STATE OF SOUTH CAROLINA. COUNTY OF CHARLESTON TYLER KIM Plainimts) i Kappa Phi Fratemi: Alpha Chapter ofPi Kappa Phi Frateenig: Pi Kappa Phi Propenies: Richard M. Pierce. Individually and in his Official Cepacty as Alpha Chapter Advisor: Brooke M, Kingsley Isbell, Individually and inher Ocal Capacity 38 Pi Kappa Phi Fraternity Director of Prevention Eduction: Justin Angotti Individually and in his Official Capacity as Pi Kappa Phi Assistant Executive Director of Education & Accounabiiy; Sean Daily; Mathew Louge. Nikos Lara and Seve Leone Defendantis) ‘Submited By: Mark A. Peper, Esq ‘Address: The Peper Law Firm, PA. 1548 Savannah Highway ‘Charleston, SC 29407 ‘NOTE: The covers! ad nfarmatin conse rin either replace nr spent he 1 IN THE COURT OF COMMON PLEAS CIVIL ACTION COVERSHEET aoirce-10. BRK S— SC Bars Telephone #: Fav Other: ma mark d peperlawfirm.com ‘quedo Tis form it equied forthe ast the ls fat ote pres of Ueceing ct eed ot Empty, ae ‘dad Cop afccovesho mao sal oe Seta song wih he Summocs a Compe DOCKETING INFORMATION (Check al ha apps) *Y/Aedow i Judgment Selement donot complete Bg sunv raat dimintincon “ZY Ronan Faia set conga Bf neon se ARBITRATION oma te Cour ne Ae Dap Rein Rls Fy Tibcs ERMC Atenas pce owe enced Sonne Dap Renan ue £5 Tha icc fom ADR off enon Ae NATURE OF ACTION hl nc Ba Bs 2 cnt, SIRES og Sales 2 alte oan go cectigr"” Gta, hemeeacing =” fonmrann Beira Gaceieutenter Gf mmcutitan 2 Maceaton Gh trwuramisn Soa focainne” = sorta 2 Gave” GQ encnawaw Gf tegwtnn, —— B nentn Sees sch © sskoumm paucity 1 vtec 5 nwincuin Deneve, ers 3 oon 5 oman kom o SEIN, Sa anne 8 finwessn —Gaainacns Renin ten) 8 Mercere, ray 3 scartty becca tn 8 cour” Retains tire” ese 3 Semin” 2 ecen — B boe 3 Setu'Cmcnarwy teat B Soren 2 St 2 fects Bers ee hee specu © cantata, Br Comm 2 tne Raion Senne Sein Saracen, Seat soca /234 (082016) age 1 of2oooa ‘Medical (620) D_ Owor state Depostins (550) 2) oer (199) =a ieton _ 2 wei sn, ‘Sevan Petr 510) PreSueDcvery PT Ar ///) D Iji2 = [Note: Frivolous ivi proceedings may be bjs tsanctons prseant to SCRCP, Rl 1, sd the South Carling Frivolous ch ul Proceedings Saetions Act, SC. Code Ans. 15-36-10 tse, Effective January 1, 2016, Alternative Dispute Resolution (ADR) is mandatory in all counties, pursuant to Supreme Court Order dated November 12, 2015. sul /PREME COURT RULES REQUIRE THE SUBMISSION OF ALL CIVIL CASES TO AN ALTERNATIVE, DISPUTE RESOLUTION PROCESS, UNLESS OTHERWISE EXEMPT. Pursuant tothe ADR Rules, you are required to take the following action(s): Please Not sci |. The parties shall select neutral and file « “Proof of ADR’ form on or bythe 210% day ofthe Fling ofthis action, Ifthe panies have not selected a neutral within 210 days, the Clerk of Court shal then appoint a primary and secondary mediator fom the current rster ona rotating basis rom among those mediators agreeing o aceept cases inthe county in which the ation hasbeen filed. 2. The initial ADR conference must be eld within 300 days after the filing ofthe ston [3 Pre-suit medical malpractice mediations required by 8,C, Cade §15-79-125 shall beheld not later than 120 days afterall defendants are served withthe "Notice of Intent to File Suit” o asthe court dies 44. Cases are exempt ffom ADR only upon the following grounds: Special proceeding, or actions secking extraordinary reli suchas mandamus, habeas corpus, or pribition; Requests for temporary elie Appeals 4, Post Conviction relief mater; «Contempt of Cour proceedings; . Forfcitteprossodings brought by goverment entities; Mortgage foreclosures and ‘Cases that have been previously subjected to an ADR conference, unless otherwise required by Rule 3 or by statute 5. In.ases not subject to ADR, the Chet Judge for Administrative Purposes, upon the motion ofthe court or of any party, may order a case to mediation, 6, Motion ofa party tobe exempt from payment of neutral fees due to indigencyshould be filed with the ‘Court within en (10) days after the ADR conference has ben concluded. ‘You must comply withthe Supreme Court Rules regarding ADR. Failure to do so may affect your ease or may result in sanctions. 1CA/ 234 (08/2016) Page 2 of 2STATE OF SOUTH CAROLINA COUNTY OF CHARLESTON ‘Tyler Kim ) ) ) ) ) ) ) ws } Fi Kapa PEt Alta Chg ef) i Kappa Phi Fraternity: Pi Kappa Phi Propertes: chad Mere Invdully ) and in his Official Capacity a3 Alpha) ‘Chapter Advisor; Brooke M. Kingsley Isbell.) Individually and in her Official Capacity as) i Kappa Phi Fraternity ) Prevention Education; Justin Angotti, ——) Individually, and in his Official Capacity as ) i Kappa Phi Fraternity Assistant Executive ) Director of Education & Accountability, ) Sean Daily; Matthew Louge; Nikos Lara; ) and Steve Leone. ) ) _—________ Defendants.) IN THE COURT OF COMMON PLEAS [NINTH JUDICIAL CIRCUIT CIVIL ACTION NO. 2017.CP-10-289% 2e3~a aes Raina keen em a 3 0 SUMMONS oe GURY TRIAL DEMANDED) 252, “E, ‘YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, 1 copy of which is served upon you, and to serve a copy of your Answer to this Complaint upon ‘counsel for the Plaintiff, Mark A. Peper, at $48 Savannah Highway, Charleston, SC 25407, within thirty (30) days after service hereof, exclusive of the day of service. If you fail to answer this Complaint within the aforesaid time, judgment by default shall be rendered against you for the relief demanded in the Complaint. This! day of August, 2017 Charest, South Colina ‘THE PEPER LAW FIRM, PA waka Peper, Es Julian A. Ferguson, Eau. '548 Savannah Highway ‘Charleston, South Carolina 29407 Phone: (843) 225-2520 Mark@PeperLawFirm.comSTATE OF SOUTH CAROLINA ) INTHE COURT OF COMMON PLEAS COUNTY OF CHARLESTON, )—NINTHJUDICIAL CIRCUIT ) CIVIL ACTION NO. 2017.cP-10-24 99 ) Tyler Kim ) ) Plaintiff, ) vs. ) } i Kappa Phi Fratemity; Alpha Chapter of) i Kappa Phi Fratemity; Pi Kappa Phi) Properties; Richard M, Piere, Individually ) and in his Official Capacity as Alpha.) COMPLAINT ‘Chapter Advisor; Brooke M. Kingsley Isbell.) (JURY TRIAL DEMANDED) Individually and in her Official Capacity as) i Kappa Phi Fratemity Director of ) Prevention Education; Justin Angott, —) Individually, and in his Official Capacity as ) Pi Kappa Phi Fratemity Assistant Executive ) Director of Education & Accountability; ) Scan Daily; Matthew Louge; Nikos Lara; ) and Steve Leone. ) ) Defendants COMES NOW Pla fff Tyler Kim, by and through his undersigned counsel, complaining ‘of Defendants Pi Kappa Phi Fraternity; Alpha Chapter of Pi Kappa Phi Fraternity; Pi Kappa Phi Properties; Richard M. Pierce, Individually and in his Official Capacity as Alpha Chapter Ac Brooke M. Kingsley Isbell, Individually and in hee Official Capacity as Pi Kappa Phi Fraternity Director of Prevention Education; Justin Angotti, Individually and in his Official Capacity as Pi Kappa Phi Fraternity Assistant Director of Education & Accountability can Daily; Mathew Louge; Nikos Lar; and Steve Leone, jointly and severally, would allege and show unto the Court the following: PARTIES AND JURISDICTION 1. ‘That Plaintiff Tyler Kim (hereinafter “Plaintiff” is, at all times relevant to this ‘Complaint, a residest of Charleston County, South Carolina. 12, ‘That Defendant Pi Kappa Phi Fraternity (hereinafter “Pi Kappa") is a domestic '501(@)8 non-profit corporation that conducts its affairs and business activites inthe tate of South Carolina, and more particularly, was conducting such business activites in Charleston County, South Carolina atthe time the causes of action arose, and further, has agents, employees, offices and/or properties located inthe County of Charleston, State of South Caralina. Pi Kappa controls and directs all activites of its chapters throughout the country, including the Alpha Chapter of Pi Kappa Phi Fratemity located in Charleston County, South Carolina, 3. ‘That Defendant Alpha Chapter of Pi Kappa Phi Fratety (hereinafter “Alpha Chapter”) was founded in Charleston, South Carolina on December 10, 1904, is the Supreme Chapter of Pi Kappa, and conducts its sts and business activities in the State of South Carolin, and more particularly, was conducting such business activites in Charleston County, South Carolina tthe time the causes of action arose and further, was acting by and through its members, agents, servans, employees, andor officers, including, but not limited to those persons and/or individuals named in this Complaint 4. ‘That Defendant Pi Kappa Phi Fraternity Properties (hereinafter Properties” isa foreign SOW(03 non-profit corporation organized under the laws of the State of Florida that conducts its affirs and business activites in the State of South Caroling, and more particularly, was conducting such busines activities in Charleston County, South Carling atthe time the causes of ation arose, and further, has agents, employees, offices andlor properties located inthe County of Charleston, State of South Carolin, Specifically, Properties isthe fatty atonal housing sorporation established to aid in the management of chapter housing, and owned and. petted the property where the causes of action arse, Properties is subject to personal jurisdiction inthe courts ofthe State of South Carolina pursuant to S.C. Code Ann. § 36-2-803.5. That Pi Kappa is a top down organization structured in the mold ofa traditional corporation with al diesives, decisions, ations orinstations lowing directly from its officers downto its employees and agents, Thos officers a etl esposile forthe acts or omisions ofits employees and agents 6. ThatDefendant Richard M, Pierce (hereinafter “Chapter Advisor" is an individual, citizen and resident of Charleston County, South Carolina At all times relevant herein to this ‘Complain, Chapter Advisor, acting as an agent of Pi Kapp, was the Alpha Chapter Advisor and Alreoly oversaw all conduct and activity ofthe Alsha Chapter and its member agents. Chapter ‘Advisor was appointed by the Pi Kappa National Count! and was charged with advising students ofthe potential and perceived risks involved in chapter activites and events and on the approach to managing chapter operations, Chapter Advisor oversaw the entire operation of the Alpha Chapter locate in Charleston, South Caofina and all ies hd the authority tact on its behalf Chapter Advisor was acing within the course and scope of his agency atthe time the causes of action arose, 7. That Defendant Brooke M. Kingsley Isbell (hereinafter “Director of Prevention Education’ is an individual, citizen and resident of Richmond, Virginia and was employed by Pi ‘Kappa as Director of Prevention Education at all times relevant to this complaint. Director of Prevention Education was charged with responsibility for developing and managing the menu of programs and initiatives intended to prevent and address the negative behaviors associated with alcohol and drug abuse, hazing, sexual abuse and harassment for all chapters of Pi Kappa, including the Alpha Chapter located in Charleston County, South Carolina ector of Prevention [Education was acting within the course and scope of her employment atthe time the eauses of8. That Defendant Justin Angotti (hereinafter “Director of Accountbility") is an individual, citizen and resident of Mecklenburg County, North Carolina and was employed by Pi Kappa as Assistant Executive Director of Education & Accountability at all times relevant to this ‘complaint. Director of Accountability was charged with esponsibility forthe development and ‘execution of the Alpha Chapter's education and assessment strategy, including. leadership development programs, officer and key committee chairman resources, member education, chapter ‘advisor training and resources, and prevention education, Further, Director of Accountability ‘oversaw tke implementation of the Alpha Chapter's risk management policies and managed the individual member and Alpha Chapter conduct processes, Director of Accountability was acting te course and scope ofhis employment tthe tme the causes of action aos. 9, ThatDefendant Sean Daily (hereinafter*Member Agent 1"), at alltimes relevant to this complaint, a resident of Charleston County, South Carona and was a member agent of the Alpha Chapter and acting atthe direction and on behalf ofthe Alpha Chapter and within the course and scope of his agency atthe time the causes of action arose 10, That Defendant Mathew Louge (herenafer “Member Agent 2°) is, a all mes relevant to this complaint, a resident of Charleston County, South Carling and was a member agent of te Alpha Chapter and acting atthe diretion and on behalf of the Alpha Chapter within the course and scope of his agency athe time the caues of action arose. 11. That Defendant Nikos Lara (hereinaler“Member Agent 3" is, tal times relevant to this complaint, a resident of Charleston County, South Carolina and was a member agent ofthe Alpha Chapter and acting atthe ection and on behalf of the Alpha Chapter within the course and scope of his agency atthe time the causes of action arose. 12, That Defendant Steve Leone (hereinafter “Member Agent 4”) i at all times relevant to this compl a resident of Charleston County, South Carolina and was a member 48, That Defendant Justin Angotti (hereinafter “Director of Accountability”) is an individual, citizen and resident of Mecklenburg County, North Carolina and was employed by Pi Kappa as Assistant Executive Director of Education & Accountability ata imes relevant to this complaint. Di ctor of Accountability was charged with responsibil forthe development and execution of the Alpha Chapters education and assessment strategy, including leadership development programs, officer and key commite chairman resources, member education, chapter visor taining and resources, and prevention education. Further, Direcoe of Accountability ‘oversaw the implementation ofthe Alpha Chapt’ sk management policies and managed the individual member and Alpha Chapter conduct processes. Director of Accountability was acting within the course and scope of his employment atthe ime the causes of action arose 9. That Defendant Shawn Daily (hereinafter “Member Agent 1") is, at ll times relevant to this complaint a resident of Charleston County, South Carolina and was @ member agent ofthe Alpha Chapter and acting tthe direction and on behalf of the Alpha Chapter and within the course and scope of his agency atthe time the causes of ation arose 10. That Defendant Matthew Louge (hereinafter “Member Agent sa all ines relevant to tis complaint, a resident of Charleston County, South Carolina end was a member agent ofthe Alpha Chapter and acting tthe direction and on behalf ofthe Alpha Chapter within the course and scope of his agency a the time the causes of aston arose 11, That Defendant Nikos Lara (hereinater“Member Agent 3") is, tall times relevant to this complain resident of Charleston County, South Carolina and was a member agent ofthe Alpha Chapter and acting a the direction and on behalf ofthe Alpha Chapter within the couse and scope of his agency atthe ime the eases of ation arose 12, That Defendant Steve Leone (hereinafter “Member Agent 4" i, at all ies relevant to this complaint, a resident of Charleston County, South Carolina and was a memberagent of the Alpha Ctapter and acting atthe direction and on behalf ofthe Alpha Chapter within the course and Scope of his ageney a the time the eauses of action arose 13, That venue is proper in this Court pursuant to § 1-7-30 South Carolina Code of Laws Annotated 14, That this Court has personal jurisdiction over the parties and subject matter Jjutisdition over the elaims set forth herein. CASE OVERVIEW 15. The Stpreme Court of South Carolina sad, “It is a trite saying that charity begins at home...men and corporations alike are required to be just before being charitable...” The Supreme Court recognized the irony presented under the facts set forth below: “it is almost contradictory to hold that an institution organized to dispense charity shall be charitable and extend aid to others, but shall not compensate or aid those injured by it in carrying on its activites." Fitzer Greater Greenville South Carolina Young Men's Christian Ass'n, 277 S.C. 1, 4,282 SE. 24 230, 232 (1981) (qucting Geiger v. Simpson Methodist-Episcopal Church of Minneapolis, 174 Minn. 389, 219 N.W. 463, 465 (1928)). 16, This ase arises out of the “anything goes” custom and culture created by Pi Kappa ‘within its Alpha Chapter, leading to the brutal beating of Plaintiff by and at the direction ofits ‘member agents, Their repeated and continuous drug and alcohol sbuse, multiple incidents of hazing and ats of violence, and refusal to implement, follow and enforce risk management poli ‘over the course of several years were ignored by the Defendants, inclu Chapter Advisor, Director of Prevention Education, Director of Accountability and others, who instead, conspired to cover up these act to protect the interests and image of Pi Kappa at all costs 17. ‘This ease isnot just about the lions, but those who let the lions out oftheir cage.18, On April 15-16, 2017, Alpha Chapter hosted an initiation pany a the Pi Kappa fiatemity house wherein it supplied copious amounts of sleobol and illegal drugs wo its member agents and guess. 19, Amargument occurred between the Pliniff and a newly initiated member agent of Pi Kappa 20, Pst was forceflly kicked out ofthe party, and member agents of Pi Kappa threatened toil him ihe ever returned 21, Shortly thereafter, Plinf ecived writen threat from a member agent of Pi Kappa that eighy (80) ofhis brothers were coming to bury him. 22, As promised, four (4) member agents of Pi Kappa broke into the personal residence of Paint and physically beat him toa pulp, leaving him in and out of consciousness, profisly bleeding, and ples. 23, Pi Kappa member agents then spread the won! oftheir succesful Inching of Plain roughout the fraternity and college campus. 24, Chapter Advisor immestately insted the member agents to take all ection necessary 10 prevent Plaintiff from seeking medics! weatment or having any furher communication with law enforcement 25, As instructed, two (2) member agents collected Plaintiff fom his residence and hed him eapve forthe remainder ofthe nigh 26, While being estrained, Plait was personally contacted by Chapter Advisor, who inno uncertain terms, strongly discouraged him from seeking any medical treatment for his: ‘or having any addtional contact with law enforcement.27 Plas iff was finally returned to his residence and escorted inside by member agents only after they were certain Plaintiff would comply with these instructions. 28. At all times prior to, during, and following the above, the sole focus of the Defendants was to protec the interests and image of Pi Kappa at all costs, even atthe expense of Plain FACTUAL ALLEGATIONS. 29. That Pi Kappa was “founded on the premise of creating leadership opportunities for our members. Our founders exemplified leadership inthe classroom, on the athletic field, in ‘campus politics and within the community of Charleston. Leadership is the very root of our organization, and it is the concept of leadership that shall guide us to our future” bupi/hvwnw pikapp org/content aspx 2id=162 30, That the members of which Pi Kappa censiders to be “notable, famous, and considered to be Pi Kappa's most prestigious and dedicated members” are: Carrol A. Campbell, J (Sigma ~ South Carolina, Former Governor of SC), Lindsey Graham (Alpha ~ Charleston. US ‘Senator - SC), Emest “Fritz” Hollings (Alpha ~ Charleston. Former US Senator ~ SC), Olin D, Johnston (Zeta ~ Wofford. Former Govemor of SC), George B. Timmerman, J. (Sigma ~ South Carolina, Former Governor of SC), Glenn MeConnell (pha ~ Charleston, President ~ College of Charleston). ttp://wowwpikapp org/content.aspxTid484, 31. That the mission of Pi Kappa is, “to create an uncommon and lifelong brotherhood that develops leaders and encourages service to others forthe betterment of our communities up ww pis tent aspx ?id=162. 32, That the vision of Pi Kappa is, “a future where every Pi Kappa Phi embraces his role as leader, puts service before self and improves the world around him”. hips! pikepp orgleontent espxideI33, That the student creed values of Kappa are “common loyalty, personal responsibilty, achievement, accountability, campus involvement responsible cizenshp, lifelong commitment.” p/w: pikappony/ontent asp id“162. “That the creed of Pi Kappa is, Tbeliove thatthe ideal chapter is made up of men ‘Who are bound together in a common loyalty which transcends any personal selfishness; ‘Who realize that membership means personal responsibility in bearing their share ofthe financial burden of the chapter andthe national organization; ‘Who bring edit to the fraternity by striving to attain the highest possible standards of scholarshi ‘Who safeguard the reputation of their chapter bby keeping careful watch over their personal conduct; ‘Who uphote faithfully the traditions and activities of their college; ‘Who prepare themselves diligently to shoulder their full responsibilty as citizens {believe that my chapter ean become an ideal chapter, ‘nd [shall do my share to make hin pikapporg/content.aspxZid=164 34. That at the 534 Supreme Chapter in 2012, Pi Kappa adopted the following Statement of Position on Alcohol Abuse: ‘The Supreme Chapter and the National Council of Pi Kappa Phi Fraternity, acting out of concem for the safety and well-being of our members, therefore oppoee alcohol sbuse by members ofthe Fraternity, regurless of ‘whether the behavior occurs ata fraternity event Pi Kappa Phi defines alcohol abuse as the type of overuse that causes irresponsible behavior, a dangerous loss of reaction time, physical illness ind damage to personal relationships. This abuse may occur ina solitary incident of in a chronie behavior pattern.‘The fraternity believes alcohol abuse prevents individual members from achieving ther full potential as citizens and exemplifying the characteristics ‘of true brotherhood. Consequently, Pi Kappa Phi works to address the negative behaviors associated with alcohol misuse and abuse, and not simply the location of those behaviors. ‘Through education, training and mature adult guidance, Pi Kappa Phi provides the tools to help students make gocd choices and to understand the consequences of their choices. The naticnal fraterity will continue to provide information about alcohol abuse, as well as counseling resources, ‘8 pat ofits comprehensive prevention education strategy. hupy/wonw pikapp.org/content aspx 7ide 69 38. Thatat the 53° Supreme Chapter in2012, Pi Kappa adopted the following Statement of Postion on Hazing: ‘The Supreme Chapter and the National Cosneil of Pi Kappa Phi Fraternity unequivocally oppose all acts of hazing. The national fraternity, as well as ‘most universities and states, define hazing as any action taken or situation created, intentionally, whether on or off aterity premises, to produce ‘mental or physical discomfort, embarrassment, harassment or ridicule, regardless of a person's willingness to patcipate. While the fratemity’s risk management policy provides a list of activities that may constitute hhazing, Pi Kappa Phi expects its chapters to provide an atmosphere where all members, associate members and guests feel safe by ensuring respect for ‘human dignity i a chief priority. Additionally, members of the Fraternity ‘are expected to hold each other accountable to our shared standards Al alleged incidents of hazing will be investigated and adjudicated in accordance with the fraterity's disciplinary code. Any member found in violation of Pi Kappa Phi's hazing policy will be sanctioned in accordance withthe code. Such sanctions may include suspension and expulsion from the fraternity ‘Members and associate members who are aware of behavior that is inconsistent with this statement or Pi Kappa Phi's hazing policy should ‘contact the fratemity’s National Heacquarters at (704) 504-0888, p/w pikanp,org/eontent aspx?id=109, 36, That at the 53" Supreme Chapter in 2012, Pi Kappa adopted the following Statement of Postion on Risk Management: i Kappa Phi Fraterity’s risk management policy (FIPG) shall apply to all fraternity entities and all levels of fraternity membership. The fraternity expects all members to comply with any and all applicable laws ofthe state, province, county, city and institution of higher education. Pi Kappa Phi °expects that chapter houses meet all local fire and health codes and standards at all times. Additionally, the possession andlor use of firearms, explosives or incendiary devices of any kind shall not be allowed on the premises ofthe chapter house ‘Through education, training and mature adult guidance. Pi Kappa Phi provides the tools to help students make good choices and to understand the consequences of their choices. The fraternity will hold chapters and individual members accountable for the choices they make, itp, content aspxTid=169, 37, That at the $3% Supreme Chapter in 2012, Pi Kappa adopted the following Statement of Position on Substance Abuse: ‘The Supreme Chapter and the National Council Pi Kappa Phi Fraternity, realizing that substance abuse prevents individual members from achieving their full potential as citizen and exemplifying the characteristics of true brotheriood, oppose substance abuse at all times. Substances are broadly Gefined as items that, when absorbed into the body, alter normal bodily function, Substances include, but are not limited to, illegal drugs, as well as prescription drugs used in a manner contrary to theit instructions or by someone to whom they were not prescribed. ‘The fratemity believes strongly in the betterment of men through our chapters and has consequently adopted a philosophy statement outlining its approach to illegal drugs and other controlled substances. Pi Kappa Phi also ‘expects members to follow federal and state drug laws across the United States, Pi Kappa Phi is concered about the impact drugs and other mind-altering substances have onthe safety and lifelong well-being of ours (si) members, as wel a the reputation of the fraternity. Through education, training, and ‘mature adult guidance, Pi Kappa Phi provides the tools to help students make good choices and to understand the consequences of their choices. The national fraternity will continue to incorporate infor substance abuse, as well as counseling resources, into i education initiatives. hitp:Jwonw pik tent aspx id 38 That Pi Kappa has a documented history, which is way too long to exhaustively catalogue in this Complaint, of alcohol abuse, hazing, disorderly conduct, violence, racism, feminism, hosting unapproved events, harassment, physical and verbal abuse, vandalism, and drug, use within its chapters. htnsi//en. wikipedia orgviki/Pi_ Kappa Phi 0