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DEVELOPMENT (NORTH AMERICA), :
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Plaintiff Sherrie Russell-Brown (“Plaintiff” or “Ms. Russell-Brown”), by and through her undersigned counsel, as and for her Amended Complaint in this action against Defendants, jointly and severally, the University of Florida Board of Trustees (“UF”), the University of Florida, Levin College of Law (“the Law School”), Robert H. Jerry, II (“Jerry”), in his individual and official capacities as Dean of the Law School, the University of Oxford (“University of Oxford”) and Oxford University Development (North America) (“Oxford NA”) (collectively, the “Defendants”), hereby alleges as follows:

This is an action for declaratory, injunctive and equitable relief, as well as monetary damages, to redress Defendants’ unlawful conduct, including their unlawful retaliation for Ms. Russell-Brown having engaged in and continuing to engage in protected activity. Defendants’ actions violated the Civil Rights Act of 1866, 42 U.S.C. § 1981 (“Section 1981”), Title IX of the Education Amendments of 1972, 20 U.S.C. §§ 1681 et seq. (“Title IX”), Title VI of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000d et seq. (“Title VI”), and the First, Fifth and Fourteenth Amendments to the U.S. Constitution pursuant to 42 U.S.C. § 1983.

This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331 and 1343 because this action involves federal questions regarding the deprivation of Ms. Russell-Brown’s rights under federal civil rights laws.

Venue is proper in this district pursuant to 28 U.S.C. § 1391(b), because Defendants UF, the Law School and Jerry reside and/or may be found in this district. A substantial part of the events or omissions giving rise to the claims occurred in New Jersey. All of the operative facts of retaliation were committed in New Jersey. The relevant records and documents are located in New Jersey. Many of the individuals with personal knowledge regarding the post-Release retaliation against Ms. Russell-Brown, including prospective employers, are located in New Jersey. The Defendants’ witnesses, if any, are likely to be employees whose presence can be obtained by the Defendants. Finally, New Jersey State law governs the claims of civil conspiracy and defamation.

Defendant UF is an institution of higher education. Defendant UF is also a public body corporate, pursuant to § 1001.72, Florida Statutes (2009), with all the powers of a body corporate, including the power to contract and be contracted with, to sue and be sued, to plead and be impleaded in all courts of law or equity. UF receives Federal financial assistance and is subject to Title VI and Title IX.

Defendant University of Oxford is an institution of higher education, having its principal place of business at University Offices, Wellington Square, Oxford OX1 2JD, United Kingdom. Dr. Andrew D. Hamilton, a U.S. citizen, is the Vice-Chancellor and Chief Executive Officer of the University of Oxford (see, e.g.

Defendant Oxford NA, is a Delaware corporation, file number 2182294, with its
principal place of business at 500 Fifth Avenue, 32nd Floor, New York, New York 10110. Oxford
NA’s appointed registered agent for service of process is CT Corporation, 1209 Orange Street,
Wilmington, Delaware, 19801. Oxford NA is an alter ego or agent of the University of Oxford (see,
e.g.