Harvard Complaint (File Copy)

Harvard Complaint (File Copy)

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Harvard Complaint (File Copy)

@powderhownd14924 days ago

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
----------------------------------------…
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stop and deter this outrageous antisemitic conduct and penalize the students and faculty who 
…
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plagiarism allegations and a month of intense public scrutiny did Harvard’s president finally 
…
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discriminate, and assault Jewish students—including on October 18, when a mob of protesters 
a…
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severe and pervasive hostile environment for Jews on campus leaves Harvard’s remaining Jewish 
…
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11. Venue in the District of Massachusetts is proper under 28 U.S.C. § 1391 because 
it is the…
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18. SAA Member #4 is a Jewish Ph.D. student at Harvard University, taking courses 
at Harvard …
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environment” based on “actual or perceived shared ancestry or ethnic identity as Jews,” in whic…
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Awareness Campaign. As part of that campaign, on November 7, 2023, OCR reminded schools 
of th…
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 “Applying double standards by requiring of [Israel] a behavior not expected or 
demanded of…
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30. Antisemitism is a core tenet of Harakat al-Muqawama al-Islamiya, known by its 
Arabic acr…
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policies. Harvard, however, refuses to apply these policies in a non-discriminatory manner to …
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environment that a reasonable person would consider intimidating, hostile, or abusive and deni…
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“[s]tudents [and] faculty . . . agree to respect the rights, dignity, and differences of other…
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which effectively prevents members of the audience from adequately hearing or seeing the 
eve…
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closed, dissent by non-attendees is limited to activity outside the meeting that does not impe…
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use the “Harvard” name or marks in organizations’ activities without permission from a dean or…
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education—finding that Harvard was the most antisemitic college in the United States—and in a …
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49. SJP—which has a recognized chapter at Harvard Divinity in addition to its 
affiliate, Har…
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notwithstanding that the conduct plainly violated policies including Harvard’s Statement on 
…
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During the meeting, Jewish students, in the words of Harvard Hillel’s president, were met “wit…
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Jewish-supremacist political ideology,” using a phrase coined by Ku Klux Klan Grand Wizard 
D…
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views, has repeatedly and publicly announced his fantasy of murdering Jews, and claims that 
…
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providing resources to explain the bias in Wispelwey’s course—as Chief DIB Officer Barbosa 
a…
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so that anyone entering or exiting would be forced to walk through the gauntlet. The video als…
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67. In August 2022, Harvard PSC members disrupted Harvard’s convocation—a 
ceremony for incom…
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student who interrupted Dean Khurana was later selected as a Rhodes Scholar, after receiving 
…
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Harvard Refuses to Discipline a Professor Who Intentionally Discriminated 
Against Jewish Stu…
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Harvard’s Statement on Rights and Responsibility and finding that he: subjected the students t…
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and, following Hamas’s October 7 massacre, has enabled yet another intolerable wave of 
antis…
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creating an “open-air prison” in Gaza (even though Israel completely removed itself in 2005 
…
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for Hamas’s massacre: “We, the undersigned student organizations, hold the Israeli regime 
en…
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86. Later on October 9, SAA Member #2 emailed President Gay and Harvard Law 
Dean John F. Man…
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Harvard failed to condemn it or take any other actions to prevent the statement from further 
…
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she was unable to reach anyone in her family. After class, she was accosted by a student who—
…
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95. On October 16, students chalked antisemitic writings at the entrance to Harvard 
Law, usi…
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98. On October 19, Harvard PSC and Harvard GS4P recruited hundreds of protesters 
to march th…
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came to the door to tell the Jewish students to wait in another room until the administrators …
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103. On October 27, during Family Weekend—when students’ families visit campus—
Harvard PSC a…
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106. Three days later, on October 30, Harvard PSC and Harvard GS4P, in violation of 
Harvard’…
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109. On November 16, the next day, protesters held an unauthorized event in 
Caspersen lounge…
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112. On or around November 5, fliers that SAA Member #5 had hung at Harvard Law, 
advertising…
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demonstrators break in.” None of the administrators responded to SAA Member #1 concerning 
an…
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118. As Professor Summers stated in a November 15 Washington Post Op-ed titled 
“The Cancer o…
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“from the river to the sea, Palestine will be free,” and “we have them outnumbered,” among 
o…
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murder of a police officer in Jerusalem, and the latter to sixteen years in prison for her 
p…
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Seasons of Light celebration and making it unequivocally clear that vandalizing the menorah wa…
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and President Gay, telling them it was “deeply concerning” and reminding them, “when I told 
…
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130. Reflecting its deliberate indifference to the severe and pervasive hostile 
environment …
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weeks later, after Bharmal was recorded assaulting a Jewish student on October 18, Professor 
…
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135. On October 19—after taking a break because of the disruptive mob charging 
through the h…
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participates in disruptive student groups’ activities; and Harvard Divinity Professors Rantisi…
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140. On December 5, the same day President Gay testified before Congress, Harvard 
Faculty an…
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that amounts to bullying, harassment, intimidation, that is actionable conduct, . . . we do ta…
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migrant workers, thousands of whom died building the infrastructure for the 2022 FIFA World 
…
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That same day, Rabbi Wolpe explained on CNN: “I resigned because I came to the conclusion 
th…
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Jewish communit[y] that [President Gay] enabled.” Moreover, the letter recognized that Jewish …
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not Jewish. This discriminatory double standard has created and exacerbated the discrimination…
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156. Harvard also has no problem censoring controversial speakers or discussions—
unless they…
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158. Neither the recommendations in the “Harvard & the Legacy of Slavery” report, 
nor then-P…
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numerous strong statements and sponsored numerous events condemning racist police killings 
a…
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law prohibiting conversion from Hinduism to any other religion,” “[r]emove . . . 300 masjids 
…
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166. Harvard Public Health administrators sent more emails to large lists of 
community membe…
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a graphic glorifying a Hamas terrorist paraglider a day after Hamas’s massacre and who 
conti…
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that day, where an “individual affiliated with [Harvard Law] entered our campus and is reporte…
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made to feel less important than, other non-Jewish students. Students, along with Harvard 
fa…
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Islamic poetry and engage with the Quran. Harvard’s refusal to stand against antisemitism has …
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is forced to confront his fears concerning uncontrolled antisemitic mobs on campus or the 
an…
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Harvard will ameliorate antisemitism after being told by Chief DIB Officer Barbosa that his 
…
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COUNT I 
Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.
(Intentional Di…
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origin that deprives Kestenbaum and SAA’s Jewish Harvard student members of full access to 
H…
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194. Harvard and its administrators also directly and intentionally discriminate against 
Kes…
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199. Plaintiffs are entitled to appropriate injunctive relief under Title VI, because 
Harvar…
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things, to provide them a discrimination-free environment to be achieved by Harvard abiding by…
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race, ethnic characteristics, or national origin bias—treating incidents of abuse, harassment,…
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implicitly or explicitly conditioned on the hiring or promotion of professors who 
espouse an…
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Dated: January 10, 2024 Respectfully submitted, 
ALEXANDER KESTENBAUM and STUDENTS 
AGAINST …
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