IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA
JOHN DOE,Plaintiff,v.SWARTHMORE COLLEGE,Defendant.::::::::::::
CIVIL ACTION NO. _______________JURY TRIAL DEMANDEDCIVIL ACTION COMPLAINT
Plaintiff John Doe,
by and through his undersigned attorneys, files this Complaintagainst Swarthmore College and, in support thereof, alleges as follows:
I. NATURE OF THE ACTION
1. This case arises out of actions taken by Defendant Swarthmore College(“Swarthmore” or “College”) concerning false allegations made against Plaintiff John Doe(“John”), a male student at Swarthmore with stellar and otherwise unblemished academic anddisciplinary records.2. In April 2011, John Doe and Jane Doe
(“Jane”), a fellow Swarthmore student,engaged in two consensual physical encounters: (1) a brief kiss on April 23, 2011; and (2) sexualactivities occurring on April 30, 2011. The two did not have sexual intercourse during eitherencounter. On May 1, 2011, one day after the second encounter, by Jane’s own admission, she
Contemporaneously with this Complaint, Plaintiff has filed a Motion For Permission To Proceed UnderPseudonym.
A pseudonym is used to protect Jane’s identity as well.
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