fil

f ll

HOV

 1P

 :

u

r

W

IN

THE

COURT

OF

COMMON

PLEAS

LORAIN

COUNTY

OHIO

17

CVl

9376

 

IBSON

BROS.

INC.

23

West

College

Street

Oberlin OH

44074

C SE

NO.

 

ttjdgeJUDGE

JOHN

R

MIRALD

nd

TYPE:

LIBEL/

SLANDER/

TORTIOUS

INTERFERENCE

WITH

BUSINESS

RELATIONSHIPS/

TORTIOUSINTERFERENCE

WITH

CONTRACT/

DECEPTIVETRADE

PRACTICES/

INTENTIONAL

INFLICTION

OF

EMOTIONAL

DISTRESS/

NEGLIGENTHIRING/

RETENTION/SUPERVISION/

TRESPASS

DAVID

R.

GIBSON

20

Hawthorne

Drive

Oberlin OH

44074

and

ALLYN

W.GIBSON

189

WestCollege

St.

Apt.

E

Oberlin OH

44074

Plaintiffs

JURYDEMAND

ENDORSED

HEREON

 

OBERLIN

COLLEGE

aka

OBERLIN

COLLEGE

ANDCONSERVATORY

c/o

Carmen

Twillie

Ambar

president

173

WLorain

St.

Oberlin OH

44074

And

MEREDITH

RAIMONDO

256

Shipherd

Cir.Oberlin OH

44074

Defendants.

01837109 2/

12000.00-0027

 

COMPLAINT

Plaintiffs,

GibsonBros.,

Inc.(herein

 Gibson'sBakery ),

David

R.

Gibson,

and

Alyn

W.

Gibson

(hereinafter

collectively Paintiffs ),

by

and

through

counsel,

for

theirComplaint

against

the

Defendants,

Oberlin

College

aka

Qberlin

College

and

Conservatory(hereinafter

 Oberlin

College )

and

Meredith

Raimondo

( Raimondo )

state

the

following:PARTIES

AND

INTRODUCTION

Paintiff,

Gibson's

Bakery,

is,andat

all

timesrelevant

tothis

action

was,

a

.

corporation

in

goodstandingorganizedunder

the

laws

of

the

State

of

Ohio

and

operating

at

23

West

College

St.,

Oberlin,

Ohio.

Paintiff

David

R.

Gibson

is

an

Ohioresident

and

is

an

owner

and

employee

of

.

Gibson's

Bakery.

Plaintiff

Alyn

W.

Gibson

is

an

Ohio

resident

andis

an

owner

and

employee

of

.

Gibson's

Bakery.

Upon

information

and

belief,Oberlin

College

is

a

corporation

incorporated

by

.

special

legislative

act

and

located

at

173

W

Lorain

St,

Oberlin,OH

44074,

and

is

also

known

as

and/orreferred

to

as

Oberlin

College

and

Conservatory.

Upon

information

and

belief,

Raimondo

is

an

Ohio

resident

andisthe

Vice

.

President

and

Dean

of

Students

of

Oberlin

College

and

has

been

in

that

position

since

approximately

April

2016.

Gibson's

Bakery

has

been

a

local,

family-owned

and

operated

business

for

well

.

over

a

century.

In

1885,

David

Gibson's

great-grandfather

startedthebusiness

with

a

pushcart,

.

andthebusiness

has

beenat

its

present

location

in

Oberlin

since

1905.

2

1837109-2/

12000.00-0027

 

8

Throughout

its

existence,

Gibson'sBakery

has

worked

to

maintain

its

reputation

asa

community-minded

family

business

providing

quality

product

and

service

to

the

Oberlin

community,

includingOberlin

College

students,

faculty,

staff,

and

visitors.

OBERLIN

COLLEGECAMPUS

TURMOIL

9.

In

recent

years,

Oberlin

College

has

found

itself

at

thecenter

of

controversies

that

threatenedthe

reputation

and

financial

welfare

of

the

college.

10.

As

part

of

its

business

plan

and

public

relations

campaignto

benefit

itsimage

and

attract

students,

Oberlin

College

markets

itself

as

having

a

legacy

of

being

a

strong

advocate

for

and

a

strong

supporter

of

African-American

students

and

racialminorities.

11.

Inapproximately

December2015,

Oberlin

College

came

under

pressure

for

its

treatment

of

African-

American

students.

Inapproximately

December2015,

students

sent

a

14-page

list

of

demands

to

2.

Oberlin

College'sBoard

of

Trustees,

Oberlin

College's

President

MarvinKrislov,

and

Oberlin

College's

seniorleadership.

13.

As

part

of

that

14-page

list

of

demands,thestudents

asserted

that:

Oberlin

College

and

Conservatory

is

an

unethical

institution...In

the

1830s,

this

school

claimed

a

legacy

of

supportingits

Black

students.

However,

thatlegacy

has

amountedto

nothing

morethan

a

public

relations

campaign

initiated

to

benefit

the

image

of

the

institution

and

not

the

Africana

people

it

was

set

outfor.

One

of

the

students'

demandswas

that

Oberlin

College

offer

 guaranteed

tenure

4.

to

JoyKarega,

an

African-

American

professor

who

had

written

articles

claiming

that

Israeli

and

U.S.

Intelligence

agencies

fund

ISIS

and

that

Israel

planned

the

September

11,

2001

attacks

in

theU.S.

At

the

time,

Joy

Karega

was

an

Assistant

Professor

of

Rhetoric

&

Composition

at

Oberlin

College.

3

1837109-2/

12000.00-0027