Class Action racial
discrimination lawsuit against Columbia University in Federal Court alleging a "pattern and
practice of discrimination against African-Americans in terms of compensation, hiring and
promotion," in Columbia's
and had sought elass relief for all African Americans employed
higher administrative pay grades.
4. In her Court complaint, Ms. White-Farrell had provided mind-boggling statistics to show the
levels of blatant racism and suspected fraud at this elite University of privilege. She showed
that even though three-quarters (74%) of Columbia's support (lower grade) staff is
nearly
minority, 6% of the senior grade
(grade 14 and above) managerial/executive positions
only
are occupied by Blacks. Further, to add insult to injury, there is at least a $20,000 salary
diffen:nce between the median salaries of the Whites and the (few) Blacks occupying any
senior grade positions
5. In February 2004, Columbia University President Lee C. Bollinger himself once again
created a hostile work environment for the Blacks and other racial minorities by vigorously
asserting the principles of Free Speech Rights enly to defend any racist and anti-Semitic
individuals within the University but later summarily firing, almost Nazi-style, any victims
of racism and racial discrimination if they spoke out against any racist practices. For all
practical purposes, President Bollinger had defended the various racist incidents including
"bake-sale"
the racist jokes an Anti-Affirmative action held by
by the marching band,
campus conservatives. and the most outrageous suggestion (disguised as a cartoon) that
"Black People Were invented In The 1700s As a Form of Cheap (Slave) Labor", while
showing a White Master whipping a Black Slave crying in pain.
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6. Blacks and other minorities at this elite of wealth and privilege continue to be
University
openly discriminated, de-humanized. harassed, and subjugated by their (predominantly
White) supervisors by blatantly racist suggestions such as "..It is a Scientific Fact That
Blacks Have Smaller And Blacks."
Brains, Whites Are Meant To Rule Over
7. Columbia Supervisors have even been allowed to Sexually & Harass & Abuse
Racially
Black/Colored Women Employees with almost total impunity.
8. If any Blacks and other employees/victims complain of discrimination or
minority
harassment, they are almost IMMEDIATELY CHARGED with some fabricated/false
allegations and FIRED.
9. However, the Columbia Administrators have ALLOWED WHITE employees to
OPENLY Abuse university computers and e-mail system ( including for sexually-
suggestive e-mails) during work, Defraud the University of thousands of dollars,
Sexually & Racially Harass Black/Colored women employees, OPENLY use
Racist & Sexist suggestions/comments on the job including NIGGERS, BITCHES,
etc. Sleep on the iob, DO DRUGS and DRINK on the job, and indulge in very
serious infractions such as even SELLING DRUGS on campus WITHOUT
BEING FIRED or sub ject to any serious discipline whatsoever. The blatant
racial discrimination and double- standar is for the Blacks/Minorities cannot be any
more clearer at Columbia University
10. Black/Minority employees have also been subject to the most offensive, degrading,
and humiliating suggestions and language such as "Niggers", Bitches", and the most
sexist and humiliating suggestions such as "Black Women Have Big Booty's So
Asses"
That We Can Fuck Them In Their "Black Women Are Only Good For
Sex", and "You're Supposed To Fuck Them, Not Marry Them! have been commonly used
by Columbia supervisors to racially and sexually harass, de-humanize, and subjugate the
Blacks and other minorities.
11. In sworn affidavits. many Black/minority employees have complained that Columbia
Supervisors have been allowed to make blatantly racist suggestions including but not limited
to: "Niggers Are Just For Sex, and you shouldn't tell anybody you're with her.",
"This place (Columbia) Is My Personal Stable. I Can Fuck Any One Of These
Want!"
BITCHES (Black/Colored women employees) Whenever I
"
12.Blatantly anti-Semitic suggestions such as . I Hope More Jewish Babies Get Blown
Upj." Speech"
and other "Hate have also been allowed at Columbia University.
13. in November 2004, there were numerous front-page newspaper articles on hate and
intimidation at Columbia University, including a front-page in The New York Daily News
- Climate University"
titled "POISON IVY of Hate Rocks Columbia that described the
anti-Semitism and intimidation directed at the Jewish students of Columbia University.
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14. On or about May 25, 2005, he New York Times ran a front-page article titled
"Columbia's an Expert Earful"
President, on Free Speech, Gets an in which Columbia
President was Detached"
Bollinger severely criticized, among other things, for being "Too
from vitally important University issues, Also, during his tenure at Columbia University
there were numerous other articles and editorials in several other newspapers and even in the
on-campus newspapers such as the Columbia Daily Spectator about his (Mr. Bollinger)
being insensitive to the issue of continuing blatant racism and the plight of the Blacks and
other racial minorities in and around Columbia University.
15. in or about June 2005, Columbia officials had also fired a highly accomplished Black
Professor of Medicine, Dr. Dolores Bacon, MD, after repeated incidents of racial harassment
and humiliation over a 10 years period. Professor Bacon was even asked how a "girl from
Ghetto"
the made it to Cornell (University.) Before being fired, Professor Bacon had also
asserted Equal Opportunity for Blacks at this Ivy League University and had recently
participated in a major National Institutes of Health (NIH) project regarding racism in
medical services.
16. The Columbia Administrators, including its President Bollinger, have continued to allow
various highly charged and well-publicized racial and anti-Semitic incidents of bigotry and
hate, including the hanging of racist Nooses and anti-semitic Swastikas on the
doors/facilities of Black and Jewish employees and even anti-racism Hunger-Strikes by
the Blacks/minorities to continue to occur at this 250-years old University of power and
privilege
17. Even though this 250-years old Ivy League University is openly proud of its alleged
tradition of liberal and open internal policies and procedures, unfortunately, Columbia
University with its power. influence, prestige, and almost unlimited financial and legal
resources, and especially under Columbia President Lee Bollinger administration, has
exhibited a tendency to act above and beyond the laws and the Constitution of the United
States, at least when it is concerning the Equal Opportunity Rights, First Amendment
Rights, Fourteenth Amendment Rights, NLRA Rights and other Civil Rights issues of only
its racial and other ethnic minorities, despite receiving over $550 Million Dollars every
year in Federal/ State aid and being subject to v ery stringent Title VI regulations of the
Federal Civil Rights Act of I964.
18. In March 2003, and even before any individual race discrimination lawsuit was filed, Mr.
Raghavendra directly appealed (in a 4-page internal memorandum/letter) to Columbia
President Lee Bollinger and Senior Executive VP, Mr. Robert Kasdin, to appoint a "Special
Prosecutor"
to investigate the lack
of any meaningful and or credible policies and
procedures to prevent any continuing racial discrimination and harassment at Columbia
Prosecutor"
University. Mr. Raghavendra's repeated requests for a "Special or even a
meeting to discuss these issues were repeatedly denied.
19. Before becoming the President of Columbia University in October 2002, Columbia
President Bollinger himself (after being made the Dean of the Law School, after a high-
profile alleged (crimina0 scandal and resignation of his predecessor. and or the President of
the University of Michigan) has had an history of allegations of insensitivity to blatant
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racism, anti-Semitism, and curtailment of Free Speech Rights at the University of Michigan,
including a Court-ordered injunction issued by United States District Court Judge Avern
Cohn of the United States District Court for the Eastern District of Michigan. See John Doe
v. University of Michigan, 721 F. Supp. 852 (E.D. Mich 1989.)
20. In his landmark and decision and permanent injunction
precedent-setting (approximately
issued against the unconstitutional Speech"
18-pages) restriction of "Free at the University
of Michigan campus, Judge Cohn pointed out the hypocrisy and double-standards of the
University of Michigan's unconstitutional restrictions (apparently masterminded Mr.
by
Bollinger to cover for and satisfy his own personal career ambitions) on protected rights by
a paragraph from Mr. Bollinger's (1986)."
quoting own book titled "The Tolerant Society
21. The almost All-White senior Columbia executives have been their
very successfully using
money, power, prestige and influence to openly subjugate, blatantly discriminate, harass,
and intimidate Blacks and other racial and ethnic minorities from seeking
any any positions
of power or racial equality for several decades. Therefore, totally unacceptable
institutionalized racism and anti-Semitism continues in the various operations of this elite
University, including in the policies affecting Black/minority student admissions and
Black/minority academic programs.
22. Columbia University has been basically maintaining an Apartheid-Style organization
structure where Blacks and other racial minorities are given opportunities at the lower-
only
level positions without any power or influence. Except for a few token Blacks and
Action"
minorities and some fake "Af&rmative programs candidates, who are used for
strategic racial window-dressing purposes, there are practically no Blacks and other racial
minorities at all in any Faculty or Administrative positions of power in at Columbia
University, even though this prestigious lvy League institution is located almost in the
middle of Harlem.
23. Columbia executives a
Preview
FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 Exhibit K FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 Exhibit 28 FILED: INDEX NO. 159964/2023 FILED : NEW NEW YORK YORK COUNTY COUNTY CLERK 10/11/2023 11:51 PM CLERK INDEX No. 100389/2013 05/01/2013| NYSCEF NYSCEF DOC. DOC. NO. No. 13 21 RECEIVED NYSCEF: 10/11/2023 RECEIVED NYSCEF: 05 /01/2013 PRELIMINARY DRAFT PROPOSAL To Columbia University Administration Document" ("Working Subject To Further Review & Change As Required; First Draft: 3/04) "Yes" "No" (NEEDS Basically A OR Answer And OR Meaningful Discussion; NO Need To Discipline Or FIRE Somebody For Merely Clarifying A Civil Rights & NLRA Rights Related University Policy) Association" "Minority Employees Of Columbia University (Proposed Name: Racial Equality Struggles For Columbia University Employees Association Or (RESCUE Legal Defense) Fund) Proposed By Mr. Randy S. Raghavendra, M.Engg, M.B.A., (Columbia University's Senior Management Analyst Until September 2005) Mission Statement Association" The ultimate mission of the proposed Employees of "Minority Columbia or the RESCUE Association or (Legal Defense) Fund is to University evolve into a (potentially-elected) Columbia employee-managed civil University rights and constitutional rights organization that would promote realistic equal beyond fake racial tokens and or racial window-dressing and or opportunity, any deceptive affirmative action programs, and enhance the quality of life for faculty, and students at Columbia with particular focus on administrators, staff, University who are Hispanics, and of other nationalities of those African-Americans, (Black) color who have suffered racial discrimination and harassment, including traditionally of kinds. Victims of anti-Semitism and other forms of sexual harassment, varying illegal discrimination at Columbia will also be vigorously supported in all University Association." possible ways the proposed "Minority Employees by At the appropriate time and after sufficient positive change has been Association" the proposed Employees is expected to change accomplished, "Minority Association/Fund" its proposed "RESCUE name to more appropriately initially role and to meet the needs of the racial reflect its changing appropriately changing minorities who have suffered illegal discrimination and or and other traditionally University. Therefore. the proposed Employees harassment at Columbia "Minority Page I of9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 Association" is expected to accomplish its stated objectives in two distinct phases as follows: Phase I: the proposed Association" Initially, "Minority Employees of Columbia is University expected to be a very active civil rights support and watch-dog with the primary group mission and "true" objective of promoting Equal Opportunity and ending illegal discrimination and harassment and to stop, by appeals to reason and conscience if necessary, to law and, by appeals (including Class Action litigation, if necessary), the discrimination, harassment and or intimidation of the Blacks, Jews, and other racial and ethnic minorities employment who aspire at all levels, to seek including as faculty or senior administrators (senior grade, decision-making or those who levels) want to engage in academic pursuits and research (as undergraduate, or post-doctorial graduate, students) at the prestigious Columbia University. Association" This initial Phase I mission of the proposed "Minority Employees of Columbia University is expected to be similar to that of the United Coalition Against Racism (UCAR), a campus anti-discrimination group at the University of Michigan in the 1980s, and that of other national civil rights organizations such as the Anti-Defamation League (ADL) and the National Association For The Advancement of Colored People (NAACP) in the 1950s and 1960s. Opportunity" In 1987, the UCAR had promoted "Equal and opposed institutionalized racial discrimination and harassment at the University of Michigan by announcing that it intended to file a class action civil rights suit against the University for "not maintaining or creating a non-racist atmosphere" on campus and under the watch of Mr Lee C. Bollinger who was apparently the Dean of Law School and or their leading First Amendment Rights Scholar at that time. Initially, the ADL and the NAACP had also aggressively litigated and promoted the fair treatment of all citizens alike and ending racial/ethnic inequalities, unjust and unfair discrimination against and ridicule of the Blacks, Jews, and other racial minorities across the United States primarily during the 1950s, 1960s and 1970s. Phase II: Association" Once the proposed "Minority Employees of Columbia University has "true" achieved its initial objectives of Equal Opportunity, beyond fake racial tokens and or racial window dressing and deceptive affirmative action programs, for individuals of all races and ethnicities at Columbia University, the proposed RESCUE (Legal Defense) Fund/Association is expected to continue as a civil rights and constitutional rights watch-dog group similar to the Black Employee (Faculty, Administrators, and Staff) Associations that have been in existence for decades at the various other prestigious universities across America and or the ADL and the NAACP of today. (1MPORTANT NOTE: Even though originally proposed by Mr. Randy S. Association" Raghavendra, the proposed "Minority Employees of Columbia University will, however, NEVER represent him (Mr. Raghavendra himself) in any individual racial discrimination litigation against Columbia University and or any of its executives that was initiated by him individually.) Page 2 of 9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 important Reasons For Seeking The Establishment Of The Association" Proposed "Minority Employees Of Columbia University At The Present Time Include But Not Limited To: l. Despite continuing problems of institutionalized racial discrimination and harassment, employees' Columbia University does not have any independent managed association or forum that could assist in any meaningful resolution of the issues of racial discrimination, anti-Semitism, harassment (including sexual harassment), and intimidation of Blacks and other racial and ethnic minorities. Black Faculty, Administrators, and Staff Associations are common at many prestigious universities including but not limited to Harvard University, University of Pennsylvania, New York University, Dartmouth College, College of William & Mary, University of Michigan, and Clemson University. 2. According to the Journal of Blacks in Higher Education (JBHE), this New York's most prestigious University has had the worst Black student enrollment record and trends among the Ivy League Universities, with Black student enrollment dropping a whopping 32% during the past 13 years. Previously, a Columbia Assistant Vice President (Ms. Karen Fry) described an article concerning Affirmative Action in student admissions written by "inflammatory" even its own President to be too and prohibited its public display in a Columbia office 3. In December 2002, Ms. Zenobia White-Farrell, Columbia's own recent Head (or Guardian) of so-called Equal Opportunity, and a Black woman herself filed a Class Action racial discrimination lawsuit against Columbia University in Federal Court alleging a "pattern and practice of discrimination against African-Americans in terms of compensation, hiring and promotion," in Columbia's and had sought elass relief for all African Americans employed higher administrative pay grades. 4. In her Court complaint, Ms. White-Farrell had provided mind-boggling statistics to show the levels of blatant racism and suspected fraud at this elite University of privilege. She showed that even though three-quarters (74%) of Columbia's support (lower grade) staff is nearly minority, 6% of the senior grade (grade 14 and above) managerial/executive positions only are occupied by Blacks. Further, to add insult to injury, there is at least a $20,000 salary diffen:nce between the median salaries of the Whites and the (few) Blacks occupying any senior grade positions 5. In February 2004, Columbia University President Lee C. Bollinger himself once again created a hostile work environment for the Blacks and other racial minorities by vigorously asserting the principles of Free Speech Rights enly to defend any racist and anti-Semitic individuals within the University but later summarily firing, almost Nazi-style, any victims of racism and racial discrimination if they spoke out against any racist practices. For all practical purposes, President Bollinger had defended the various racist incidents including "bake-sale" the racist jokes an Anti-Affirmative action held by by the marching band, campus conservatives. and the most outrageous suggestion (disguised as a cartoon) that "Black People Were invented In The 1700s As a Form of Cheap (Slave) Labor", while showing a White Master whipping a Black Slave crying in pain. Page 3 of 9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 6. Blacks and other minorities at this elite of wealth and privilege continue to be University openly discriminated, de-humanized. harassed, and subjugated by their (predominantly White) supervisors by blatantly racist suggestions such as "..It is a Scientific Fact That Blacks Have Smaller And Blacks." Brains, Whites Are Meant To Rule Over 7. Columbia Supervisors have even been allowed to Sexually & Harass & Abuse Racially Black/Colored Women Employees with almost total impunity. 8. If any Blacks and other employees/victims complain of discrimination or minority harassment, they are almost IMMEDIATELY CHARGED with some fabricated/false allegations and FIRED. 9. However, the Columbia Administrators have ALLOWED WHITE employees to OPENLY Abuse university computers and e-mail system ( including for sexually- suggestive e-mails) during work, Defraud the University of thousands of dollars, Sexually & Racially Harass Black/Colored women employees, OPENLY use Racist & Sexist suggestions/comments on the job including NIGGERS, BITCHES, etc. Sleep on the iob, DO DRUGS and DRINK on the job, and indulge in very serious infractions such as even SELLING DRUGS on campus WITHOUT BEING FIRED or sub ject to any serious discipline whatsoever. The blatant racial discrimination and double- standar is for the Blacks/Minorities cannot be any more clearer at Columbia University 10. Black/Minority employees have also been subject to the most offensive, degrading, and humiliating suggestions and language such as "Niggers", Bitches", and the most sexist and humiliating suggestions such as "Black Women Have Big Booty's So Asses" That We Can Fuck Them In Their "Black Women Are Only Good For Sex", and "You're Supposed To Fuck Them, Not Marry Them! have been commonly used by Columbia supervisors to racially and sexually harass, de-humanize, and subjugate the Blacks and other minorities. 11. In sworn affidavits. many Black/minority employees have complained that Columbia Supervisors have been allowed to make blatantly racist suggestions including but not limited to: "Niggers Are Just For Sex, and you shouldn't tell anybody you're with her.", "This place (Columbia) Is My Personal Stable. I Can Fuck Any One Of These Want!" BITCHES (Black/Colored women employees) Whenever I " 12.Blatantly anti-Semitic suggestions such as . I Hope More Jewish Babies Get Blown Upj." Speech" and other "Hate have also been allowed at Columbia University. 13. in November 2004, there were numerous front-page newspaper articles on hate and intimidation at Columbia University, including a front-page in The New York Daily News - Climate University" titled "POISON IVY of Hate Rocks Columbia that described the anti-Semitism and intimidation directed at the Jewish students of Columbia University. Page 4 of 9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 14. On or about May 25, 2005, he New York Times ran a front-page article titled "Columbia's an Expert Earful" President, on Free Speech, Gets an in which Columbia President was Detached" Bollinger severely criticized, among other things, for being "Too from vitally important University issues, Also, during his tenure at Columbia University there were numerous other articles and editorials in several other newspapers and even in the on-campus newspapers such as the Columbia Daily Spectator about his (Mr. Bollinger) being insensitive to the issue of continuing blatant racism and the plight of the Blacks and other racial minorities in and around Columbia University. 15. in or about June 2005, Columbia officials had also fired a highly accomplished Black Professor of Medicine, Dr. Dolores Bacon, MD, after repeated incidents of racial harassment and humiliation over a 10 years period. Professor Bacon was even asked how a "girl from Ghetto" the made it to Cornell (University.) Before being fired, Professor Bacon had also asserted Equal Opportunity for Blacks at this Ivy League University and had recently participated in a major National Institutes of Health (NIH) project regarding racism in medical services. 16. The Columbia Administrators, including its President Bollinger, have continued to allow various highly charged and well-publicized racial and anti-Semitic incidents of bigotry and hate, including the hanging of racist Nooses and anti-semitic Swastikas on the doors/facilities of Black and Jewish employees and even anti-racism Hunger-Strikes by the Blacks/minorities to continue to occur at this 250-years old University of power and privilege 17. Even though this 250-years old Ivy League University is openly proud of its alleged tradition of liberal and open internal policies and procedures, unfortunately, Columbia University with its power. influence, prestige, and almost unlimited financial and legal resources, and especially under Columbia President Lee Bollinger administration, has exhibited a tendency to act above and beyond the laws and the Constitution of the United States, at least when it is concerning the Equal Opportunity Rights, First Amendment Rights, Fourteenth Amendment Rights, NLRA Rights and other Civil Rights issues of only its racial and other ethnic minorities, despite receiving over $550 Million Dollars every year in Federal/ State aid and being subject to v ery stringent Title VI regulations of the Federal Civil Rights Act of I964. 18. In March 2003, and even before any individual race discrimination lawsuit was filed, Mr. Raghavendra directly appealed (in a 4-page internal memorandum/letter) to Columbia President Lee Bollinger and Senior Executive VP, Mr. Robert Kasdin, to appoint a "Special Prosecutor" to investigate the lack of any meaningful and or credible policies and procedures to prevent any continuing racial discrimination and harassment at Columbia Prosecutor" University. Mr. Raghavendra's repeated requests for a "Special or even a meeting to discuss these issues were repeatedly denied. 19. Before becoming the President of Columbia University in October 2002, Columbia President Bollinger himself (after being made the Dean of the Law School, after a high- profile alleged (crimina0 scandal and resignation of his predecessor. and or the President of the University of Michigan) has had an history of allegations of insensitivity to blatant Page 5 of 9 FILED: NEW YORK COUNTY CLERK 10/11/2023 11:51 PM INDEX NO. 159964/2023 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/11/2023 racism, anti-Semitism, and curtailment of Free Speech Rights at the University of Michigan, including a Court-ordered injunction issued by United States District Court Judge Avern Cohn of the United States District Court for the Eastern District of Michigan. See John Doe v. University of Michigan, 721 F. Supp. 852 (E.D. Mich 1989.) 20. In his landmark and decision and permanent injunction precedent-setting (approximately issued against the unconstitutional Speech" 18-pages) restriction of "Free at the University of Michigan campus, Judge Cohn pointed out the hypocrisy and double-standards of the University of Michigan's unconstitutional restrictions (apparently masterminded Mr. by Bollinger to cover for and satisfy his own personal career ambitions) on protected rights by a paragraph from Mr. Bollinger's (1986)." quoting own book titled "The Tolerant Society 21. The almost All-White senior Columbia executives have been their very successfully using money, power, prestige and influence to openly subjugate, blatantly discriminate, harass, and intimidate Blacks and other racial and ethnic minorities from seeking any any positions of power or racial equality for several decades. Therefore, totally unacceptable institutionalized racism and anti-Semitism continues in the various operations of this elite University, including in the policies affecting Black/minority student admissions and Black/minority academic programs. 22. Columbia University has been basically maintaining an Apartheid-Style organization structure where Blacks and other racial minorities are given opportunities at the lower- only level positions without any power or influence. Except for a few token Blacks and Action" minorities and some fake "Af&rmative programs candidates, who are used for strategic racial window-dressing purposes, there are practically no Blacks and other racial minorities at all in any Faculty or Administrative positions of power in at Columbia University, even though this prestigious lvy League institution is located almost in the middle of Harlem. 23. Columbia executives a