prompts/exhibit_pool.json

{
  "exhibits": [
    {
      "id": "A",
      "name": "Housing Crisis Timeline",
      "date": "Jun 30 – Oct 2025",
      "from": "David Mullins",
      "to": null,
      "type": "Other",
      "text": "EXHIBIT A - HOUSING CRISIS TIMELINE\n\nJune 30, 2025: Plaintiff fled his shared housing situation due to escalating harassment and intimidation by housemate Respondent. Initial refuge at colleague's empty house with 11-day time limit.\n\nJuly 1-11, 2025: Temporary housing at colleague's house while seeking permanent solution through university channels.\n\nJuly 12-21, 2025: Housing uncertainty intensifies as temporary arrangement nears expiration.\n\nJuly 21, 2025: Explicit homelessness warning sent to senior university leadership (President Blair, Faculty A, Legal Affairs): \"I fled my home at substantial cost in order to protect my own physical safety…. I can remain at Colleague C's empty house for 11 more days. I do not have a permanent place. I cannot go to Germany as I planned and received an award for, due to all this financial and logistical disruption.\"\n\nJuly 22, 2025: University acknowledgment of homelessness warning but no immediate action.\n\nJuly 24, 2025: Dean Wasilko formally denies housing assistance despite available resources: \"I heard back from housing, and it looks like right now the only rooms we have are in the first year buildings. Obviously, that is not helpful at this juncture.\" (Exhibit G)\n\nJuly 25-August 12, 2025: Plaintiff forced into precarious couch-surfing arrangements while university maintains denial despite having confirmed housing availability.\n\nAugust 13, 2025: Plaintiff submits Emergency Removal Request seeking Title IX supportive measures including housing. (Exhibit B-5A)\n\nAugust 13-14, 2025: Simpson's 24-hour jurisdiction flip - initially accepts Title IX complaint, then explicitly disclaims jurisdiction over sex discrimination complaints. (Exhibits B-5, B-6)\n\nAugust 15, 2025: Sawa threatens disciplinary charges for seeking help from university officials. (Exhibit B-7)\n\nAugust-October 2025: Continued housing instability as all university channels fail to provide federally mandated supportive measures. \"Out of couches to surf\" - housing crisis reaches critical phase with \"imminent complete homelessness.\"\n\nMedical documentation confirms: \"He reports homelessness since June 30th which has been very stressful and likely worsens his mental health conditions. I recommend all measures to protect him from his abuser and to provide stable housing be made.\" Treating Physician. (Exhibit F)\n\nPresent: 90+ days of homelessness while university maintains available housing resources but refuses compliance with federal Title IX supportive measures requirements."
    },
    {
      "id": "B-0",
      "name": "Initial Request for Emergency Housing",
      "date": "Jun 30, 2025",
      "from": "David Mullins",
      "to": "Dr. Adam Wasilko",
      "type": "Email",
      "text": "EXHIBIT B-0: INITIAL REQUEST FOR EMERGENCY HOUSING\nJune 30, 2025\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nTo: Dr. Adam Wasilko <wasilkoa@duq.edu>\nCc: Dr. Daniel Selcer <selcerd@duq.edu>, Faculty A <Faculty A>\n\nDear Dean Wasilko,\n\nI'm writing to report an incident that occurred this evening involving my roommate, Respondent, which left me feeling physically threatened and unsafe in my own home.\n\nWhile I am already in the process of filing a small claims complaint related to the housing situation, this escalation was entirely unexpected and extremely distressing.\n\nRespondent approached me in the kitchen; when I calmly stated that I was not interested in talking, she began yelling at me, got within inches of my face, and aggressively followed me through the apartment. When I asked if she was following me, she confirmed it aloud. She pursued me up the stairs toward my room, saying \"I'm coming up,\" and only stopped just short of entering. I locked myself in my room and remained there, visibly shaken. I even told her I was recording—for my own safety—though I was not, because I felt that threatened.\n\nI no longer feel safe sharing a living space with her. I am urgently seeking any emergency housing options, protective campus measures, or relevant reporting mechanisms available. I am also requesting that your office formally document this event and advise on next steps, including whether this constitutes a violation of university conduct standards.\n\nPlease let me know how to proceed. I am happy to provide a full written statement or speak further at any time.\n\nSincerely,\nDavid Mullins\n\nFrom: Dr. Adam Wasilko wasilkoa@duq.edu\nDate: Tue, Jul 1, 2025 at 8:49 AM\nTo: David Mullins dntstoplaughing@gmail.com\nCc: Dr. Daniel Selcer selcerd@duq.edu, Faculty A\nSubject: Re: Urgent Safety Concern and Housing Support Request\n\nHi David—\n\nThanks for reaching out. I am sorry you are dealing with this!\n\nAre you looking for on campus housing options in the interim?\n\nYour best option would be to file a police report through our public safety. You can do that by calling 412-396-2677 or by walking into the police station on campus at any time. They are there 24/7. They would then share the report to see if conduct charges were applicable.\n\nI certainly understand that the situation sound unsettling, but it doesn't sound like a code of conduct violation at this point. It is always best to document these things in case they escalate.\n\nDr. W\n\nDr. Adam T. Wasilko\nAssociate Vice President for Student Life\nDean of Students\nDuquesne University\n412-396-6657"
    },
    {
      "id": "B-0A",
      "name": "Gender Reversal Hypothetical",
      "date": "Jul 23, 2025",
      "from": "David Mullins",
      "to": "Dr. Adam Wasilko",
      "type": "Email",
      "text": "EXHIBIT B-0A: GENDER REVERSAL HYPOTHETICAL\nJuly 23, 2025\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Wed, Jul 23, 2025 at 5:39 AM\nTo: Dr. Adam Wasilko <wasilkoa@duq.edu>\nCc: Dr. Daniel Selcer <selcerd@duq.edu>, Faculty A <Faculty A>\nSubject: Re: Safety Concerns Regarding Respondent\n\nDear Dean Wasilko,\n\nRespectfully, I did not file a report with Public Safety because, frankly, I did not trust your guidance. Your initial response minimized a serious and dangerous situation and displayed a fundamental misunderstanding of the student conduct code. I concluded that (1) a formal City of Pittsburgh police report would carry more weight and credibility than a campus safety report, and (2) there is no plausible or good-faith reading of the account I provided in my initial email (quoted in full below) that could justify your conclusion that it \"doesn't sound like a code of conduct violation.\" That language profoundly undermined my confidence in your role as an advocate for student safety and Title IX compliance. In retrospect, I can't help but wonder whether your response would have been the same had the genders in this situation been reversed.\n\nHousing — I didn't respond about housing because I was able to find something temporary, but I'm glad you brought it up again: I may not have a place or the funds for a deposit from the beginning of August until I've received two paychecks in September. If assistance is still available, I would greatly appreciate it.\n\nAll my best,\nDavid"
    },
    {
      "id": "B-1",
      "name": "Simpson Title IX Exchange",
      "date": "Jul 24, 2025",
      "from": "Alicia Simpson",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-1: SIMPSON TITLE IX EXCHANGE\nJuly 24, 2025\n\nFrom: Alicia Simpson <simpsona8@duq.edu>\nDate: Thu, Jul 24, 2025\nTo: David Mullins\nCc: Dr. Wasilko\n\nDear David,\n\nMy name is Alicia Simpson and I am the Title IX Coordinator and Director of Sexual Misconduct Prevention and Response for Duquesne University. Also copied on this email is Dr. Wasilko, as I know you have previously communicated with her regarding your concerns.\n\nMy office is notified when there are reported incidents of alleged sexual harassment or sexual misconduct involving students, faculty and staff. I am in receipt of your email where you allege that there has been noncompliance with Title IX regarding a situation with another student that has caused you to be displaced from your housing. I am sorry to hear of the difficult situation you have been experiencing.\n\nOne of my primary roles is to help ensure your health and safety. The Title IX office provides oversight to the University processes for Title IX sexual harassment and non-Title IX sexual misconduct, and I am here to provide you with support and talk with you about resources on our campus and in the community.\n\nBased on the nature of this report, I would like to meet with you to discuss the report, gather additional information, go over your options under our policies, and discuss any supports or resources you may need. Please reply to this email with your availability if you would like to meet with me.\n\nAt this time, based on the information I have been provided, I do not have enough information to determine whether the appropriate policy to address this report is TAP 31, TAP 61, or our Student Code of Conduct. Once we meet and I am able to gather additional information, I will determine the appropriate policy and let you know.\n\nI look forward to hearing from you.\n\nThank you,\nAlicia\n\nFrom: David Mullins dntstoplaughing@gmail.com\nDate: Thu, Jul 24, 2025 at 1:59 PM\nTo: Alicia Simpson simpsona8@duq.edu\nSubject: Re: Office of Title IX/Sexual Misconduct (Private)\n\nHi Alicia,\n\nThank you very much for your mail. Would it be possible to meet on Zoom at 4:30PM?\n\nAll my best, David\n\n---\n\nFrom: Alicia Simpson simpsona8@duq.edu\nDate: Thu, Jul 24, 2025 at 2:44 PM\nTo: David Mullins dntstoplaughing@gmail.com\nSubject: Re: Office of Title IX/Sexual Misconduct (Private)\n\nHi David,\n\nI am in a hearing the rest of this afternoon, but have availability to meet on Zoom tomorrow.\n\nWould tomorrow sometime between 12pm – 4:30pm work for you?\n\nThank you,\nAlicia\n\n---\n\nFrom: David Mullins dntstoplaughing@gmail.com\nDate: Thu, Jul 24, 2025 at 2:59 PM\nTo: Alicia Simpson simpsona8@duq.edu\nSubject: Re: Office of Title IX/Sexual Misconduct (Private)\n\nHi Alicia,\n\nThank you for offering to meet. I am unable to attend a meeting tomorrow and cannot delay resolution any further.\n\n---\n\nFrom: Alicia Simpson simpsona8@duq.edu\nDate: Thu, Jul 24, 2025 at 3:46 PM\nTo: David Mullins dntstoplaughing@gmail.com\nSubject: Re: Office of Title IX/Sexual Misconduct (Private)\n\nHi David,\n\nMy hearing ended earlier than expected, so I am now available to meet with you via Zoom at 4:30 p.m. Below is the link for the Zoom:\n\n[Zoom meeting details provided]\n\nI look forward to meeting with you shortly.\n\nThank you, Alicia\n\n---\n\nFrom: Alicia Simpson simpsona8@duq.edu\nDate: Thu, Jul 24, 2025 at 4:36 PM\nTo: David Mullins mullinsd@duq.edu\nCc: David Mullins dntstoplaughing@gmail.com\nSubject: Re: Office of Title IX/Sexual Misconduct (Private)\n\nHi David,\n\nI wanted to check to see if you had received my email and were still available and interested with meeting with me. I will remain on the Zoom for another 10 minutes, in the event you are running late.\n\nThank you, Alicia"
    },
    {
      "id": "B-2",
      "name": "Wasilko Meeting Requirement Post Upper Admin Escalation",
      "date": "Jul 25, 2025",
      "from": "Dr. Adam Wasilko",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-2: WASILKO MEETING REQUIREMENT POST UPPER ADMIN ESCALATION\nJuly 25, 2025\n\nFrom: Dr. Adam Wasilko <wasilkoa@duq.edu>\nDate: Fri, Jul 25, 2025 at 4:21 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Dr. Anne Sawa <mullarke@duq.edu>, Alicia Simpson <simpsona8@duq.edu>\n\nDear David,\n\nAs you are aware, I have repeatedly advised you to contact various university offices to discuss your concerns. Several university offices have proactively reached out to you so that they can better understand your concerns and evaluate what, if any, resources or assistance they may be able to provide to you. I strongly encourage you to please engage with these offices.\n\nIn this regard, it is my understanding that Dr. Anne Sawa, Executive Director of Student Conduct, contacted you this week and provided you with a link to her calendar to schedule a meeting. Please make arrangements to meet with her.\n\nIn addition, Title IX Coordinator Alicia Simpson reached out to you on July 24 to schedule a Zoom meeting, but I understand that you have not made arrangements with her yet. Please schedule this meeting.\n\nYou have also been encouraged you to contact Duquesne University Public Safety if you have safety concerns. Please do so if you have such concerns. Their number is: 412-396-6002.\n\nWe cannot assist you or provide you with further guidance unless you are willing to engage with the appropriate offices and give them the opportunity to better understand and discuss your concerns.\n\nDr. Wasilko"
    },
    {
      "id": "B-3",
      "name": "Wasilko Meeting Requirement Post OCR",
      "date": "Jul 28, 2025",
      "from": "Dr. Adam Wasilko",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-3: WASILKO MEETING REQUIREMENT POST OCR\nJuly 28, 2025\n\nFrom: Dr. Adam Wasilko <wasilkoa@duq.edu>\nDate: Mon, Jul 28, 2025\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Dr. Anne Sawa <mullarke@duq.edu>, Alicia Simpson <simpsona8@duq.edu>\n\nDear David,\n\nI am following up on my email sent to you this past Friday. As I indicated, several University offices, including Public Safety, Student Conduct, and the Title IX office, have reached out to you and have asked you to please meet with them. The University cannot assist you unless you engage with the appropriate offices.\n\nIf you would like to meet with representatives from these offices, please reach out to them directly.\n\nDr. Wasilko"
    },
    {
      "id": "B-3A",
      "name": "OCR Escalation and Records Demand",
      "date": "Jul 26, 2025",
      "from": "David Mullins",
      "to": "University President, Senior Leadership, OCR",
      "type": "Email",
      "text": "EXHIBIT B-3A: OCR ESCALATION AND RECORDS DEMAND\nJuly 26, 2025\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nTo: president@duq.edu\nCc: Alicia Simpson <simpsona8@duq.edu>, provost@duq.edu, Faculty A <Faculty A>, Dr. Daniel Selcer <selcerd@duq.edu>, legal@duq.edu, Dr. Adam Wasilko <wasilkoa@duq.edu>, OCR.Atlanta@ed.gov, OCR@ed.gov\nDate: Sat, Jul 26, 2025 at 6:06 AM\nSubject: Title IX Retaliation, Ongoing Housing Crisis—Immediate Referral to Office for Civil Rights (OCR)\n\nDear University President, Senior Leadership, and All Relevant Offices,\n\nI am writing to notify you that effective immediately, I am referring my case to the US Department of Education Office for Civil Rights. This escalation is a direct result of the University's ongoing failure to provide Title IX-mandated protection and the recent act of retaliation and obstruction by Dean Adam Wasilko on July 25, 2025.\n\nSUMMARY OF VIOLATIONS:\n\nFailure to act on a clear Title IX safety threat. My report of stalking, intimidation, and credible fear for my safety by a female roommate was minimized, not referred to appropriate channels, and not investigated as required. I believe this is chiefly because I am male. Had I been female and my roommate male, the response would have been immediate and protective.\n\nOngoing housing insecurity. After fleeing my home on June 30th out of fear for my physical safety, I remain without stable, graduate-appropriate housing as a direct and ongoing result of the University's inaction. As of today, I have less than $40 in my bank account, no permanent housing, and no credible path towards it.\n\nRetaliation and obstruction. After my first demand for immediate remedy (Morning July 24th), Dean Wasilko sent a reply that attempted to deflect, silo, and pressure me into further delay. He removed senior leadership from the CC chain and failed to provide any meaningful resolution. This constitutes ongoing noncompliance and retaliation under Title IX.\n\nComplicity of Administration, Including Local Title IX Office. Since Dean Wasilko's retaliatory email was sent with both the Executive Director of Student Conduct and the Title IX Coordinator on copy, and neither responded with an offer of meeting, remedy, or even acknowledgment, it is now clear to me that the entire infrastructure responsible for student safety and civil rights at Duquesne is complicit in this ongoing abuse.\n\nI REITERATE MY DEMANDS FOR REMEDY:\n- Graduate-appropriate housing or fully funded off-campus housing through Fall 2025, effective immediately\n- Official retroactive Title IX designation for the June 30 incident\n- Written acknowledgment of Title IX and reporting failures by Dean Wasilko\n- Immediate production of all records, reports, and communications related to my case\n- $20,000 in compensation for administrative labor, emotional distress, academic disruption, and housing insecurity\n\nSincerely,\nDavid Mullins"
    },
    {
      "id": "B-5",
      "name": "Simpson Emergency Response",
      "date": "Aug 13, 2025",
      "from": "Alicia Simpson",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-5: SIMPSON EMERGENCY RESPONSE\nAugust 13, 2025\n\nFrom: Alicia Simpson <simpsona8@duq.edu>\nDate: Wed, Aug 13, 2025 at 2:02 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Public Safety Officer A, Public Safety Officer B, Dr. Sawa\n\nDear David,\n\nThank you for providing this information to myself and Public Safety Officer A. Your concerns and allegations warrant further information gathering and review by Public Safety, the Office of Student Conduct, and the Office of Title IX in order to evaluate the situation and determine an appropriate response to your concerns and needs.\n\nTo better understand your allegations, your current situation and assess appropriate next steps, it is necessary for representatives of these offices to meet with you to gather additional information. Additionally, during our meeting, we can discuss your current needs relating to supportive measures and other well-being needs such as your concerns relating to housing and finances.\n\nWhile it is a standard and essential practice to hold meetings following receipt of concerns such as yours, we are willing to streamline the process for you by making myself and representatives from Student Conduct and Public Safety available to meet with you at the same time, either in person or via Zoom. That way, you will not have to arrange multiple meetings or explain your concerns multiple times, and our offices can jointly evaluate and coordinate next steps. We have identified Friday, August 15, at 9:00 a.m. as an available time and are holding that time open for a meeting with you. Please confirm your availability and preference for an in-person or Zoom meeting.\n\nThank you again for bringing this to our attention. We are committed to ensuring a safe and equitable environment for all students.\n\nSincerely,\nAlicia"
    },
    {
      "id": "B-5A",
      "name": "Plaintiff Meeting Refusal & OCR Restoration",
      "date": "Aug 13, 2025",
      "from": "David Mullins",
      "to": "Alicia Simpson",
      "type": "Email",
      "text": "EXHIBIT B-5A: PLAINTIFF MEETING REFUSAL & OCR RESTORATION\nAugust 13, 2025\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Wed, Aug 13, 2025 at 4:20 PM\nTo: Alicia Simpson <simpsona8@duq.edu>\nCc: David Mullins <mullinsd@duq.edu>, Public Safety Officer A <Public Safety Officer A>,\n    Public Safety Officer B <Public Safety Officer B>, Dr. Anne Mullarkey Sawa\n    <mullarke@duq.edu>, OCR@ed.gov, legal@duq.edu, provost@duq.edu,\n    president@duq.edu, Faculty A <Faculty A>,\n    Dr. Daniel Selcer <selcerd@duq.edu>, OCR.Atlanta@ed.gov\n\nTitle IX and Public Safety,\n\nI am not available for meetings (Zoom or otherwise). Please handle this in writing only.\n\nOCR is copied; do not remove OCR, Legal Affairs, senior leadership, Public Safety, or departmental leadership from the CC line going forward.\n\nDeadline\n\nPlease provide written confirmation of Option A or Option B by 5:00 PM ET today (August 13, 2025).\n\nReason for the deadline\n\nGiven the ongoing safety risk, the prior documentation (see Exhibit I), and the fact that supportive measures are administrative directives that can be implemented immediately (email orders to Public Safety/Registrar/Access Control; written notice from Title IX), a 5:00 PM ET deadline is appropriate for a prompt response. If you cannot finalize the full package by 5:00 PM ET, please by 5:00 PM ET: (1) issue the mutual no-contact and no-presence-in-shared-spaces orders, (2) place the Public Safety CAD alert and identify a duty contact, and (3) confirm registrar separation. The remaining items (building-access flags, mailbox reassignment, written risk analysis or emergency-removal notice) should follow within 2 hours.\n\nRegulatory framework (for reference)\n\n  34 C.F.R. \u00a7106.44: respond promptly and not be deliberately indifferent.\n\n  34 C.F.R. \u00a7106.30: supportive measures are non-disciplinary, non-punitive,\n  individualized, offered as appropriate and as reasonably available, without fee or\n  charge, designed to restore or preserve access and protect safety, without\n  unreasonably burdening the other party.\n\n  Coordinator duty: supportive measures are available with or without a formal\n  complaint.\n\n  34 C.F.R. \u00a7106.44(c): emergency removal may follow an individualized safety\n  and risk analysis finding an immediate threat to physical health or safety, with\n  notice and an opportunity to challenge immediately following removal.\n\n  34 C.F.R. \u00a7106.71: retaliation is prohibited.\n\nRequired written action \u2014 today\n\nPlease complete one of the following and confirm in writing by 5:00 PM ET:\n\nOption A \u2014 Emergency removal (physical presence only)\n  1. Issue an emergency physical-presence ban for the respondent from all campus\n     properties and events (remote participation preserved).\n  2. Provide the written individualized safety/risk analysis and the respondent's\n     opportunity-to-challenge language.\n\nOption B \u2014 Full supportive-measures set (implemented now)\n  - Mutual no-contact order.\n  - Space/course separation: registrar-enforced sectioning; Graduate Lounge\n    exclusion; reassigned mailbox/building access.\n  - Public Safety: CAD alert, priority-response protocol, and a named point of\n    contact.\n  - Modality fallback (remote) for me until all measures are live; return to normal\n    in-person access thereafter.\n  - All communications in writing via Title IX (no meetings required).\n\nRecord and notice\n\nI have provided documented proof of homelessness and a negative bank balance and have repeatedly requested supportive measures since June 30. Conditioning supportive measures on additional meetings is inconsistent with the duty to offer and implement them promptly, including with or without a formal complaint. Given the record (see Exhibit I)\u2014including prior removals of OCR, Legal Affairs, and senior leadership from CC\u2014further conditioning or delay is likely to be viewed as retaliatory and will be reported to OCR (cc'd).\n\nDelivery and confirmation\n\nIf you decline emergency removal, please provide the written risk analysis and the complete list of supportive measures implemented today. Send same-day written confirmation of Option A or Option B to all parties on this thread, including OCR, Legal Affairs, senior leadership, Public Safety, the DGS, and the Department Chair.\n\n\u2014 David Mullins\n\nAttachments / references:\n  Exhibit I \u2014 Meetings Record & Administrative Non-Response (timeframe now\n  extended through Aug. 13, 2025).\n  Exhibit I \u2014 Meetings Record & Administrative Non-Response-1.pdf  108K"
    },
    {
      "id": "B-6",
      "name": "Simpson Jurisdiction Disclaimer",
      "date": "Aug 14, 2025",
      "from": "Alicia Simpson",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-6: SIMPSON JURISDICTION DISCLAIMER\nAugust 14, 2025\n\nFrom: Alicia Simpson <simpsona8@duq.edu>\nDate: Thu, Aug 14, 2025 at 9:42 AM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Public Safety Officer A, Public Safety Officer B, Dr. Sawa\n\nDear David,\n\nThe Title IX, Student Conduct, and Public Safety procedures all involve a request for a meeting so that we are able to ensure that we have gathered all relevant information prior to determining the appropriate University policy and/or process to address a reported concern. I understand that at this time, you are unwilling to meet with us to discuss the report and your concerns. Without a meeting, I am limited to reviewing the information you provided in order to make a preliminary determination, outlined below, regarding the Title IX Office's jurisdiction over the reported situation.\n\nThe Title IX Office is solely responsible for addressing reports of alleged violations of the University's Title IX (TAP 61) policy and the University's non-Title IX sexual misconduct (TAP 31) policy. Reported matters that are outside the scope of TAP 61 or TAP 31, will not be addressed by my office and will instead be referred to the appropriate University department.\n\nWith regard to your reported allegations against your former roommate, Respondent, based on a review of the information you have provided, I have determined that the reported alleged conduct does not meet TAP 61, nor TAP 31's definitions of prohibited conduct, even if proven to be true. Therefore, based on information provided by you at this time, the Title IX Office does not have jurisdiction over your report and cannot take action or provide assistance as requested.\n\nIf you wish to pursue allegations of disparate treatment sex discrimination against Dr. Adam Wasilko, those allegations also are outside the jurisdiction of the policies (TAP 61 and TAP 31) administered by the Title IX Office. Instead, I would refer you to TAP 30, which establishes the University's policy prohibiting unlawful discrimination in the classroom and workplace.\n\nMy determinations are based on the information provided by you as of today's date and are subject to change upon receipt of additional information that alleges violations of our TAP 61 or TAP 31 policies. Accordingly, I remain available to meet with you should you wish to do so in the future.\n\nSincerely,\nAlicia"
    },
    {
      "id": "B-7",
      "name": "Sawa Retaliation Threat",
      "date": "Aug 15, 2025",
      "from": "Dr. Anne Sawa",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT B-7: SAWA RETALIATION THREAT\nAugust 15, 2025\n\nFrom: Dr. Anne Mullarkey Sawa <mullarke@duq.edu>\nDate: Fri, Aug 15, 2025 at 8:00 AM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Public Safety Officer A, Public Safety Officer B\n\nHello David,\n\nAs you know from previous correspondence including my outreach on July 21, 2025, I am the Executive Director of Student Conduct.\n\nThis is to reconfirm that in order to initiate the student conduct process related to your concerns about Respondent, we would need to meet either in person or via Zoom for you to provide additional details as well as to discuss if and how you want to move forward with the conduct process, and your level of involvement. Please feel free to review the Student Handbook, particularly Article XIII, The Code of Students' Rights, Responsibilities, and Conduct, for more information on the Formal and Informal Conduct processes.\n\nI understand that you are refusing to meet. Please understand that if you wish to pursue claims that Respondent violated the Code of Conduct and wish to seek related relief, then please visit my calendar to schedule a time to meet in the next few days. Otherwise, the Office of Student Conduct will not consider your allegations, and you must stop emailing me.\n\nIn addition, as the Executive Director of Student Conduct, I am providing you with notice that you must stop sending mass emails to University officials and offices about your concerns. You have been provided with the appropriate campus contacts to assist you in navigating your concerns and needs. They cannot assist you unless you adhere to and cooperate with their processes and procedures, including meetings. To be clear, if you want assistance from the University, you are expected to communicate directly with the resources offered to you and to do so in a respectful and civil manner. Failure to do so may result in charges against you for violating the Student Code of Conduct.\n\nI hope you will move forward with making an appointment with me and directly engaging with the other contacts that you have been provided so that we may better understand your concerns and provide you with assistance.\n\nSincerely,\nAnnie"
    },
    {
      "id": "C",
      "name": "External Faculty Witness Academic Expert Declarations",
      "date": "Sep 30 & Oct 1, 2025",
      "from": "External Faculty Witness",
      "to": null,
      "type": "Other",
      "text": "EXHIBIT C\n\nExternal Faculty Witness Academic Expert Declarations\n\nDate: Sept 30 & Oct 1, 2025\nType: Expert Declaration\nPages: 4\nSource: External Faculty Witness\n\nAUTHENTICATION\n\nI hereby certify that this exhibit is a true and correct copy of the original declarations and supporting communications from External Faculty Witness and is offered as evidence in support of Plaintiff's motion.\n\n/s/ David Michael Mullins\n\nDavid Michael Mullins, Pro Se\nPhD Candidate, Department of Philosophy\nDuquesne University\n\nEXHIBIT C: EXTERNAL FACULTY WITNESS ACADEMIC EXPERT DECLARATIONS\nSeptember 30 & October 1, 2025\n\nDECLARATION OF EXTERNAL FACULTY WITNESS\n\nI, External Faculty Witness, pursuant to 28 U.S.C. \u00a7 1746, declare under penalty of perjury:\n\n1. I am a Professor of Political Science at the University of Hawai'i at Manoa and have long served as an academic mentor to David Mullins.\n\n2. Based on my knowledge of David's academic work and communications, his education and research have been severely derailed by his housing instability and the conflict with his former roommate.\n\n3. In my opinion, supportive housing and protective measures are necessary for him to resume his academic work.\n\nExecuted on 9-30-2025.\n\nExternal Faculty Witness\nProfessor, Department of Political Science\nDirector, University of Hawai'i Research Center for Futures Studies\nThe University of Hawai'i at Manoa\n\nSUPPLEMENTAL DECLARATION OF EXTERNAL FACULTY WITNESS\nRE: SEPTEMBER 17, 2025 CONVERSATIONS WITH DAVID MULLINS\n\nBACKGROUND AND RELATIONSHIP\n\n1. I previously submitted a declaration on September 30, 2025, regarding the severe educational harm David Mullins has suffered due to housing instability and lack of university support.\n\n2. In addition to my role as David's academic mentor, I am also a personal friend and someone David contacts regarding both academic matters and significant personal events affecting his studies.\n\nDAVID'S PRIOR EXPRESSIONS OF FEAR\n\n1. In conversations prior to September 17, 2025, David had explained to me his fear of encountering his former roommate, Respondent, on campus.\n\n2. He described the June 30, 2025 incident where Respondent pursued him to his bedroom after he stated he didn't feel safe, and his ongoing anxiety about encountering her without protective measures in place.\n\n3. David had expressed frustration that university officials were forcing his in-person return beginning September 15, 2025, without implementing any protective measures such as no-contact orders or registrar-enforced separation.\n\n4. He specifically warned that he feared encountering Respondent in academic spaces and that such encounters would cause severe distress and prevent his educational participation.\n\nSEPTEMBER 17, 2025 INITIAL CONTACT\n\n1. On September 17, 2025, at approximately 6:51 p.m., David contacted me via Facebook Messenger.\n\n2. David reported that Respondent had been waiting outside his Philosophy seminar classroom.\n\nMY FOLLOW-UP AND DAVID'S RESPONSE\n\n1. Recognizing the significance of this encounter given David's prior expressed fears, I asked him how he was doing.\n\n2. Several hours later, David responded \"better now.\"\n\n3. David's delayed response and the content of his message (\"better now\" rather than \"I'm fine\") made me concerned that the encounter had been more serious than his initial brief report suggested.\n\nMY ASSESSMENT BASED ON THESE CONVERSATIONS\n\n1. As someone who has known David in both academic and personal contexts for 19 years, I understood this communication pattern to reflect genuine distress.\n\n2. This incident is directly related to the educational harm I described in my September 30 declaration: David cannot focus on his PhD research when he is experiencing encounters that cause this level of distress and require hours of recovery time.\n\nAUTHENTICATION OF FACEBOOK MESSAGES\n\n1. I have reviewed the Facebook Messenger screenshots attached as Exhibit C and confirm they accurately reflect the conversations David and I had on September 17, 2025.\n\n2. The timestamps shown in those screenshots correspond to my recollection of when David initially contacted me and when he responded to my follow-up inquiry.\n\nI declare under penalty of perjury that the foregoing is true and correct.\n\nExecuted on October 1st, 2025, in Huntsville, Alabama.\n\nExternal Faculty Witness, PhD\nProfessor of Political Science\nUniversity of Hawai'i at M\u0101noa\n\n\nFACEBOOK MESSENGER CONVERSATION\n\nSEPTEMBER 17, 2025\n\nConversation between David Mullins and External Faculty Witness\n\nSeptember 17, 2025, 6:51 PM\n\nDavid: Respondent literally waiting outside of second class im in person\n\nSeptember 17, 2025, 7:42 PM\n\nProfessor External Faculty Witness: Ack how are you feeling?\n\nSeptember 17, 2025, 9:11 PM\n\nDavid: better now\n\nAUTHENTICATION\n\nI, David Michael Mullins, declare under penalty of perjury that the above conversation accurately reflects the Facebook Messenger exchange between External Faculty Witness and myself on September 17, 2025, regarding my encounter with Respondent outside my Philosophy seminar classroom.\n\n/s/ David Michael Mullins\n\nDavid Michael Mullins, Pro Se"
    },
    {
      "id": "D",
      "name": "Signal Transcript & Timeline",
      "date": "Jun 23\u201330, 2025",
      "from": "David Mullins, Respondent",
      "to": null,
      "type": "Transcript",
      "text": "EXHIBIT D: SIGNAL TRANSCRIPT & TIMELINE\nJune 23-30, 2025\n\nTIMELINE SUMMARY:\n\nJune 2 \u2013 Move-in at [street address] with co-tenant Respondent.\n\nJune 13\u201316 \u2013 Respondent initiates repeated discussions about A/C use ahead of the upcoming heat wave, asking multiple times if setting the thermostat to 78\u00b0F is acceptable and if Mullins is comfortable with the cost. Mullins agrees and says comfort is the priority.\n\nJune 19\u201320 \u2013 Heatwave begins. Temperature in Mullins' bedroom and office rises to the high 80s, peaking at 90\u00b0F. Mullins raises concerns about being unable to work or sleep due to heat and dehydration. Respondent claims the A/C cannot cool the house further, citing poor insulation, high outside temperature, risk of malfunction if set lower, cost, risk of power blackouts, and her prior experience. Mullins requests clarification; Respondent confirms that lowering the thermostat would not be effective.\n\nJune 21\u201325 \u2013 Mullins repeatedly communicates ongoing heat distress; Respondent suggests drinking more water or Gatorade.\n\nJune 25 \u2013 Respondent requests lowering the A/C for her own comfort. The apartment immediately becomes livable at the new setting. She offers no comment regarding her previous claims.\n\nJune 26 \u2013 Mullins raises concerns about the inconsistency in a Signal chat, states that the A/C will remain on, and insists on transparency regarding the utility bill and an end to further manipulation. Respondent requests an in-person meeting; Mullins does not respond, preferring written communication. He ceases all direct in-person contact.\n\nJune 27 \u2013 Respondent locks Mullins out of the apartment. Upon return, Mullins is let in by Respondent and tells her directly not to lock him out again. He then walks upstairs, makes it clear he does not want to discuss it further, and thanks her for not locking him out again.\n\nJune 28\u201330 \u2013 Landlord refuses to enforce the lease, characterizing the issue as a \"roommate communication\" problem. Respondent continues avoidance.\n\nJune 30 \u2013 After consulting legal counsel, Landlord warns Respondent regarding the lockout and A/C manipulation. That evening, Respondent confronts Mullins in the kitchen, positioning herself as close as possible to him and maintaining this proximity as he attempts to leave for the stairs. She is visibly upset, yelling and using obscenities, and focuses her anger on Mullins's decision to go to the landlord. As Mullins moves toward the stairs, she continues to follow. In the living room, Mullins turns and asks if she is following him, and she confirms that she is. He continues toward his room, and she explicitly says she is coming up to his room. Mullins then goes into his room, locks the door, and notifies the landlord, deans, department chair, and DGS by email. Respondent stops partway up the stairs. Mullins blocks Respondent on Signal.\n\nJuly 1 \u2013 Mullins moves out with a friend's assistance, is harassed by Respondent throughout.\n\nJuly 2 \u2013 Mullins files a police report."
    },
    {
      "id": "F",
      "name": "Medical Documentation – Treating Physician",
      "date": "Aug 13 & Oct 1, 2025",
      "from": "Treating Physician",
      "to": null,
      "type": "Medical Letter",
      "text": "EXHIBIT F: MEDICAL DOCUMENTATION – TREATING PHYSICIAN\nAugust 13 & October 1, 2025\n\nMEDICAL LETTER 1 – AUGUST 13, 2025\n\nTreating Physician, DO\nPrivate Pay Psychiatry and Psychotherapy\n\nTo Whom It May Concern,\n\nI am a physician treating David Mullins. He's informed me he does not feel safe around a specific individual on campus, and from what he's described to me, I believe its reasonable for him to have this fear. I have advised him to involve law enforcement for his protection in response to this reasonable fear. To share a living space with this individual would cause him a great deal of stress, would be highly likely to worsen his medical condition, and could impair his academic functioning. I recommend every effort be made to avoid this.\n\nSincerely,\nTreating Physician, DO\n8/13/2025\n[office address]\nPittsburgh, PA 15206\n[phone]\n\nMEDICAL LETTER 2 – OCTOBER 1, 2025\n\nTreating Physician, DO\nPsychiatry\n\nTo whom it may concern,\n\nI am a Doctor of Osteopathic medicine treating David Mullins. He's asked me to state some facts of his medical case, which I've written and attest to below. I have diagnosed David with ADHD and depression. I am treating those conditions. In September of 2025 he reported to me he ran out of lexapro earlier than planned. At the time he said this was due to proximity to his abuser and he recently clarified he was taking more than prescribed. He reports homelessness since June 30th which has been very stressful and likely worsens his mental health conditions. Worsening his mental health conditions is expected to negatively impact his graduate education. I recommend all measures to protect him from his abuser and to provide stable housing be made. This will benefit and protect his mental health and his performance in his graduate program.\n\nSincerely,\nTreating Physician, DO\n10/01/2025\n[office address]\nPittsburgh, PA 15206\n[phone]"
    },
    {
      "id": "Y",
      "name": "Faculty Handbook Course Modality Provision",
      "date": "2025-2026",
      "from": null,
      "to": null,
      "type": "Policy Document",
      "text": "Department chairs are responsible for making teaching assignments and ensuring that courses are taught by qualified faculty. They oversee the delivery of curricula and confirm that faculty administer their assigned courses as planned. For accreditation and other academic reasons, courses designed to be offered in-person must be taught in-person (other than on rare, one-off occasions). Similarly, faculty assigned to teach online courses cannot require on-campus sessions. Faculty members do not have the latitude to switch courses to an alternative format or modality to suit their personal needs or preferences."
    },
    {
      "id": "G",
      "name": "Wasilko Housing Denial",
      "date": "Jul 24, 2025",
      "from": "Dr. Adam Wasilko",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT G: WASILKO HOUSING DENIAL\nJuly 24, 2025\n\nFrom: Dr. Adam Wasilko <wasilkoa@duq.edu>\nDate: Thu, Jul 24, 2025 at 9:35 AM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Dr. Daniel Selcer <selcerd@duq.edu>, Faculty A <Faculty A>, Dr. Anne Sawa <mullarke@duq.edu>\n\nDear David,\n\nI heard back from housing, and it looks like right now the only rooms we have are in the first year buildings. Obviously, that is not helpful at this juncture. However, we will continue to work on this and see if we can find something.\n\nPlease do follow up with Dr. Sawa to file a report.\n\nBest,\nDr. W\n\nDr. Adam T. Wasilko\nAssociate Vice President for Student Life\nDean of Students\nDuquesne University\n412-396-6657"
    },
    {
      "id": "I",
      "name": "Selcer Meeting Exchange",
      "date": "Aug 25, 2025",
      "from": "Dr. Daniel Selcer",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT I: SELCER MEETING EXCHANGE\nAugust 25, 2025\n\nFrom: Dr. Daniel Selcer <selcerd@duq.edu>\nDate: Mon, Aug 25, 2025 at 11:48 AM\nTo: David Mullins <mullinsd@duq.edu>\nCc: Dr. Kristine Blair <blairk2@duq.edu>, Faculty A <Faculty A>\n\nDear David,\n\nThank you for meeting with me and Faculty A last Thursday via Zoom.\n\nYou explained that you are housing insecure, and that your first priority is to find housing. You indicated the department community has been supportive and that people have offered to give you a place to stay if you cannot find anything. We hope you are continuing to make progress on this front.\n\nYou also shared that your second priority is to be back physically in the classroom. We explained that the expectation in our program is that seminar participation is in-person, and that TA responsibilities require presence in class.\n\nYou said that you want to have particular safety measures in place before you will come on campus. You explained that you do not feel safe on campus because you fear Respondent. You confided that you feel physically intimidated by her, and that you believe she has an unregistered firearm.\n\nYou categorized the safety measures that you want as: 1. A no-contact order; 2. A campus safety order (a public safety escort when you arrive on campus), and 3. Registrar separation.\n\nWe explained that the Philosophy Department could not issue the orders that you are requesting, and that you would need to follow the procedures of the potentially relevant university offices (Title IX, Student Conduct, and Public Safety) in order to seek these measures.\n\nIn the meantime, as remote TA work is not viable and at this point and you are not willing to come to campus, I am reassigning you for the FA25 semester to Faculty B, for whom you will work virtually as a Research Assistant. Your duties will be outlined in a subsequent communication. This remote work for your stipend is permitted during the FA25 semester only - in SP26 you will again be assigned as a TA and expected to attend the class in which you work in person.\n\nYou are also temporarily authorized to remotely attend the two classes in which you are enrolled this semester - the Graduate Teaching Seminar and Marion & Phenomenology. This is possible only because they are two of the very few graduate classes we are running this semester in which room and class size permits remote participation.\n\nThis remote seminar attendance for these FA25 classes is authorized only for the first three weeks of class at this time. It is also authorized subject to the condition that you fully engage with the Title IX, Student Conduct, and Public Safety offices within the next week and beyond, consistent with their prior instructions to you regarding next steps. If you are requesting a medical accommodation, it is also conditioned on you fully engaging with the Disability Services Office consistent with their processes.\n\nAll my best,\nDan\n\n---\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Mon, Aug 25, 2025 at 10:06 PM\nTo: Dr. Daniel Selcer <selcerd@duq.edu>\nCc: David Mullins <mullinsd@duq.edu>, Faculty A <Faculty A>, Dr. Kristine Blair <blairk2@duq.edu>, OCR.Atlanta@ed.gov\n\nDear Dan,\n\nI want to begin by noting that I have tried very hard to engage Duquesne's processes in good faith. But at the end of the day, the law is clear: federal obligations take precedence over internal procedures.\n\nFirst, supportive measures are my right under Title IX and ADA, not contingent on my compliance with further \"process.\" I have already engaged extensively in writing, provided documentation including a physician's letter, sworn statement from me and an eyewitness, and escalated to OCR oversight.\n\nSecond, the three-week limit you have placed on remote participation is neither neutral nor legitimate. It acknowledges that accommodations are feasible but withholds them as a temporary concession, creating yet another crisis point after months of ongoing crisis.\n\nThird, I want to emphasize that I have never refused to come to campus. My consistent position is that I am able and willing to attend in person if appropriate safety measures are implemented.\n\nFourth, the measures I requested, a no-contact directive, registrar separation, and a campus safety escort, are baseline supportive measures under Title IX. They are non-punitive and designed solely to preserve access.\n\nFifth, your summary omits the fact that the Title IX Office informed me in writing that \"the Title IX Office does not have jurisdiction over your report and cannot take action or provide assistance as requested.\" This determination was issued without any legal basis.\n\nSixth, your summary also omits that the head of Student Conduct threatened me that if I continued emailing University officials about my safety and access, she would initiate conduct charges against me. I immediately identified this as retaliatory under 34 C.F.R. §106.71.\n\nI am also CC'ing OCR on this communication and ask that they be included on all further correspondence regarding this matter.\n\nSincerely,\nDavid Michael Mullins"
    },
    {
      "id": "I-1",
      "name": "Mullins Demands Retraction of Retaliatory Zoom Countdown",
      "date": "Sep 2, 2025",
      "from": "David Mullins",
      "to": "Dr. Daniel Selcer",
      "type": "Email",
      "text": "EXHIBIT I-1: MULLINS DEMANDS RETRACTION OF RETALIATORY ZOOM COUNTDOWN\nSeptember 2, 2025\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nTo: Dr. Daniel Selcer <selcerd@duq.edu>\nCC: David Mullins <mullinsd@duq.edu>, Faculty A <Faculty A>, Dr. Kristine Blair <blairk2@duq.edu>, OCR.Atlanta@ed.gov\nDate: Sep 2, 2025, 2:59 AM\nSubject: Re: follow up to 8/21/25 meeting\n\nDear Dan,\n\nI have received no clarity or response to my correction of the record. I wish to reiterate two central points:\n\n1. Remote access is not a choice and does not fulfill the University's obligations.\n\nWhile I am grateful to have Zoom access at present, it does not resolve the core failure: I remain denied meaningful contact with colleagues and faculty in person, use of departmental offices, and access to the library. These are all integral to my education. My in-person access is not a matter of preference but of institutional denial: it is the administration's refusal to provide basic safety measures that has foreclosed my ability to participate in campus life. Title IX and ADA require supportive measures regardless of jurisdictional findings or dismissal of a complaint. The philosophy department cannot unilaterally provide these measures; only central administration can. But at a minimum, the department could have avoided retaliating against me—and could retract that retaliatory posture now.\n\n2. The \"countdown\" limitation on Zoom is retaliatory and unlawful.\n\nThe imposition of a three-week cap is not a supportive measure at all. It is a countdown clock designed to coerce compliance or force attrition, a textbook example of retaliation masquerading as accommodation. Federal regulations are explicit:\n\n• §106.44(g)(2): \"No punitive or disciplinary measures.\"\n• §106.44(g)(4): \"Right to seek impartial review of supportive measure decisions.\"\n\nThe threat itself is harmful. Every day the countdown remains, I have to wonder whether my access will suddenly be cut off. By its own terms, the threat suggests I have already \"violated\" the condition, since I cannot and will not \"re-enter\" a process that has threatened and abandoned me. This leaves me opening my inbox uncertain whether I will be forced back to campus against medical directives, destabilizing my education and health.\n\nThe department must commit to my right to safe access to education. In practice, this means securing my Zoom access indefinitely until central administration addresses my safety concerns. Anything less leaves my access contingent, uncertain, and retaliatory. Even if central administration do not do so until forced to by OCR, the department's federal obligation to protect my access remains. If this results in my being on Zoom for too long, that is unfortunate for me but is the fault of central administration. The department can still show it is more concerned with rights, federal compliance, and my safety than with the looming threat of accidentally setting a remote access precedent for the program.\n\nIf the department does not intend to follow through on this retaliatory threat but leaves it in place, then it is inflicting harm pointlessly: every day the threat remains live, I must anticipate being cut off. If the department does intend to follow through, then it is openly retaliating — and must, at minimum, provide me the impartial review required under §106.44(g)(4).\n\nNo precedent is set here — remote access is a remedial measure in a singular case of Title IX and ADA failure. And of course, any worry about precedent is no alibi for federal noncompliance: the department's fear is not just cruel in its consequences but a massive source of liability.\n\nAccordingly:\n• The three-week limit is facially retaliatory and must be retracted.\n• Even if it is not retracted, I must be given the opportunity to challenge any termination of my Zoom access before an impartial decision-maker, as the statute requires.\n\nSincerely,\nDavid Michael Mullins"
    },
    {
      "id": "J",
      "name": "Selcer Final Directive",
      "date": "Sep 3, 2025",
      "from": "Dr. Daniel Selcer",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT J: SELCER FINAL DIRECTIVE\nSeptember 3, 2025\n\nFrom: Dr. Daniel Selcer <selcerd@duq.edu>\nDate: Wed, Sep 3, 2025 at 6:00 PM\nTo: David Mullins <mullinsd@duq.edu>\n\nDear David,\n\nAs I know you are aware, you are welcome to attend your seminars in person at any time.\n\nI did not reply to your email of August 25 because the instructions I provided in my message of the same date were already clear and not a request for dialogue: You are expected to follow up with and participate in the relevant processes with Title IX, Student Conduct, and Public Safety or to drop your requests for accommodation and return to in-person attendance. If you are now also seeking a medical accommodation, you must file for it through Disability Services consistent with the procedure described in TAP No. 56 (Requests for Reasonable Accommodations for Disabilities) and register through the Disability Services form.\n\nYou have not yet engaged as instructed with the University offices that could potentially assist you as my August 25 email made it clear you needed to do. I also authorized three weeks of remote seminar attendance subject to the condition that you fully engage the Title IX, Student Conduct, and Public Safety offices within the week. It does not appear that you have done anything since my August 25 email to fully engage with these offices consistent with their prior instructions and attempts at outreach, such as arranging meetings for representatives to talk with you. I suggest that you closely review all the communications that you have received from various offices, including those you received on August 15, and follow the instructions you were provided. This is my final directive to do so. Until September 12, you may continue to attend your seminars via Zoom if you wish.\n\nRepresentatives of these offices will determine whether any continued measures – including remote seminar attendance after September 12 – or other actions are warranted. If they determine that they are, they will implement those accommodations or actions directly and/or notify the Philosophy Department if something is required on our part. Otherwise, we expect you to attend seminars in person from September 15 forward.\n\nSincerely,\nDan Selcer"
    },
    {
      "id": "K-1",
      "name": "Mullins Conflict Disclosure to Dean Blair",
      "date": "Oct 20, 2025",
      "from": "David Mullins",
      "to": "Dean Kristine Blair",
      "type": "Email",
      "text": "EXHIBIT K-1: MULLINS CONFLICT DISCLOSURE TO DEAN BLAIR\nOctober 20, 2025, 10:10 AM\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Sun, Oct 20, 2025 at 10:10 AM\nTo: Dr. Kristine Blair <blairk2@duq.edu>\nSubject: [External] Conflict of Interest \u2013 Required Teaching Seminar\n\nDear Dr. Blair,\n\nI hope you\u2019re having a good fall break.\n\nI wanted to make you aware of a conflict of interest affecting my required Ph.D. teaching seminar. The course is taught by Professor Dan Selcer, who is a named defendant in my ongoing federal civil case against Duquesne University. Because participation in this seminar is required for the Ph.D. program and involves discussion of Title IX compliance, I do not believe it\u2019s appropriate for me to remain enrolled under his instruction.\n\nCould you please advise on a way to fulfill this requirement through an alternate instructor or equivalent course? Until this is resolved, I\u2019ll refrain from attending to avoid any appearance of impropriety or further conflict.\n\nThank you very much for your understanding and guidance.\n\nBest regards,\nDavid Michael Mullins"
    },
    {
      "id": "K-2",
      "name": "Blair Consults Selcer and Announces Joint Determination",
      "date": "Oct 22, 2025",
      "from": "Dean Kristine Blair",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT K-2: BLAIR CONSULTS SELCER AND ANNOUNCES JOINT DETERMINATION\nOctober 22, 2025, 8:35 AM\n\nFrom: Dr. Kristine Blair <blairk2@duq.edu>\nDate: Wed, Oct 22, 2025 at 8:35 AM\nTo: David Mullins <dntstoplaughing@gmail.com>\nSubject: Re: [External] Conflict of Interest \u2013 Required Teaching Seminar\n\nDear David:\n\nI hope you have had a restful Fall Break. In preparing my response to your query, I did need to consult Dr. Selcer as instructor to secure some additional details.\n\nBoth Dr. Selcer and I strongly concur that it is appropriate for you to remain enrolled in your required teaching seminar, which is only being taught by Dr. Selcer this semester. Dr. Selcer is committed to providing you with the same consideration and opportunities as any other student. He also will meet with you so that you can catch up on missed content on days that you were absent, and Director of Graduate Studies Faculty A will attend these meetings to the extent her schedule permits.\n\nThus, you should return to class today in order to complete the course with a passing grade, a requirement for your ability to teach in Fall 2026. Dr. Selcer reports that you have attended the course on three occasions (8/27, 9/3, and 9/17) and will not pass should you not resume attendance. In addition, here are the other required conditions impacting your standing in the course:\n\n1. Schedule times to meet with Dr. Selcer to review missed content on days that you were absent\n2. Complete all readings and submit all missing prompts where required\n3. Plan to complete your syllabus draft, critique, and revision, including meeting with Dr. Selcer to review your syllabus revision\n4. Deliver your teaching demo\n\nDr. Selcer is able to work with you on these requirements to foster your success in the course. Should you choose to withdraw from the course, do note that you would be required to re-enroll in Fall 2026 along with your concurrent teaching assignment, and would be required to complete, based on the cohort model, all activities for GTS1 and GTS2.\n\nSincerely,\nKris Blair, Dean"
    },
    {
      "id": "K-5",
      "name": "Blair Denies TAP 33 Applicability",
      "date": "Oct 22, 2025",
      "from": "Dean Kristine Blair",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT K-5: BLAIR DENIES TAP 33 APPLICABILITY, COPIES STAFF E\nOctober 22, 2025, 2:20 PM\n\nFrom: Dr. Kristine Blair <blairk2@duq.edu>\nDate: Wed, Oct 22, 2025 at 2:20 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Staff E <Staff E>\n\nDear David,\n\nPlease be advised that TAP 33 does not apply to this situation. First, as a student, you are not a \\\"Covered Party\\\" as defined by TAP 33. Second, the scenario, including Dr. Selcer continuing to serve as your instructor, does not fall within the limited definition of a \\\"Conflict of Interest\\\" in TAP 33.\n\nAs such, there is no change to the email that I sent to you this morning at 8:35 a.m.\n\nSincerely,\nKris Blair"
    },
    {
      "id": "N",
      "name": "Faculty D Syllabus/Policy (Anyone Can Zoom)",
      "date": "Spring 2025",
      "from": null,
      "to": null,
      "type": "Policy Document",
      "text": "EXHIBIT N: FACULTY D SYLLABUS/POLICY (ANYONE CAN ZOOM)\nPHIL 520\u2013420W \u2013 Religious Platonism\nSpring 2025 Semester\n\nCOURSE INFORMATION:\nPHIL 520\u2013420W \u2013 T 3:05\u20135:45pm \u2013 CH324\nFACULTY D OFFICE HOURS: T 1-3pm \u2013 CH 328\n\nATTENDANCE POLICY (KEY ZOOM PROVISION):\nSince this class meets only once a week, you should plan to attend every class. Although we will meet in person, I will also keep a Zoom meeting running, so if you are not feeling well, please attend that session remotely! If you need to attend a session remotely, please email me ahead of time to let me know. If there is more than one week when you are not present in some form (in-person or remotely), you will need to write up a minimum 700 word paper discussing something from the text for the week you were absent, or lose one-third of a letter grade on your course grade. The paper is due within seven days of the day you are absent.\n\nCOURSE DESCRIPTION:\nWe will look at the aesthetic, ethical, and metaphysical consequences generated by the irruption of popular religion into the Greek philosophical tradition, such that philosophers came to be regarded as saints. We will begin with Porphyry\u2019s embrace of popular religion as analogous to philosophy, his canonization of his teacher Plotinus, and his dialogue with Iamblichus, who in turn systematized the analogy between philosophy and popular religious practice. We will then spend most of the term on the restless fourth- and fifth-century Neoplatonist Augustine, focusing particularly on his great psychological treatise, the Confessions, and his primary hermeneutical treatise, On Christian Teaching.\n\nREQUIRED TEXTS:\nNeoplatonic Philosophy: Introductory Readings, edited by John Dillon and Lloyd P. Gerson (Hackett, 2004); Saint Augustine, Confessions, trans. Henry Chadwick (Oxford University Press, 1992). Saint Augustine, On Christian Teaching, trans. R.P.H. Green (Oxford University Press, 2008 [1997]).\n\nPRESENTATIONS:\nEach graduate student will sign up for one five-minute presentation on anything covered in class the previous week. The presentation will be based on (but will not consist in simply reading) a paper of 1000\u20132000 words (including footnotes) submitted to the Canvas site by midnight Sunday night. Together your paper, presentation, and questions for other presenters constitute 30% of your course grade.\n\nTERM PAPER:\nThe term paper, due before midnight on 4/30, should be no less than 5000 words in length for graduate students, have a strong thesis, and (for graduate students) make use of relevant secondary literature. The paper should not have a bibliography. All citations should be in Chicago style footnotes. Your term paper constitutes 70% of your course grade.\n\nACADEMIC INTEGRITY:\nPlagiarism\u2014including quoting or nearly quoting someone else\u2019s words without acknowledgment, or using an artificial intelligence program to compose portions of your work for you\u2014will result in a failing grade for the course.\n\nSCHEDULE:\n1/13 Religious Platonism          3/10 Conf., Bks. 1-3\n1/20 Neopl. Phil., 1-12, 18-49    3/17 Conf., Bks. 4-6\n1/27 Neopl. Phil., 56-83, 105-121 3/24 Conf., Bks. 7-9\n2/3  Neopl. Phil., 122-159        3/31 Conf., Bks. 10-11\n2/10 Neopl. Phil., 178-220        4/7  NO CLASS\n2/17 Neopl. Phil., 221-263        4/14 Conf., Bks. 12-13\n2/24 On C. Teach., Bk. 1          4/21 On C. Teach., Bk. 2\n3/3  NO CLASS                     4/28 On C. Teach., Bk. 3"
    },
    {
      "id": "P",
      "name": "Title IX Policy Appendix C",
      "date": null,
      "from": null,
      "to": null,
      "type": "Policy Document",
      "text": "EXHIBIT P: TITLE IX POLICY APPENDIX C (CONTACT INFO & RESPONSIBILITIES)\n\nAPPENDIX C: TITLE IX SEXUAL HARASSMENT & SEXUAL MISCONDUCT\n\nREPORTING\n\nAny person may make a non-confidential report of sex discrimination, including sexual harassment (whether or not the person reporting is the person alleged to be the victim of conduct that could constitute sex discrimination or sexual harassment), in person, by mail, by telephone, or by electronic mail, using the contact information listed for the Title IX Coordinator, or by any other means that results in the Title IX Coordinator receiving the person's verbal or written report. Such a report may be made at any time (including during non-business hours) by using the telephone number or electronic mail address, or by mail to the office address, listed for the Title IX Coordinator below. Contact information for Title IX Deputies is also included below:\n\nTITLE IX COORDINATOR AND DIRECTOR OF SEXUAL MISCONDUCT PREVENTION AND RESPONSE\n\nAlicia Simpson, JD\n412.396.2560\nsimpsona8@duq.edu\nOffice: Union #339\nAddress: Duquesne University\nUnion #339\n600 Forbes Avenue\nPittsburgh, PA, 15282\n\nDEPUTY TITLE IX AND SEXUAL MISCONDUCT PREVENTION AND RESPONSE COORDINATORS\n\nStaff A (Athletics) 412.396.5243 \u2013 Business Hours\nStaff B (Human Resources) 412.396.5881 - Business Hours\nAnnie Mullarkey Sawa (Student Conduct) 412.396.6642 - Business Hours\nStaff C (Nursing) 412.396.6551 - Business Hours\nStaff D (Disability Services) 412.396.6658 \u2013 Business Hours\n\nNON-DISCRIMINATION AND TITLE IX\n\nDuquesne University does not discriminate on the basis of sex in the education program or activity that it operates. Duquesne University is required by Title IX and its implementing regulations not to discriminate in such a manner. The requirement not to discriminate in the education program or activity extends to admission and employment. Inquiries about the application of Title IX to Duquesne University may be referred to the Title IX Coordinator, to the Assistant Secretary for Civil Rights at the United States Department of Education Office for Civil Rights, or both.\n\nAdditional information, including relevant policy information is included on the Title IX website at duq.edu/titleix"
    },
    {
      "id": "Q",
      "name": "Zoom Removal Sequence",
      "date": "Oct 6-17, 2025",
      "from": null,
      "to": null,
      "type": "Email",
      "text": "EXHIBIT Q: ZOOM REMOVAL\nOctober 6-17, 2025\n\nEMAIL SEQUENCE:\n\n1. Oct 6, 2025 (7:12 PM) \u2014 Plaintiff \u2192 Faculty C\nSubject: Temporary Off-Campus Participation\n\\\"I wanted to let you know that, because of an unfolding legal matter, I'm not able to be on campus at the moment. I'm working on resolving it quickly and hope to be back in person soon, but in the meantime I'll need to participate remotely.\\\"\n\n2. Oct 6, 2025 (9:52 PM) \u2014 Faculty C \u2192 Plaintiff\n\\\"Yes, Zooming in tomorrow would work fine. We really need to go over your pr\u00e9cis tomorrow in class. It is so apropos and raises important questions. So, I'll set up the Zoom for you. Good.\\\"\n\n3. Oct 15, 2025 \u2014 TRO Hearing\nPlaintiff asks Selcer under oath if he will continue Zoom access. Selcer says yes.\n\n4. Oct 16, 2025 (11:01 AM) \u2014 Plaintiff \u2192 Faculty C\nSubject: Unable to Join Class\n\\\"I attempted to join class through the usual Zoom link, but no meeting was available. I just wanted to let you know in case there was a technical change or an alternate link I should use.\\\"\n\n5. Oct 17, 2025 (9:04 AM) \u2014 Selcer \u2192 Plaintiff\nSubject: seminar attendance\nCc: Faculty A\n\\\"I've discussed your remote attendance of his graduate seminar with Faculty C and he did not identify a compelling reason to continue it. We would both welcome your return to in-person attendance of our seminars.\\\"\n\n6. Oct 17, 2025 (7:25 PM) \u2014 Faculty C \u2192 Plaintiff\n\\\"Colleague B had surgery this past week, so I gave him the opportunity to Zoom for that one day, which you joined. So, please ask Dan about any need for continued online attendance.\\\"\n\n7. Oct 17, 2025 (7:31 PM) \u2014 Plaintiff \u2192 Faculty C\n\\\"Just to clarify \u2014 I did request remote attendance earlier this semester due to ongoing legal and safety issues, and you kindly authorized that arrangement at the time. I can re-forward the original message if helpful.\\\"\n\nPATTERN:\nOct 6: Faculty C authorizes Zoom directly\nOct 15: Selcer says yes at TRO hearing\nOct 16: Zoom link disappears\nOct 17 AM: Selcer claims Faculty C found \\\"no compelling reason\\\"\nOct 17 PM: Faculty C confused, unaware of prior authorization\n\nSelcer went to a professor who had already authorized Zoom, reframed it as a \\\"compelling reason\\\" test Faculty C never knew he was administering, and reported the result as Faculty C's independent judgment."
    },
    {
      "id": "R",
      "name": "Selcer Response to Safety Concerns",
      "date": "Jul 20, 2025",
      "from": "David Mullins",
      "to": "Dr. Daniel Selcer",
      "type": "Email",
      "text": "EXHIBIT R: SELCER RESPONSE TO SAFETY CONCERNS\nJuly 20, 2025\n\nFrom: David Mullins <`dntstoplaughing@gmail.com`>\nDate: Sun, Jul 20, 2025, 9:16 AM\nTo: Dr. Daniel Selcer <`selcerd@duq.edu`>, Faculty A <`Faculty A`>\n\nDear Dan and Faculty A,\n\nI've been struggling to write this email, in part because of the Dean of Students' reaction (\\\"doesn't reach the level of a student conduct violation, but make sure you call the police and stay safe [?!]\\\"). Narrating this, I find myself with a strange fear it will be minimized, which is odd, because I do not think either of you would do that.\n\nTo be blunt: I am scared of this person. I fear for my safety in any context where she knows my whereabouts, and I have had to hide my current address (with help from a member of the department), because retaliation has consistently been her response to any attempt at boundary-setting.\n\nIn our last conversation, Respondent expressed strong enthusiasm for the idea that, in her view, the Second Amendment should mean firearm regulations should be less of a hassle than they are.\n\nI cannot imagine sharing an office or a course with her. This is far beyond something that can be mediated or apologized for\u2014at least not in any way that could be prompted institutionally. Not only has Respondent never apologized for anything, she has simply never acknowledged or responded to the basic reality of a single violation.\n\nI want to underline that I did not know Respondent personally before I moved in around June 2. I have had maybe six conversations with her in total. The situation is bizarre and has nothing in common with any roommate issue I have ever experienced.\n\nAll my best, and thank you for reading,\nDavid\n\n---\n\nFrom: Dr. Daniel Selcer <`selcerd@duq.edu`>\nDate: Sun, Jul 20, 2025, 12:27 PM\nTo: David Mullins <`dntstoplaughing@gmail.com`>, Faculty A <`Faculty A`>\n\nDear David,\n\nI do think the most important thing right now is that you have secured another place to live. Looking forward, I can assure you it won't be a problem to ensure you don't share an office.\n\nThe Dean of Student's response is largely bound by the institutional language of the Student Code of Conduct.\n\nIf possible, could I ask you to write up a brief timeline of the events in question and briefly write up your current concerns? We can then discuss possible paths forward.\n\nAll my best,\nDan\n\n*******************************************\nDr. Daniel Selcer\nAssociate Professor & Chair\nDepartment of Philosophy\nDuquesne University\n600 Forbes Ave.\nPittsburgh, PA  15282  USA\n`selcerd@duq.edu`"
    },
    {
      "id": "S",
      "name": "Mullins Lists Conduct Violations / Wasilko Dismissal",
      "date": "Jul 21, 2025",
      "from": "David Mullins",
      "to": "Dr. Adam Wasilko",
      "type": "Email",
      "text": "EXHIBIT S: MULLINS LISTS CONDUCT VIOLATIONS / WASILKO DISMISSAL\nJuly 21, 2025\n\nFrom: David Mullins <`dntstoplaughing@gmail.com`>\nDate: Jul 21, 2025, 9:12 AM\nTo: Dr. Adam Wasilko <`wasilkoa@duq.edu`>, Dr. Daniel Selcer <`selcerd@duq.edu`>, Faculty A <`Faculty A`>\n\nDear Dan, Faculty A & Dean Wasilko,\n\nI am sad to say that based on the 1-2 punch of 1. Dean Wasilko's initial email response and 2. This most recent response from my department chair, I have lost the basic confidence that my interests will be protected in this process without my own full-throated and at times oppositional advocacy.\n\nLet me be clear: I told you and am telling you I fear for my safety. Not in the past, but now and in the future. I fled my home at substantial cost in order to protect my own physical safety. I was harassed and followed as I was leaving (\\\"predator vibes,\\\" said Colleague C, who helped me move out): \\\"Who you talking to David?\\\" \\\"Where you going David?\\\" Respondent following me up and down the stairs as I moved out, despite me repeatedly saying, \\\"I don't want to talk, I don't feel safe.\\\"\n\nAs I said in my previous email, every time I have pursued a process or set a boundary, Respondent has retaliated. I am filing in small claims court. I am talking to you. When she learns that I even tried to pursue formal redress, I will be in danger. \\\"You F****** talked to the landlord?!\\\" was what she yelled as she followed me through our house and started the stairs to our bedroom.\n\nI can remain at Colleague C's empty house for 11 more days. I do not have a permanent place. I cannot go to Germany as I planned and received an award for, due to all this financial and logistical disruption.\n\nDo you think I have ever made a university or legal complaint in my life? I haven't. This is the first and only time. Respect me enough to presume its legitimacy, at least enough to read closely all I present to you.\n\nI want to be clear that this is not a matter I take lightly. It needs to be taken seriously or I will be more than happy to pursue avenues of litigation. Let's please not do that.\n\nWhat should we do? I am open to additional ideas, but there is one that is clearly necessary.\n\nI request assistance navigating and drafting an account of the clear and multiple student conduct violations in this situation. When the Dean Wasilko said it \\\"didn't reach the level of [a violation]\\\" in their email, they were clearly and obviously wrong. In about 5 minutes skimming the handbook I found the below rules, *all* of which I am sure I could demonstrate either apply to this case or they apply nowhere:\n\n**Relevant Student Conduct Violations**\n\n1. **Bullying:**\nUse of written, verbal, or electronic expression, or physical acts/gestures, likely to cause emotional or physical harm, intimidate, control, or diminish another person physically or mentally.\n\n2. **Coercion:**\nUse of force, threat, or emotional intimidation to cause or attempt to cause another person to engage in or submit to certain activities.\n\n3. **Endangering Health or Safety of Another Person:**\nTaking or threatening action that endangers the safety, physical or mental health, or life of any person, and/or creating a reasonable fear of such action.\n\n4. **Incivility through Language or Actions:**\nEngaging in disruptive, ill-mannered, disrespectful, or offensive behavior.\n\n5. **Stalking:**\nRepeatedly following, harassing, threatening, or intimidating a specific person to the extent that it causes reasonable fear for their safety or substantial emotional distress, by any means (in person, electronic, social media, etc.).\n\n6. **Disorderly or Disruptive Conduct:**\nConduct which unreasonably interferes with university or community activities or with the legitimate activities of any university member, including disruption or obstruction of teaching, research, administration, meetings, or community living.\n\n7. **Dishonesty and Misrepresentation:**\nFailing to maintain a high standard of integrity and truthfulness in actions, including:\na) Misrepresenting personal information to university officials.\nb) Forgery or unauthorized use/alteration of documents or IDs.\n\n8. **Violating Laws and/or Policies:**\nViolating any published university policy, rule, regulation, guideline, procedure, and/or any federal, state, or local law or ordinance.\n\n9. **Failure to Behave in Keeping with the University's Mission:**\nEngaging in behavior that is not consistent with the university's mission.\n\nOnce I receive confirmation that I will be allowed to pursue this process as is my right, I will be happy to share the small claims file I submitted to court, which documents in irrefutable detail, including chat transcripts, e-mails, the police report and the officer's own assessment (\\\"Someone this deranged should not be in a graduate program\\\"), the bullying, manipulative, and cruel behaviors of Respondent relative to me.\n\nPlease reply with a formal written response outlining next steps and confirming my right to pursue these violations through the university's conduct process.\n\nMy only goal is a just, safe, and fair resolution; I hope it will not require further escalation. I don't like writing emails in this tone; I am from Texas and my grandmother is probably already complaining in paradise about my manners.\n\nAll my best,\n\nDavid\n\n---\n\nFrom: Dr. Adam Wasilko <`wasilkoa@duq.edu`>\nDate: Mon, Jul 21, 2025, 9:55 AM\nTo: David Mullins <`dntstoplaughing@gmail.com`>, Dr. Daniel Selcer <`selcerd@duq.edu`>, Faculty A <`Faculty A`>\n\nDavid-\n\nYou are welcome to report this to student conduct, you can email `mullarke@duq.edu`. I am not on campus this week.\n\nDr. Wasilko\n\nSent from my iPhone\n\n---\n\nFrom: Dr. Adam Wasilko <`wasilkoa@duq.edu`>\nDate: Jul 21, 2025, 11:49 AM\nTo: David Mullins <`dntstoplaughing@gmail.com`>, Dr. Daniel Selcer <`selcerd@duq.edu`>, Faculty A <`Faculty A`>\n\nDavid-\n\nI wanted to clarify something- in my email to you I suggested you file a report to public safety, who would then determine if charges were applicable and work with conduct. Did you do that? I also asked if you needed interim housing, but I didn't get a response. I said at the time, in my opinion, it was not a conduct violation based on the single incident described in your email. My advice remains the same- file a report with public safety. Any student is able to do that 24 hours a day, seven days a week.\n\nDr W"
    },
    {
      "id": "T",
      "name": "Sawa Initial Conduct Meeting Request",
      "date": "Jul 21, 2025",
      "from": "Dr. Anne Sawa",
      "to": "David Mullins",
      "type": "Email",
      "text": "EXHIBIT T: SAWA INITIAL CONDUCT MEETING REQUEST\nJuly 21, 2025\n\nSubject: Incident Report\n\nFrom: Dr. Anne Mullarkey Sawa <`mullarke@duq.edu`>\nDate: Mon, Jul 21, 2025, 8:04 PM\nTo: David Mullins <`dntstoplaughing@gmail.com`>\nCc: Dr. Adam Wasilko <`wasilkoa@duq.edu`>, Faculty A <`Faculty A`>, Dr. Daniel Selcer <`selcerd@duq.edu`>\n\nHello David,\n\nDr. Wasilko shared your email with me related to a conflict with another student.\n\nI am happy to meet with you to discuss the conduct process and next steps. Please visit my calendar to schedule a time to meet. I am out of the office currently and return on Friday, July 25.\n\nIf in the meantime, you have safety concerns, please contact 911 off-campus and 412 396 2677 on-campus.\n\nI look forward to speaking with you.\n\nThank you,\n\nAnnie\n\nDr. Anne Mullarkey Sawa\nDuquesne University\nExecutive Director of Student Conduct\nDeputy Title IX Coordinator\nAdjunct Faculty, School of Education\n`mullarke@duq.edu`\n412.396.6642\n\nNotice of Confidentiality: This e-mail, and any attachments, is intended only for use by the addressee(s) and may contain privileged, private or confidential information. Any distribution, reading, copying or use of this communication and any attachments by anyone other than the addressee, is strictly prohibited and may be unlawful. If you have received this e-mail in error, please immediately notify me by e-mail by replying to this message and permanently destroy or delete the original and any copies or printouts of this e-mail and any attachments."
    },
    {
  "id": "V",
  "name": "Selcer Post-TRO Denial with Faculty C Coordination",
  "date": "Oct 17, 2025",
  "from": "Dr. Daniel Selcer",
  "to": "David Mullins",
  "type": "Email",
  "text": "EXHIBIT V: SELCER POST-TRO DENIAL WITH FACULTY C COORDINATION\nOctober 17, 2025\n\nFrom: Dr. Daniel Selcer <selcerd@duq.edu> via liveduq.onmicrosoft.com\nDate: Fri, Oct 17, 2025, 9:04 AM\nTo: David, Faculty A\n\nDear David,\n\nI've discussed your remote attendance of his graduate seminar with Faculty C and he did not identify a compelling reason to continue it. We would both welcome your return to in-person attendance of our seminars. As I've explained before, if we receive notice of accommodation specifying virtual attendance from any of the university offices empowered to make that determination, we will of course extend it.\n\nAll my best,\nDan\n\n*\nDr. Daniel Selcer\nAssociate Professor & Chair\nDepartment of Philosophy\nDuquesne University\n600 Forbes Ave.\nPittsburgh, PA  15282  USA\nselcerd@duq.edu"
},
{
  "id": "W",
  "name": "Faculty C Authorization and Subsequent Reversal",
  "date": "Oct 6–17, 2025",
  "from": null,
  "to": null,
  "type": "Email",
  "text": "EXHIBIT W: FACULTY C AUTHORIZATION AND SUBSEQUENT REVERSAL\nOctober 6–17, 2025\n\n---\n\nEMAIL 1 OF 6\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Monday, October 6, 2025, 7:12 PM\nTo: Faculty C <Faculty C>\nSubject: [External] Temporary Off-Campus Participation\n\nDear Faculty C,\n\nI wanted to let you know that, because of an unfolding legal matter, I'm not able to be on campus at the moment. I'm working on resolving it quickly and hope to be back in person soon, but in the meantime I'll need to participate remotely or find another way to stay involved.\n\nI've been preparing for tomorrow's discussion and would really value the chance to talk about Heidegger if it's possible to do so by Google Meet or another format that works for you. I'm happy to adjust to whatever arrangement is easiest on your end.\n\nThank you very much for your understanding and flexibility.\n\nWarmly,\nDavid Michael Mullins\n\n---\n\nEMAIL 2 OF 6\n\nFrom: Faculty C <Faculty C>\nDate: Monday, October 6, 2025, 9:52 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nSubject: Re: [External] Temporary Off-Campus Participation\n\nDavid:\n\nI hope all of this works out soon indeed for you.\n\nYes, Zooming in tomorrow would work fine. We really need to go over your précis tomorrow in class. It is so apropos and raises important questions. So, I'll set up the Zoom for you. Good.\n\nAll my best,\n\nFaculty C\n\n---\n\nEMAIL 3 OF 6\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Monday, October 6, 2025, 10:13 PM\nTo: Faculty C <Faculty C>\nSubject: Re: [External] Temporary Off-Campus Participation\n\nDear Faculty C,\n\nThank you! I'm looking forward to it. Will try to be 'there' early in case there are any issues.\n\nAll best,\nDavid\n\n---\n\nEMAIL 4 OF 6\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Thursday, October 16, 2025, 11:01 AM\nTo: Faculty C <Faculty C>\nSubject: [External] Unable to Join Class\n\nDear Faculty C,\n\nI attempted to join class through the usual Zoom link, but no meeting was available. I just wanted to let you know in case there was a technical change or an alternate link I should use.\n\nThank you for your time,\nDavid Michael Mullins\n\n---\n\nEMAIL 5 OF 6\n\nFrom: Faculty C <Faculty C>\nDate: Friday, October 17, 2025, 7:25 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nSubject: Re: [External] Unable to Join Class\n\nDavid:\n\nColleague B had surgery this past week, so I gave him the opportunity to Zoom for that one day, which you joined. So, please ask Dan about any need for continued online attendance.\n\nWith all best. See you on Thursday! Have a good mini \"break\"!\n\nYours,\nFaculty C\n\n---\n\nEMAIL 6 OF 6\n\nFrom: David Mullins <dntstoplaughing@gmail.com>\nDate: Friday, October 17, 2025, 7:31 PM\nTo: Faculty C <Faculty C>\nSubject: Re: [External] Unable to Join Class\n\nDear Faculty C,\n\nThank you for your message. Just to clarify — I did request remote attendance earlier this semester due to ongoing legal and safety issues, and you kindly authorized that arrangement at the time. I can re-forward the original message if helpful.\n\nOf course, I'll plan to be in class next week as scheduled. I just wanted to be sure the record reflects that I'd requested and received authorization earlier in the term.\n\nAll best,\nDavid"
},
{
  "id": "X-4",
  "name": "Faculty B Reports Interpersonal Upset — No Performance Issues",
  "date": "Feb 5, 2026",
  "from": "Faculty B",
  "to": "David Mullins",
  "type": "Email",
  "text": "From: Faculty B <Faculty B>\nDate: Thu, Feb 5, 2026, 2:41 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\nSubject: Class today, class next Tuesday\n\nDear David,\n\nI'm upset by what happened between us in class today. It would be helpful for me if you didn't come to class next Tuesday, while I process this. Thanks for your understanding.\n\nBest,\nFaculty B\n\nFaculty B, Ph.D.\nProfessor of Philosophy\nEditor of Idealistic Studies: an Interdisciplinary Journal of Philosophy\nDepartment of Philosophy\nDuquesne University\n600 Forbes Ave\nPittsburgh, PA 15282\nPhone 412-396-6506\nemail: Faculty B"
},
{
  "id": "X-6",
  "name": "Selcer/Mullins Meeting — No Performance Issues Language; Faculty B Doesn't Control Stipend",
  "date": "Feb 10, 2026",
  "from": "Dr. Daniel Selcer, David Mullins",
  "to": null,
  "type": "Transcript",
  "text": "EXHIBIT X-6: SELCER/MULLINS MEETING — NO PERFORMANCE ISSUES LANGUAGE (CONDENSED)\nFebruary 10, 2026\nZoom meeting between Dr. Daniel Selcer (Chair) and David Mullins\n\nCONTEXT: Five days after Faculty B emailed Mullins asking him not to come to class (Exhibit X-4), Selcer meets with Mullins to discuss the situation. No \"performance issues\" language appears anywhere in this meeting. Three days later, Selcer's written reassignment letter (Exhibit X-8) introduces the phrase for the first time.\n\nKEY EXCHANGE 1 — SELCER'S FRAMING:\nSelcer: \"I understand there have been some issues between you and Faculty B, and I am trying to understand the situation and want to give you the opportunity to give me your perspective on what happened.\"\n\nKEY EXCHANGE 2 — MULLINS REPORTS NO PRIOR COMPLAINTS:\nMullins: \"This is the first I'm hearing of any problem or issue of any kind. Faculty B has been nothing but enthusiastic about my work, both last semester's research assistant, and this one.\"\nMullins: \"I've consistently fulfilled every research and TA responsibility requested — attending lectures, meeting deadlines — without issue or complaint until now.\"\n\nKEY EXCHANGE 3 — FACULTY B'S POSITIVE FEEDBACK CONFIRMED:\nMullins: \"She was a difficult supervisor, but I've made it work and we made it work and she said nothing but positive things about me is how I experienced it. If there's been some running issue, I haven't heard about it. I've heard just positive stuff.\"\n\nKEY EXCHANGE 4 — FACULTY B DOES NOT CONTROL STIPEND:\nMullins: \"Am I at a risk of being instantaneously fired?\"\nSelcer: \"Well, we don't instantaneously fire people, David. A faculty supervising a student TAing under a stipend — that is a supervisory relationship, but it's not the kind of formalized supervisory relationship that would have something to do with the status of a stipend. Faculty B doesn't make decisions about your stipend.\"\nMullins: \"So how to proceed is up in the air, but my stipend—\"\nSelcer: \"Let me just figure out what the actual situation is and we will speak again.\"\n\nKEY EXCHANGE 5 — SELCER'S COLLEGIAL TONE:\nSelcer asks Mullins to skip one class session while he interviews everyone: \"It gives me a chance to talk to everyone.\"\nSelcer on the seminar withdrawal: \"I would hope that no matter who's involved, professional issues with respect to TA work are different from faculty-student relationships and seminars.\"\n\nPATTERN: On Feb 10, Selcer frames this as a situation he needs to understand, uses no \"performance issues\" language, confirms Faculty B has no stipend authority, and maintains a collegial tone. Three days later (Exhibit X-8), he introduces \"performance issues raised by two of the three faculty members,\" threatens stipend suspension through 2029, and questions Mullins's viability as instructor of record."
},
{
  "id": "X-7",
  "name": "Faculty B Requests Reassignment — Door Open, No Performance Complaint",
  "date": "Feb 13, 2026",
  "from": "Faculty B",
  "to": "David Mullins",
  "type": "Email",
  "text": "EXHIBIT X-7: FACULTY B REQUESTS REASSIGNMENT — DOOR OPEN, NO PERFORMANCE COMPLAINT\nFebruary 13, 2026\n\nFrom: Faculty B <Faculty B>\nDate: Fri, Feb 13, 2026, 8:33 AM\nTo: David Mullins <dntstoplaughing@gmail.com>\nCc: Daniel Selcer <selcerd@duq.edu>\n\nDear David (cc'd Dan Selcer),\n\nI have asked Dan to reassign your TA position (he says this will not affect your funding). My office door is always open to you during my office hours, and I look forward to seeing you in our Schelling class.\n\nBest wishes,\nFaculty B\n\n\"Th'abuse of greatness is when it disjoins\nRemorse from power\" — Shakespeare, Julius Caesar.\n\nFaculty B, Ph.D.\nProfessor of Philosophy\nEditor of Idealistic Studies: an Interdisciplinary Journal of Philosophy\nDepartment of Philosophy\nDuquesne University\n600 Forbes Ave\nPittsburgh, PA 15282\nPhone 412-396-6506\nemail: Faculty B"
},
{
  "id": "X-8",
  "name": "Selcer Fabricates 'Performance Issues' and Threatens Stipend Through 2029",
  "date": "Feb 13, 2026",
  "from": "Dr. Daniel Selcer",
  "to": "David Mullins",
  "type": "Email",
  "text": "From: Dr. Daniel Selcer <selcerd@duq.edu>\nDate: Feb 13, 2026, 4:09 PM\nTo: David Mullins <dntstoplaughing@gmail.com>\n\nDear David,\n\nGreetings. I'm writing to let you know that after having heard from both you and Faculty B about the tensions and confrontations that developed in the framework of your TA assignment for her Environmental Philosophy class, I am reassigning you. You will TA for Faculty A's Logic class for the remainder of the SP26 semester. This reassignment will not affect your stipend.\n\nDr. Faculty A will reach out next week to share the course syllabus, discuss her TA expectations, and delimit your responsibilities. Please plan to begin attending her class starting the week of February 23.\n\nI note that there have now been performance issues raised by two of the three faculty members for whom you have held TA assignments. This raises concerns about the viability of your future assignment as the instructor of record for the classes you are scheduled to begin teaching next year.\n\nFuture significant performance issues, including ones that may be raised by your TA supervisor (SP26), students in the classes you will teach as a Graduate Teaching Fellow (FA26, SP27, FA27, SP28, FA28, SP29), or faculty assigned to evaluate those classes through our PhD teaching observation system, may result in a recommendation by the Chair to the Dean of Liberal Arts for suspension of your stipend.\n\nSincerely,\nDan Selcer\n\nDr. Daniel Selcer\nAssociate Professor & Chair\nDepartment of Philosophy\nDuquesne University\n600 Forbes Ave.\nPittsburgh, PA 15282 USA\nselcerd@duq.edu"
},
{
  "id": "Z-b",
  "name": "Deliberate Indifference Standard — Training Definition",
  "date": "Jul 28, 2020",
  "from": null,
  "to": null,
  "type": "Training Slide",
  "text": "EXHIBIT Z-b: DELIBERATE INDIFFERENCE STANDARD — TRAINING DEFINITION\nPCHE Summer 2020 Title IX Training (Connelly)\n\nSlide 5 — Three-Part Framework\n1. Actionable sexual harassment PLUS\n2. Actual knowledge triggers a school's response which\n3. Must not be deliberately indifferent\n\nSlide 64 — Required Response\nWhere a school has: (1) had actual notice; (2) of sexual harassment; (3) in a program or activity; (4) in the U.S., it must respond:\n- Promptly (to include undefined timeframes for all steps)\n- In a manner that is not \"deliberately indifferent\"\n- Equitably, including explaining and providing supportive measures\n- By adopting and following new procedures to include a \"Formal complaint\" process, prior to issuing any discipline\n- By adopting a grievance process that includes a presumption that the Respondent is \"not responsible for the alleged conduct\" until a determination is made regarding responsibility at the end of the process\n\nSlide 65 — What is Deliberate Indifference?\nA school is deliberately indifferent ONLY where:\n- Its response to sexual harassment is clearly unreasonable under the known circumstances\n- If the school follows the procedural requirements, the OCR will not find deliberate indifference solely because it would have come to a different conclusion\n\nPRACTICE POINTER: You should not be striving to merely satisfy the \"deliberate indifference\" standard"
},
{
  "id": "Z-c",
  "name": "Supportive Measures — Mandatory, Non-Punitive, Individualized",
  "date": "Jul 28, 2020",
  "from": null,
  "to": null,
  "type": "Training Slide",
  "text": "EXHIBIT Z-c: SUPPORTIVE MEASURES — MANDATORY, NON-PUNITIVE, INDIVIDUALIZED\nPCHE Summer 2020 Title IX Training (Connelly)\n\nSlide 38 — Supportive Measures Definition\nNew Definition, but familiar ground, as it codifies best practices:\n- Available to both Complainants and Respondents\n- Designed to restore or preserve equal access to the education program or activity without unreasonably burdening the other party, including measures designed to protect the safety of all parties or the educational environment, or deter sexual harassment\n- The Title IX Coordinator is responsible for coordinating the effective implementation of supportive measures\n- Fact specific inquiry — no unreasonable burden (some burden ok)\n\nSlide 39 — Characteristics\nFormerly called Interim Measures, these are school-provided services that are:\n- Available at any time after a report of sexual harassment\n- Non-disciplinary\n- Non-punitive\n- Not \"unreasonably burdensome\" to the other party\n- Individualized\n- Provided at no cost\n\nPRACTICE POINTER: Do a word search for \"Interim\" on your webpages\n\nSlide 40 — Examples\nFamiliar Supportive Measures include:\n- Work or class schedule modifications\n- Counseling\n- Mutual no contact orders\n- Changes in housing or work locations\n- Leaves of absence\n- Extensions of deadlines\n\nMust be documented, and kept as confidential as possible\n\nPRACTICE POINTER: Removal from teams, clubs, etc., are not Supportive Measures. Use your emergency removal process"
},
{
  "id": "Z-d",
  "name": "Conflict of Interest and Bias — Training Requirements",
  "date": "Jul 28, 2020",
  "from": null,
  "to": null,
  "type": "Training Slide",
  "text": "EXHIBIT Z-d: CONFLICT OF INTEREST AND BIAS — TRAINING REQUIREMENTS\nPCHE Summer 2020 Title IX Training (Connelly)\n\nSlide 43 — Fairness, Equity, and Impartiality\nThe Title IX Team must identify and avoid:\n- Bias against individuals or types of people\n- Pre-judgment based on gender, race, sex, religion, disability, etc.\n- Pre-judgment based on status as a Complainant or Respondent\n- Conflicts of interest\n- Profiling and predictive behaviors\n\nWhen in doubt, remember to treat parties the same\n\nSlide 44 — What is Bias?\nBias is a predisposition to think about a specific group and its individual members in a preconceived way\n- Explicit: fully and clearly expressed or demonstrated\n- Implicit: implied, rather than expressly stated; unconscious\n\nSlide 45 — Avoiding Bias\n- Learn about, be alert for, and avoid, stereotypes such as sex stereotypes\n- Do not prejudge. Beware of making judgments or assumptions about the validity of the allegations even before you start your work or even mid-process\n- Review and analyze all relevant evidence gathered\n- Avoid leading questions\n- Focus on the elements needed for proof\n- Remember: you might not get credit for the right answer if you don't show your work (be prepared to justify your conclusions with the information you have gathered)\n\nSlide 46 — What is a Conflict of Interest?\nA conflict between the private interests and the official responsibilities of a person in a position of trust (Merriam-Webster)\n\nCOI must be avoided to:\n- Protect process participants\n- Ensure fairness\n- Maintain the trust, integrity, and credibility of the Title IX process\n- Comply with Title IX\n- Avoid litigation and minimize appeals\n\nSlide 47 — Avoiding COI\nExamples of potential COI:\n- Appeal Decision-Maker's spouse was a witness in the investigation\n- Investigator accepts 50 yard-line tickets from Athletic Director\n- Title IX Team member publishes a blog that stereotypes based upon gender\n\nPRACTICE POINTER: In scanning for COI, consider where there may be influence unrelated to the evidence in the case, such as personal relationships, financial relationships, or power dynamics\n\nSlide 48 — COI Response Best Practices\n- Design a way for the parties and Title IX Team members to report bias and COI\n- Encourage Title IX Team member to disclose potential bias and COIs\n- Create written guidelines for assessing bias and COI stating that a determination will be based on objective facts, and not on generalizations, stereotypes, suspicions, or conclusions\n- Use an objective standard for determinations like whether \"based on objective facts, a reasonable person would believe that a COI exists\""
},
{
  "id": "Z-e",
  "name": "Actual Knowledge & Responsible Employee Program",
  "date": "Jul 28, 2020",
  "from": null,
  "to": null,
  "type": "Training Slide",
  "text": "EXHIBIT Z-e: ACTUAL KNOWLEDGE & RESPONSIBLE EMPLOYEE PROGRAM\nPCHE Summer 2020 Title IX Training (Connelly)\n\nSlide 30 — Actual Knowledge Defined\nActual knowledge means notice of sexual harassment or allegations of sexual harassment to:\n- A recipient's Title IX Coordinator; or\n- Any official of the recipient who has authority to institute corrective measures on behalf of the recipient\n\nImputation of knowledge based solely on respondent being an employee is not enough\n\nSlide 31 — What Triggers Actual Knowledge?\nAny person may report sex discrimination, including sexual harassment, to the Title IX Coordinator. A report may be made at any time (including during non-business hours) by using the telephone number or electronic mail address, or by mail to the office address, listed for the Title IX Coordinator.\n\nPRACTICE POINTER: How will your school receive reports? Ensure there are multiple ways to report and that each reporting mechanism is monitored.\n\nSlide 32 — Who Has Authority?\nThe preamble states that a school's Title IX Coordinator, and any official with \"authority to institute corrective measures\" has actual knowledge.\n\nThis could include: Provost, VP for Student Affairs, Dean of Students, HR Director, etc.\n\nPRACTICE POINTER: Consider whether your institution defines \"authority to institute corrective measures\" more broadly than just the Title IX Coordinator\n\nSlide 33 — Responsible Employee Program\nWhat if a school designates ALL employees as mandatory reporters? Then the school will have \"actual knowledge\" whenever any employee knows of sexual harassment or allegations of sexual harassment.\n\nThis is a policy decision each institution must make.\n\nSlide 34 — Consequences of Responsible Employee Designation\nIf your institution has a responsible employee program:\n- Every employee who receives a report = actual knowledge to the institution\n- Failure to act on that knowledge = potential deliberate indifference\n- Training ALL employees on reporting obligations is critical\n\nPRACTICE POINTER: If you have a responsible employee program, make sure every employee knows what to do when they receive a report"
}
    
    
  ]
}