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MECKLENBURG COUNTY BOARD OF ELECTIONS Page 1 of 1

VOTER PROFILE

Full Name: KRYST, CHESLIE CORRINNE VRN: 001000409820


Residence Age:
Address:
222 E BLAND ST # 336 30
CHARLOTTE, NC 28203 Register Date: 09/18/2017
Mailing Address 60 W 57TH ST APT 14B
on File: Status: A
NEW YORK NY 10019

Sex: FEMALE
Race: M Ethnicity: NL
Party: DEMOCRATIC
Birth Place: MI
Districts Voting History (36 Most Recently Voted Elections )
11/03/2020 11/03/2020 GENERAL
PRECINCT: 022
11/06/2018 11/06/2018 GENERAL
MUNI: CLT
CITY COUNCIL: 3 11/07/2017 11/07/2017 GENERAL
CONGRESS: 14
SUPERIOR COURT: 26E
JUDICIAL: 26
SENATE: 39
HOUSE: 088
COUNTY COMMISSIONER: 2
SCHOOL: 2
PROSECUTORIAL: 26
VOTING TAB DIST: 022

I CERTIFY THAT THIS INFORMATION IS TRUE AND ACCURATE. Signature: ____________________________________________________________ Date: 04/01/2022

Apr 1 2022 4:15PM


EXHIBIT 1.
12/3/23, 6:46 AM Gmail - Public Records Act Request

Michael Ayele <waacl13@gmail.com>

Public Records Act Request


Williams, Mona <mona.williams@cco.sccgov.org> Mon, Sep 18, 2023 at 7:44 PM
To: "waacl13@gmail.com" <waacl13@gmail.com>, "waacl1313@gmail.com" <waacl1313@gmail.com>,
"waacl42913@gmail.com" <waacl42913@gmail.com>

Dear Mr. Ayele (W),

The County of Santa Clara (“County”) has designated the Office of the County Counsel as the office responsible for
receiving and coordinating public record requests, and as such, I am providing an initial response to your September 7,
2023, California Public Records Act (“CPRA”) request, which is attached. Pursuant to California Government Code
section 7922.535(b) and (c)(1), the County extends its time for responding to your request by an additional 14 days to
search for and collect requested records from offices other than the Office of the County Counsel.

The County will provide a response to your request by Monday, October 2, 2023.

Thank you,

Mona Mabengi Williams | Deputy County Counsel

Office of the County Counsel, County of Santa Clara

70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110

Office: (408) 299-5922 | Mobile: (669) 235-1956

mona.williams@cco.sccgov.org | counsel.sccgov.org

NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If
you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office
of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system.

Records Request on Brock Turner Sept 2016 College Speaking Tour After 90 Days in County Jail for Sexual
Assault of Chanel Miller.pdf
1968K

https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1777394507752700387&simpl=msg-f:1777394507752700387 1/1
12/3/23, 6:48 AM Gmail - Public Records Act Request

Michael Ayele <waacl13@gmail.com>

Public Records Act Request


Williams, Mona <mona.williams@cco.sccgov.org> Mon, Oct 2, 2023 at 7:18 PM
To: "waacl13@gmail.com" <waacl13@gmail.com>, "waacl1313@gmail.com" <waacl1313@gmail.com>,
"waacl42913@gmail.com" <waacl42913@gmail.com>

Dear Mr. Ayele (W),

Attached please find the County’s production in response to your September 7, 2023, CPRA request, which is attached.
Please note that the County redacted information that is not subject to disclosure in response to a CPRA request;
information for which the public interest in not disclosing the information clearly outweighs the public interest in disclosure;
and other information that is non-responsive to your request or constitutes the private personal information of third
parties. (See Gov. Code, § 7922.000; Evid. Code, § 1040; Cal. Const., art. 1, § 1.)

This production completes the County’s response to your request under the CPRA; the County will be closing out your
request.

Kind regards,

Mona Mabengi Williams | Lead Deputy County Counsel

Office of the County Counsel, County of Santa Clara

70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110

Office: (408) 299-5922 | Mobile: (669) 235-1956

Pronouns: she/her/hers

mona.williams@cco.sccgov.org | counsel.sccgov.org

NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If
you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office
of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system.

From: Williams, Mona


Sent: Monday, September 18, 2023 9:45 AM
To: waacl13@gmail.com; waacl1313@gmail.com; waacl42913@gmail.com
Subject: Public Records Act Request

Dear Mr. Ayele (W),

https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1778661207308023564&simpl=msg-f:1778661207308023564 1/2
12/3/23, 6:48 AM Gmail - Public Records Act Request
The County of Santa Clara (“County”) has designated the Office of the County Counsel as the office responsible for
receiving and coordinating public record requests, and as such, I am providing an initial response to your September 7,
2023, California Public Records Act (“CPRA”) request, which is attached. Pursuant to California Government Code
section 7922.535(b) and (c)(1), the County extends its time for responding to your request by an additional 14 days to
search for and collect requested records from offices other than the Office of the County Counsel.

The County will provide a response to your request by Monday, October 2, 2023.

Thank you,

Mona Mabengi Williams | Deputy County Counsel

Office of the County Counsel, County of Santa Clara

70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110

Office: (408) 299-5922 | Mobile: (669) 235-1956

mona.williams@cco.sccgov.org | counsel.sccgov.org

NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If
you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office
of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system.

2 attachments
9.7.2023_Brock-Turner.pdf
1930K
B.Turner_Report of Probation_redacted.pdf
6882K

https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1778661207308023564&simpl=msg-f:1778661207308023564 2/2
EXHIBIT 2.
COUNTY OF KANE
719 Batavia Avenue
Kane County Geneva, Illinois 60134
Finance Department (630) 208-5112
Website: www.countyofkane.org

W (AACL) - Michael A. Ayele


waacl13@gmail.com
W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia , Addis Ababa, 10013
9355284300
Association for the Advancement of Civil Liberties (AACL)

9/12/2023

Thank you for writing to the County of Kane Finance Department with your request for information pursuant to the Illinois
Freedom of Information Act, 5 ILCS 140/1 et seq.

On September 5, 2023 you submitted the following FOIA Request to the Kane County Finance Department:

Hello,

This is Michael A. Ayele sending this message though I now go by W. You may call me W. I am
writing this letter for the purpose of filing a request for records with your office.[i] The bases for
this records request are [1] the September 2016 rumored Brock Turner “college speaking
tour” on the subject of “alcohol and promiscuity” after he had spent 90 (ninety) days in county
jail for sexually assaulting Chanel Miller while she was unconscious;[ii] [2] the dissenting
opinion issued by Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown
Jackson in the Students for Fair Admissions v University of North Carolina as well as President
and Fellows of Harvard College case. [iii]

I) Records Requested

What I am requesting for prompt disclosure are records in your possession detailing your
discussions about [1] Brock Allen Turner as a Caucasian man, who (i) began attending Stanford
University as a Freshman student sometime in (or around) the month September 2014; (ii) was
more likely than not informed what constitutes “affirmative and effective consent” in healthy
sexual relationships when he was a Freshman undergraduate student of Stanford
University;[iv] (iii) was on (or around) January 10th 2015 accused of being sexually
inappropriate with a female student who was (also) attending Stanford University;[v] (iv) was on
(or around) January 18th 2015 arrested for sexually assaulting Chanel Miller behind a dumpster
(on the campus of Stanford University) while she was unconscious;[vi] (v) was on (or around)
March 30th 2016 found guilty of sexually assaulting and sexually penetrating Chanel Miller
while she was unconscious despite his claims that he had not done so;[vii] (vi) was not remanded
to custody on (or around) March 30th 2016 even though he had been found guilty of sexually
assaulting Chanel Miller while she was unconscious; [viii] (vii) was on June 02nd 2016
sentenced to 6 (six) months of county jail for the sexual assault he perpetrated on Chanel Miller;
(viii) has gone on to be released from the Santa Clara county jail on (or around) September 02nd
2016 after serving 90 (ninety) days of the six months jail sentence; (ix) was in the month of
September 2016 reported to have seriously considered going on a “college speaking tour” to
warn young people of the risks associated with “alcohol drinking and promiscuity;” [2] Chanel
Miller as a woman of Asian descent, who (i) was very much vexed by the 6 months jail sentence
handed to Brock Turner on June 02nd 2016;[ix] (ii) believes that her life is worth significantly
more than the 90 day prison sentence Brock Turner ended up serving after he had sexually
assaulted her;[x] (iii) has had a very unpleasant phone call with a probation officer in Santa
Clara, California following the conviction of Brock Turner on March 30th 2016;[xi] [3] the
decision of Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson
to note that “it is not a stereotype to acknowledge the basic truth that young people’s experiences
are shaded by a societal structure where race matters;” [4] fear of public speaking (or
glossophobia) ranking as one of American’s greatest fears. [xii]

II) Request for a Fee Waiver and Expedited Processing

The requested records do/will demonstrate that [1] Michael A. Ayele (a.k.a) W is a Black man,
who has never denied (i) having come to the United States of America (U.S.A) on an F-1 Visa in
the month of December 2009 for the purpose of obtaining a Bachelor of Arts (B.A) Degree from
Westminster College (Fulton, Missouri); (ii) having been informed what constitutes “affirmative
and effective consent” in healthy sexual relationships during Calendar Year 2010 when he was
an undergraduate student of Westminster College (Fulton, Missouri); (iii) having been informed
about the April 05th 1986 rape and murder of Jeanne Ann Clery during Calendar Year 2010
when he was an undergraduate student of Westminster College (Fulton, Missouri); (iv) having
taken issue with manner in which he was informed about the rape and murder of Jeanne Ann
Clery as well as the way he was informed about “consent;” (v) having initiated contact with the
Department of Justice (DOJ) Federal Bureau of Investigation (FBI) as well as the Central
Intelligence Agency (CIA) about the April 05th 1986 rape and murder of Jeanne Ann
Clery;[xiii] (vi) having become a member of the San Francisco Public Library (SFPL) sometime
in the months of November/December 2014; (vii) having initiated contact with the SFPL about
Chanel Miller’s memoir entitled: “Know My Name;” [xiv] [2] Chanel Miller is a woman of
Asian descent, who (i) was on January 18th 2015 sexually assaulted (by Brock Turner) behind a
dumpster on the campus of Stanford University; (ii) is an alumna of the University of California,
Santa Barbara (UCSB); (iii) became an alumna of the UCSB after having been traumatized by
the May 23rd 2014 horrific incident near that campus; (iv) recommended for Brock Turner to
seek mental health counseling because she was afraid that he might do something similar to what
Elliot Rodger did on May 23rd 2014;[xv] (v) who has never explicitly opposed the 6 (six) year
prison sentence recommended by Alaleh Kianerci after Brock Turner was found guilty of
sexually assaulting and sexually penetrating her; [3] Supreme Court Justices Sonia Sotomayor,
Elena Kagan and Ketanji-Brown Jackson are women, who have (during the month of July 2023)
been subjected to extensive media interest for writing (in part) that “it is not a stereotype to

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acknowledge the basic truth that young people’s experiences are shaded by a societal structure
where race matters.”

In my judgment, the facts presented in my request for a fee waiver and expedited processing are
not the sort to bolster public confidence in the activities, the engagements and the priorities of
the U.S government (overall), but more particularly in those of the U.S judicial branch of
government. As a Black man with a U.S college degree, who was in January 2010 informed what
constitutes “affirmative and effective consent” in healthy sexual relations, I would like to take
this opportunity to [1] condemn violence committed against women irrespective of their racial
backgrounds, their sexual orientations, their national origins, their religious affiliations and/or
their disability status; [2] condemn the rape and murder Jeanne Ann Clery was victim of on April
05th 1986 when she was an undergraduate student of Lehigh University (located in the State of
Pennsylvania); [3] condemn the sexual assault Chanel Miller was victim of on January 18th 2015
on the campus of Stanford University (located in the State of California); [4] express in writing
the outrage I felt upon learning (sometime) in June 2016 that Brock Allen Turner was very likely
going to be spending 90 (ninety) days in county jail even though he was on March 30th 2016
found guilty of sexually assaulting and sexually penetrating Chanel Miller on the campus of
Stanford University; [5] condemn the discrimination, the racism, the sexism and the many
double standards I have had to (i) bear witness to and/or (ii) experience in person; [6] condemn
gun related violence committed in the United States of America (U.S.A) and/or elsewhere
around the globe; [7] condemn the horrific incident perpetrated on May 23rd 2014 near the
UCSB by the sexist involuntary celibate (incel) Elliot Rodger.

The core issues presented in this records request are as follows. 1) Have you ever had
conversations about Americans fear of public speaking? If yes, will you promptly disclose those
records? 2) Have you ever had conversations about the privilege and the entitlement a person is
born into if that person feels audacious enough to go on a “college speaking tour” for the
purpose lecturing young people on subjects such as “alcohol drinking and promiscuity” after
having registered as a sex-offender? If yes, will you will promptly disclose those records? 3)
Have you ever had conversations about the privilege and the entitlement a person is born into if
that person feels audacious enough to go on a “college speaking tour” for the purpose of
lecturing young people on subjects such as “alcohol drinking and promiscuity” after having been
found guilty of sexually assaulting a woman of color? If yes, will you promptly disclose those
records? 4) Have you ever had conversations about the 90-day jail sentence Brock Allen Turner
served between June 02nd 2016 and September 02nd 2016 after he had been found guilty of
sexually assaulting Chanel Miller (while she was unconscious)? If yes, will you promptly
disclose those records? 5) Have you ever had conversations about the reasons why Brock Allen
Turner spent 90 days in county jail after he was found guilty of sexually assaulting Chanel Miller
(while she was unconscious)? If yes, will you promptly disclose those records? 6) Have you ever
had conversations about the strong likelihood that Brock Allen Turner was informed what
constitutes “affirmative and effective consent” when he was an undergraduate student of
Stanford University during Calendar Years 2014 – 2015? If yes, will you promptly disclose those
records? 7) Have you ever had conversations about the reasons why female undergraduate
students continue to suffer sexual violence (at alarming rates) even though the men are informed

3|Page
what constitutes “affirmative and effective consent” during the course of their First (1st) year of
post-secondary academic education/training (related to Title IX sessions)? If yes, will you
promptly disclose those records? 8) Have you ever had conversations about “consent” being a
politically contentious issue when it’s being addressed/dealt with by a Black man similarly
situated to Michael A. Ayele (a.k.a) W? If yes, will you promptly disclose those records? 9)
Have you ever had conversations about the dissenting opinion issued by Supreme Court Justices
Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson in the matter of Students for Fair
Petition v University of North Carolina as well as Presidents and Fellows of Harvard
College? If yes, will you promptly disclose those records? 10) Have you ever had conversations
about the decision of Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown
Jackson to note that “it is not a stereotype to acknowledge the basic truth that young people’s
experiences are shaded by a societal structure where race matters?” If yes, will you promptly
disclose those records? 11) Have you ever had conversations about the May 23rd 2014 shooting
and stabbing incident that was perpetrated by sexist incel Elliot Rodger near the UCSB? If yes,
will you promptly disclose those records? 12) Have you ever had conversations about the reasons
why Chanel Miller recommended for Brock Allen Turner to seek mental health therapy taking
into account that she’s an alumna of UCSB who was traumatized by the May 23rd 2014 incident
near that campus? If yes, will you promptly disclose those records? 13) Have you ever had
conversations about the reasons why the Santa Clara County Probation Department never asked
Chanel Miller (in their discussions with them) if she was objecting to the 6-year prison sentence
that had been recommended by District Attorney Alaleh Kianerci after Brock Turner was on
March 30th 2016 found guilty of sexually assaulting Chanel Miller? If yes, will you disclose
those records? 14) Have you ever had conversations about the decision of the State of California
to (i) expand the legal definition of rape and (ii) impose mandatory minimum sentences
following the 90 days of county jail served by Brock Turner for the sexual assault of Chanel
Miller? [xvi] If yes, will you promptly disclose those records?

This records request should be expedited because it puts into question the government’s integrity
about the way that people are treated in the U.S.A on account of their gender, their racial
backgrounds, their national origins and their disability status. My request for a fee waiver should
be granted because [1] I have identified operations and activities of the federal government in
concert with U.S local/state government; [2] the issues presented are meaningfully informative
about government operations or activities in order to be ‘likely to contribute’ to and increase
public understanding of those operations or activities; [3] this records request is being filed for
non-commercial purposes and any records you disclose to me could be made available to the
general public at no financial expense to them. Under penalty of perjury, I hereby declare all the
statements I have made to be true and accurate. Be well. Take care. Keep yourselves at arms
distance.

W (AACL)

Michael A. Ayele

4|Page
Anti-Racist Human Rights Activist

Audio-Visual Media Analyst

Anti-Propaganda Journalist

Work Cited

[i] Please be advised that I have previously disseminated a vast number of documents obtained
through records request using the means of various digital publishing platforms. As a
representative of the media, I would like to take this opportunity to inform you that the records
you disclose to me could be made available to the general public at no financial expense to them.
This records request is being filed for non-commercial purposes. As previously noted, any
records disclosed to me could be made available to the general public at no financial expense to
them. On December 10th 2021, I have launched a website on Wordpress.com for the purpose of
making the records previously disclosed to me by the U.S government further accessible to
members of the general public interested in the activities of their elected and non-elected
representatives. You can find out more about the recent publications of the Association for the
Advancement of Civil Liberties (AACL) here.: https://michaelayeleaacl.wordpress.com/

[ii] September 09th 2016 Conversation Between Cenk Uygur and Ana Kasparian on the Subject
of Rapist Brock Turner “College Speaking Tour”

Ana Kasparian.: As if the injustice involved in the Brock Turner case couldn’t get any worse,
there are now reports that he could possibly tour high-school campuses in order to give speeches
to students about the negative impact of alcohol and promiscuity. (…) So, during this case, and
for those of you who might have missed this story, Brock Turner was the former Stanford
University swimmer who was caught raping a woman who was unconscious behind a dumpster.
He was found guilty and he got a six months jail sentence that was cut short to only three months
because of “good behavior.”

According to Mediaite, “there was talk during the trial of him launching a speaking tour during
which he would visit high schools and give lectures on ‘drinking and promiscuity,’ and now that
idea is back in the spotlight.” This story is now in the spotlight because a Stanford University
professor (Ruth Starkman) just wrote an opinion piece in the Huffington Post in which she very
correctly stated: “Until Brock Turner apologizes, he should not be allowed to speak on
campuses. Any campus appearance must be conditioned on his taking full responsibility for his
actions, apologizing to the victim, and condemning sexual assault.” He has refused to do all
three things even after his convictions. (…)

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Cenk Uygur.: To me, the most unbelievable part of the story (…) is the drinking part. It seems
like he’s saying: “Don’t drink too much. Otherwise, you will go on to rape women behind a
dumpster.”

Ana Kasparian.: Yeah, there are plenty of people who drink, get drunk and aren’t immediately
convinced that it’s a good idea to go rape people.

Cenk Uygur.: It seems like he didn’t get it at all. (…) It definitely sounds as though he’s looking
to go around campuses saying that she (Chanel Miller) wasn’t raped. (…) She was being
promiscuous.

Ana Kasparian.: That’s exactly right!

Cenk Uygur.: Oh my God! (…)

Ana Kasparian.: He could possibly do this speaking tour and get paid for it! (…) His message is
a really bad message that rewards bad behavior. (…)

Cenk Uygur.: The bigger injustice is that he gets a lenient sentence while others do not. We have
an unequal justice system. I don’t want people coming away from this thinking: “We’ve got to be
harsher on all defendants.” We just want an equal justice system. Either treat everybody like
Brock Turner or treat everyone harshly, but have one system, not unequal justice. That’s the
main point.

Rapist Brock Turner College Speaking Tour? The Young Turks.


YouTube.: https://www.youtube.com/watch?v=oRTwp0vnbbo&t=96s

[iii] The Equal Protection Clause of the Fourteenth Amendment enshrines a guarantee of racial
equality. The Court long ago concluded that this guarantee can be enforced through race-
conscious means in a society that is not, and has never been colorblind. In Brown v Board of
Education, (…) the Court recognized the constitutional necessity of racially integrated schools in
light of the harm inflicted by segregation and the “importance of education to our democratic
society.” For 45 years, the Court extended Brown’s transformative legacy to the context of
higher education, allowing colleges and universities to consider race in a limited way and for the
limited purpose of promoting the important benefits of racial diversity. This limited use of race
has helped equalize educational opportunities for all students of every race and background and
has improved racial diversity on college campuses. Although progress has been slow and
imperfect, race conscious college admission policies have advanced the Constitution’s guarantee
of equality and have promoted Brown’s vision of a Nation with more inclusive schools.

Today, this Court stands in the way and rolls back decades of precedent and momentous
progress. It holds that race can no longer be used in a limited way in college admissions to
achieve such critical benefits. In so holding, the Court cements a superficial rule of
colorblindness as a constitutional principle in an endemically segregated society where race has
always mattered and continues to matter. The Court subverts the constitutional guarantee of

6|Page
equal protection by further entrenching racial inequality in education, the very foundation of our
democratic government and pluralistic society. Because the Court’s opinion is not grounded in
law or fact and contravenes the vision of equality embodied in the Fourteenth Amendment, I
dissent.

Equal educational opportunity is a prerequisite to achieving racial equality in our Nation. From
its founding, the United States was a new experiment in a republican form of government where
democratic participation and the capacity to engage in self-rule were vital. At the same time,
American society was structured around the profitable institution that was slavery, which the
original Constitution protected. The Constitution initially limited the power of Congress to
restrict the slave trade, (…) accorded Southern States additional electoral power by counting
three fifth of their enslaved population in apportioning congressional seats, (…) and gave
enslavers the right to retrieve enslaved people who escaped to free States (…). Because a
foundational pillar of slavery was the racist notion that Black people are a subordinate class
with intellectual inferiority, Southern States sought to ensure slavery’s longevity by prohibiting
the education of Black people, whether enslaved or free. (…) Thus, from this Nation’s birth, the
freedom to learn was neither colorblind nor equal. (…)

With time, and at the tremendous cost of the Civil War, abolition came. More than two centuries
after the first African enslaved persons were forcibly brought to our shores, Congress adopted
the Thirteenth Amendment to the Constitution, which abolished “slavery” and “involuntary
servitude, except as a punishment for crime.” (…) “Like all great historical transformation,”
emancipation was a movement, “not a single event” owed to any single individual, institution or
political party. (…) The fight for equal educational opportunity, however, was a key driver.
Literacy was an “instrument of resistance and liberation.” (…) Education “provided the means
to write a pass to freedom” and “to learn of abolitionist activities.” (…) It allowed enslaved
Black people “to disturb the power relations between master and slave,” which “fused their
desire for literacy with their desire for freedom.” (…) Put simply, “the very feeling of inferiority
which slavery forced upon Black people fathered an intense desire to rise out of their condition
by means of education.” (…)

Racially integrated schools improve cross-racial understanding, “break down racial


stereotypes,” and ensure that students obtain the “skills needed in today’s increasingly global
marketplace…through exposure to widely diverse people, culture, ideas and viewpoints.” (…)
More broadly, inclusive institutions that are “visibly open to talented and qualified individuals
of every race and ethnicity” instill public confidence in the “legitimacy” and “integrity” of those
institutions and the diverse set of graduates they cultivate. That is particularly true in the context
of higher education, where colleges and universities play a critical role in “maintaining the
fabric of society” and serve as “the training ground for a larger number of our Nation’s
leaders.” (…) It is thus an objective of the highest order, a “compelling interest” indeed, that
universities pursue the benefits of racial diversity and ensure that the “diffusion of knowledge
and opportunity” is available to students of all races.

This compelling interest in student body diversity is grounded not only in the Court’s equal
protection jurisprudence but also in principles of “academic freedom,” which “long have been
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viewed as a special concern of the First Amendment.” In light of the “important purpose of
public education and the expansive freedoms of speech and thought associated with the
university environment,” this Court’s precedents recognize the imperative nature of diverse
student bodies on American college campuses. Consistent with the First Amendment, student
body diversity allows universities to promote “the robust exchange of ideas which discovers
truth out of a multitude of tongues rather than through any kind of authoritative selection.”
Indeed, as the Court recently reaffirmed in another school case, “learning how to tolerate
diverse expressive activities has always been ‘part of learning how live in a pluralistic society’”
under our constitutional tradition. (…)

In short, for more than four decades, it has been this Court’s settled law that the Equal
Protection Clause of the Fourteenth Amendment authorizes a limited use of race in college
admissions in service of the educational benefits that flow from a diverse student body. From
Brown to Fisher, this Court’s cases have sought to equalize educational opportunity in a society
structured by racial segregation and to advance the Fourteenth Amendment’s vision of an
America where racially integrated schools guarantee students of all races the equal protection of
the laws.

Today, the Court concludes that indifference to race is the only constitutionally permissible
means to achieve racial equality in college admissions. That interpretations of the Fourteenth
Amendment is not only contrary of precedent and the entire teaching of our history, (…) but is
also grounded in the illusion that racial inequality was a problem of a different generation.
Entrenched racial inequality remains a reality today. That is true for society writ large and,
more specifically, for Harvard and the University of North Carolina (UNC), two institutions with
a long history of racial exclusion. Ignoring race will not equalize a society that is racially
unequal. What was true in the 1860s, and again in 1954, is true today: Equality requires
acknowledgment of inequality. (…)

These opportunity gaps “result in fewer students from underrepresented backgrounds even
applying to” college, particularly elite universities. (…) “Because talent lives everywhere, but
opportunity does not, there are undoubtedly talented students with great academic potential who
have simply not had the opportunity to attain the traditional indicia of merit that provide a
competitive edge in the admission process.” (…) Put simply, society remains “inherently
unequal.” (…) Racial inequality runs deep to this very day. That is particularly true in
education, the “’most vital civic institution for the preservation of a democratic system of
government.’” Plyler v Doe. (…) As I have explained before, only with eyes open to this reality
can the Court “carry out the guarantee of equal protection.”

Both UNC and Harvard have sordid legacies of racial exclusion. Because “context matters”
when reviewing race-conscious college admissions programs, (…) this reality informs the
exigency of respondents’ current admissions policies and their racial diversity goals.

For much of its history, UNC was a bastion of white supremacy. Its leadership included
“slaveholders, the leaders of the Ku Klux Klan, the central figures in the white supremacy
campaigns of 1898 and 1900, and many of the State’s most ardent defenders of the Jim Crow
8|Page
and race-based Social Darwinism in the twentieth century.” (…) The university excluded all
people of color from its faculty and student body, glorified the institution of slavery, enforced its
own Jim Crow regulations, and punished any dissent from racial orthodoxy. (…) It resisted
racial integration after this Court’s decision in Brown, and was forced to integrate by court
order in 1955. (…) It took almost 10 more years for the first Black woman to enroll at the
university in 1963. (…) Even then, the university admitted only a handful of underrepresented
racial minorities, and those students suffered constant harassment, humiliation, and isolation.
(…) UNC officials openly resisted racial integration well into the 1980s, years after the youngest
Member of this Court was born. During that period, Black students faced racial epithets and
stereotypes, received hate mail, and encouraged Ku Klux Klan rallies on campus. (…)

To this day, UNC’s deep-seated legacy of racial subjugation continues to manifest itself in
student life. Buildings on campus still bear the names of members of the Ku Klux Klan and other
white supremacist leaders. Students of color also continue to experience racial harassment,
isolation and tokenism. Plus, the student body remains predominantly white: approximately 72%
of UNC students identify as white, while only 8% identify as Black. These numbers do not reflect
the diversity of the State, particularly Black North Carolinians, who make up 22% of the
population. (…)

UNC is not alone. Harvard, like other Ivy League universities in our country, “stood beside
church and state as the third pillar of a civilization built on bondage.” (…) From Harvard’s
founding, slavery and racial subordination were integral parts of the institution’s funding,
intellectual production, and campus life. Harvard and its donors had extensive financial ties to,
and profited from, the slave trade, the labor of enslaved people, and slavery-related investments.
(…) Harvard’s leadership and prominent professors openly promoted “’race science,’” racist
eugenics, and other theories rooted in racial hierarchy. Activities to advance these theories
“took place on campus,” including “intrusive physical examinations” and “photographing of
unclothed” students. The university also “prized the admission of academically able Anglo-
Saxon students from elite backgrounds – including wealthy white sons of the South.” By contrast,
an average of three Black students enrolled at Harvard each year during the five decades
between 1890 and 1940. (…) Those Black students who managed to enroll at Harvard “excelled
academically, earning equal or better academic records than most white students,” but faced the
challenges of the deeply rooted legacy of slavery and racism on campus. (…) Meanwhile, a few
women of color attended Radcliffe College, a separate and overwhelmingly white “women’s
annex” where racial minorities were denied campus housing and scholarships. (…) Women of
color at Radcliffe were taught by Harvard professors, but “women did not receive Harvard
degrees until 1963.” (…)

Today, benefactors with ties to slavery and white supremacy continue to be memorialized across
campus through “statues, buildings, professorships, student houses, and the like.” (…) Black
and Latino applicants account for only 20% of domestic applicants to Harvard each year. “Even
though those students of color who beat the odds and earn an offer of admission” continue to
experience isolation and alienation on campus. (…) For example, Harvard has reported that
“far too many Black students at Harvard experience feelings of isolation and marginalization,”

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(…) and that “student survey data showed that only half of Harvard undergraduates believe that
the housing system fosters exchanges between students of different backgrounds.” (…)

These may be uncomfortable truths to some, but they are truths nonetheless. “Institutions can
and do change,” however, as societal and legal changes force them “to live up to their highest
ideals.” (…) The majority’s true objection appears to be that a limited use of race in college
admission does, in fact, achieve what it is designed to achieve: It helps equalize opportunity and
advances respondents’ objective by increasing the number of underrepresented racial minorities
on college campuses, particularly Black and Latino students. This is unacceptable, the Court
says, because racial groups that are not underrepresented “would be admitted in greater
numbers” without these policies. (…) Reduced to its simplest terms, the Court’s conclusion is
that an increase in the representation of racial minorities at institutions of higher learning that
were historically reserved for white Americans is an unfair and repugnant outcome that offends
the Equal Protection Clause. It provides a license to discriminate against white Americans, the
Court says, which requires the courts and state actors to “pick the rights races to benefit.”
Nothing in the Fourteenth Amendment or its history supports the Court’s shocking proposition,
which echoes arguments made by opponents of Reconstruction era laws and this Court’s
decision in Brown. (…) In a society where opportunity is dispensed along racial lines, racial
equality cannot be achieved without making room for underrepresented groups that for far too
long were denied admission through the force of law, including at Harvard and UNC. (…) By
singling out race, the Court imposes a special burden on racial minorities for whom race is a
crucial component of their identity. Holistic admission requires “truly individualized
consideration” of the whole person. (…) Yet, “by foreclosing racial considerations,
colorblindness denies those who racially self-identify the full expression of their identity” and
treats “racial identity as inferior” among all “other forms of social identity.” (…) In a single
paragraph at the end of its lengthy opinion, the Court suggests that “nothing” in today’s opinion
prohibits universities from considering a student’s essay that explains “how race affected that
student’s life.” (…) This supposed recognition that universities can, in some situations, consider
race in application essays is nothing but an attempt to put lipstick on a pig. The Court’s opinion
circumscribes universities ability to consider race in any form by meticulously gutting
respondents’ asserted diversity interests. (…) Yet, because the Court cannot escape the
inevitable truth that race matters in students’ lives, it announces false promise to save face and
appear attuned to reality. No one is fooled. (…) In the end, the Court merely imposes its
preferred college application format on the Nation, not acting as a court of law applying
precedent but taking on the role of college administrators to decide what is better for society.
The Court’s course reflects its inability to recognize that racial identity informs students
viewpoints and experiences in unique ways. The Courts goes as far as to claim that Bakke’s
recognition that Black Americans can offer different perspectives than white people amounts to a
“stereotype.” (…) It is not a stereotype to acknowledge the basic truth that young people’s
experiences are shaded by a societal structure where race matters. Justice Sonya Sotomayor
Dissenting in the Matter of Students for Fair Admissions, Inc., v President and Fellows of
Harvard College and University of North
Carolina. https://www.supremecourt.gov/opinions/22pdf/20-1199_hgdj.pdf

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[iv] According to the January 30th 2018 report published by the National Council on Disability
(NCD), [1] “affirmative and effective consent” is being taught to college/university students of
the United States of America (U.S.A) during the course of their Freshmen Year; [2]
college/university students are informed about “healthy sexual relationships” during the course
of their 1st (first) year of post-secondary academic education; [3] 20% (twenty percent) of
women were sexually assaulted in a college/university setting by the time they reached their
Senior year in Calendar Year 2005; [4] 32% (thirty two) percent of women with a disability were
sexually assaulted during Calendar Years 2014 and 2015 in a college/university setting; [5]
sexual assault is a “public health and public safety concern with far reaching implications;” [6]
sexual assault is a “deeply personal violation,” which leaves “physical and emotional impacts
that change the lives of victims;” [7] sexual assault causes “long term physical, psychological,
and emotional effects, including depression, post-traumatic stress, thoughts of suicide,
flashbacks, and sleep disorders.” About “Affirmative and Effective Consent” on U.S College
Campuses. Michael A. Ayele (a.k.a) W. Association for the Advancement of Civil Liberties
(AACL).: https://michaelayeleaacl.wordpress.com/2022/11/02/affirmative-and-effective-
consent-in-healthy-sexual-relationships-on-college-campuses-index/

[v] Brock Turner wrote: “Before this happened, I never had any trouble with law enforcement
and I plan on maintaining that.” On November 15th 2014, three months before my assault,
Deputy Shaw spotted a few young men walking through Stanford campus with beer cans. When
apprehended, they ran. One guy was caught and detained, confessed the guy who escaped was
Brock Turner. He was summoned back. The police noted: He returned wearing a bright orange
tuxedo and Deputy Shaw smelled the odor of alcohol on him…He had a black backpack on with
Coors Lights beers inside, as well as a beer and knew he was not supposed to have it because he
was not 21 years old. He stated that when he saw Deputy Shaw approach, he made the decision
to run. While running, he heard the verbal commands to stop, but continued evading. He said it
was a split-second decision and he regretted making it. Deputy Shaw would be the one to
photography my body three after this incident.

Six months after my assault, two young women found Detective Kim and reported they’d
encountered Brock at the Kappa Alpha (KA) fraternity the weekend before I was assaulted. The
police report noted: He put his hat on her and she took it off. He then started to dance behind her
and tried to turn her around to face him. She felt uncomfortable and tried to turn her body away
so that he would not be directly “behind” her. He became really “touchy” and put his hands on
her waist and stomach. He even put his hands on her upper thighs. She felt more exceedingly
uncomfortable and got down off of the table. She said the Defendant “creeped” her out because
of his persistence. Chapter 10. Chanel Miller: Know My Name.

September 2014: Turner starts attending Stanford University on a swimming scholarship.

November 15th 2014: Turner and several teammates are chased by police after officers see the
group walking on campus drinking beer. The group had been on its way to a football game when
they scattered after an officer shouted for them to stop. Two officers chase the teens through
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campus, finally catching one. The detained swimmer calls Turner and told him to return and talk
with police. Turner, who was wearing an orange tuxedo, returns and apologizes for running
away. He receives and ticked for being a minor in possession of alcohol. (…)

January 10th 2015: Turner attends a party at Kappa Alpha fraternity house. A female Stanford
student who lived in Turner’s dorm building introduces a friend to him. The friend later tells
police Turner “creeped her out” and was “grabby” with her because he was placing his hands
on her waist, stomach and thigh while they were dance. The friend says she didn’t invite Turner
to dance with her nor did she seek his physical attention. She tells police she left the dance floor
to get away from Turner. Timeline of significant dates in the life of Brock Turner. Associated
Press.: https://apnews.com/general-news-962a8de554994637afce94a22afb78e9

[vi] I clicked back to the news of my homepage, saw Stanford athlete, saw raping, saw
unconscious woman. I clicked again, my screen filled with two blue eyes and a neat row of teeth,
freckles, red tie, black suit. I had never seen this man before. Brock Turner. I read he had been
charged with five felony counts: rape of an intoxicated person, rape of an unconscious person,
sexual penetration by a foreign object of an intoxicated woman, sexual penetration by a foreign
object of an unconscious woman, assault with intent to commit rape. Too many words, jumbled
together. Read it again, slower. I typed into Google, what is a foreign object. The panic was
quiet and slow. It was defined as an object that intrudes where it should not be, as into a living
body or machinery. Examples include: a speck of dust in the eye, splinter, wood chip, fishhook,
glass. What intruded into me. The article mentioned the victim had been digitally penetrated. My
mind went to digital cameras. I Googled that too. Digital, Latin root digitalis, from digitus
“finger, toe.” He must have fingered her, me. Google finally sat me down and broke the news.
(…)

The news linked to a police report, I clicked, scrolling, looking for victim, victim, victim. I found
the deputy’s carefully written notes. I found the female subject, later identified as VICTIM. I
found her on the ground behind the dumpster. I found her wearing a black, skin tight dress. I
found her dress had been pulled up to about her hips, and was gathered near her waist. Her
entire buttocks were uncovered, and she was not wearing any underwear. I found her lower
abdomen and pubic area was visible. I found her vagina and butt. I found her long hair was
disheveled, knotted and completely covered in pine needles all throughout. I found her lying in a
position with her feet and legs bent in a 45 – 90-degree angle (fetal position) and her arms were
in front of her chest with her hands on the ground near her face. I found her dress stretched
down over both shoulders, bra pulled out. I found it was only covering her right breast. I found
the necklace wrapped all the way around her neck so that the pendant portion was now centered
on her back. I found a pair of white with black polka-dot panties lying bunched up on the ground
about 6 inches in front of VICTIM’s stomach. I found her silver iPhone on the ground behind her
buttocks. There was a blue cell phone case that was approximately 4 inches away, separated
from the iPhone. I found she was wearing brown boots that were still laced, with the laces tied in
a bow. (…) So on that January morning in 2015, reading the story of the Stanford assault on the
news was like being read a letter. Sorry to inform you, impersonal and flat. (…) It was about a
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sad and strange rape on a local campus, a body found stripped and disheveled. This time, it was
my name. (…) Chapter 2. Chanel Miller: Know My Name.

[vii] Stanford swimmer denies alleged rape. I almost choked, felt I’d been slapped hard in the
chest. This article had a trigger warning, this version more graphic, I brushed it aside, clicked
the police report, eyes sliding back and forth. Throughout the night, Turner hooked up with a few
girls. In the report, all the people he’d kissed were named girls, but because he’d assaulted me, I
was never called girl, only victim. He stated that he kissed VICTIM while on the ground. He took
off the VICTIM’s underwear and fingered her vagina. He also touched the VICTIM’s breasts.
(…) Turner does not know the identity of VICTIM. He never got her name and was not able to
really describe her. He stated that he probably would not be able to recognize victim if he saw
her again. (…) He was having a good time with VICTIM and stated that she also seemed to enjoy
the activity. Enjoy. I stared at this word, a little thing I did not recognize. (…) I called my DA,
Hey! Did you see this? He said I liked it! How is that even possible? I can’t believe this; can you
believe this? What is this? I was half laughing, incredulous. But she did not match my tone. I
know, she said. I know. She sighed the way you do before you begin a sentence with
unfortunately or regrettably. She explained that pleading not guilty was a predicted formality.
This was to be expected. But I’m telling you now, I said, I didn’t enjoy it. I don’t know who he is.
He doesn’t even know what I look like. Chapter 2. Chanel Miller: Know My Name.

On Wednesday, a jury found former Stanford swimmer Brock Turner guilty of sexually
assaulting an unconscious and intoxicated young woman outside a fraternity house. 20-year-old
Turner was arrested Jan. 18, 2015, after two graduate students found him on top of an unmoving
woman outside Kappa Alpha fraternity at approximately 1 a.m. Turner subsequently withdrew
from Stanford and was charged with five felony counts, later reduced to three: assault with intent
to commit rape of an intoxicated or unconscious person, sexual penetration of an intoxicated
person and sexual penetration of an unconscious person. Turner has been convicted on all
counts. Brock Turner found guilty on three felony counts. The Stanford
Daily.: https://stanforddaily.com/2016/03/30/brock-turner-found-guilty-on-three-felony-counts/

A lawyer for Brock Turner, the former Stanford student convicted of sexually assaulting an
unconscious woman, argued in court during an appeal hearing that his client was seeking
“outercourse” with his victim. The attorney’s appeal of the high-profile case, which led to
international outrage after Turner received a lenient sentence in 2016, advanced in a California
court this week, with an unusual legal claim that experts said was shocking and hurtful to
survivors of sexual violence. Turner was originally convicted of assault with intent to commit
rape of an intoxicated woman and penetration of an unconscious person after passerby spotted
him thrusting on top of a motionless woman outside of a fraternity house in 2015. But his lawyer
Eric Multhaup argued in court Tuesday that his client was not attempting rape, but was seeking
“outercourse,” which he said was sexual contact while clothed and a “version of safe sex.” The
language and claims at the hearing, which came a month after voters recalled the judge who
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gave Turner six months in jail, stunned legal scholars and activists. (…) Numerous legal experts
said they had never before heard the term “outercourse” used by defense attorneys in sexual
assault cases, though some noted it was common for lawyers to argue that the accused had
different intentions than charges suggested. (…) Anne Coughlin, a University of Virginia law
professor (…) said that “outercourse,” as Multhaup appeared to be defining it, would still be a
criminal act, adding that it was an “ugly play on words” that “seems to be an effort to undercut
the terrible harm Turner caused to this woman.” Brock Turner sought ‘outercourse’ with victim,
says lawyer for ex-Stanford student. The Guardian.: https://www.theguardian.com/us-
news/2018/jul/25/brock-turner-stanford-swimmer-sexual-assault-outercourse

[viii] The People of the State of California, Plaintiff, versus Brock Allen Turner, Defendant,
Information No. B1577162. (…) We, the jury, find the defendant, Brock Allen Turner, guilty of a
felony, a violation of California Penal Code section 220 (a)(1), assault with intent to commit a
rape of an intoxicated or unconscious person. Dated March 30th 2016 by foreperson, Juror No.
5. (…) My DA requests that Brock be remanded. But the handcuffs never touch him, his attorney
arguing he should remain out on bail. Chapter 8. Chanel Miller: Know My Name.

[ix] You said, During the trial I didn’t want to victimize her at all. That was just my attorney
and his way of approaching the case.

Your attorney is not your scapegoat, he represents you. Did your attorney say some
incredulously infuriating, degrading things? Absolutely. He said you had an erection, because it
was cold. I have no words.

You said, you are in the process of establishing a program for high school and college
students in which you speak about your experience to “speak out against the college campus
drinking culture and the sexual promiscuity that goes along with that.”

Speak out against campus drinking culture. That’s what we’re speaking out against? (…) Not
awareness about campus sexual assault, or rape, or learning to recognize consent? (…)
Drinking culture and the sexual promiscuity that goes along with that. Goes along with that, like
a side effect, like fries on the side of your order. (…)

You should never have done this to me. Secondly, you should have never made me fight so long
to tell you, you should have never done this to me. But here we are. The damage is done, no one
can undo it. (…) When I read the probation officer’s report, I was in disbelief, consumed by
anger which eventually quieted down to profound sadness. My statements have been slimmed
down to distortion and taken out of context. I fought hard during this trial and will not have the
outcome minimized by a probation officer who attempted to evaluate my current state and my
wishes in a fifteen-minute conversation, the majority of which was spent answering questions I
had about the legal system. The context is also important. (…)

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I told the probation officer I do not want Brock to rot away in prison. I did not say he does not
deserve to be behind bars. The probation officer’s recommendation of a year or less in county
jail is a soft time-out, a mockery of the seriousness of his assaults, and of the consequence of the
pain I have been forced to endure. I also told the probation officer that what I truly wanted was
for Brock to get it, to understand and admit to his wrongdoing.

Unfortunately, after reading the defendant’s statement, I am severely disappointed and feel that
he has failed to exhibit sincere remorse or responsibility for his conduct. I fully respected his
right to a trial, but even after twelve jurors unanimously convicted him of three felonies, all he
has admitted to doing is ingesting alcohol. Someone who cannot take full accountability for his
actions does not deserve a mitigating sentence. It is deeply offensive that he would try and dilute
rape with a suggestion of promiscuity. By definition rape is the absence of promiscuity, rape is
the absence of consent, and it perturbs me deeply that he can’t even see that distinction.

The probation officer factored in that the defendant is youthful and has no prior convictions. In
my opinion, he is old enough to know what he did was wrong. (…) The seriousness of rape has to
be communicated clearly, we should not create a culture that suggests we learn that rape is
wrong through trial and error. The consequences of sexual assault need to be severe enough that
people feel enough fear to exercise good judgment even if they are drunk, severe enough to be
preventative. The fact that Brock Turner was a star athlete at a prestigious university should not
be seen as an entitlement to lenience, but as an opportunity to send a strong cultural message
that sexual assault is against the law regardless of social class.

The probation officer weighed the fact that he has surrendered a hard-earned swimming
scholarship. If I had been sexually assaulted by an un-athletic guy from a community college,
what would his sentence be? If a first-time offender from an underprivileged background was
accused of three felonies and displayed no accountability for his actions other than drinking,
what would his sentence be? How fast he swims does not lessen the impact of what happened to
me.

The probation officer has stated that this case, when compared to other crimes of similar nature,
may be considered less serious due to the defendant’s level of intoxication. It felt serious. That’s
all I’m going to say. He is a lifetime sex registrant. That doesn’t expire. Just like what he did to
me doesn’t expire, doesn’t just go away after a set number of years. It stays with me, it’s part of
my identity, it has forever changed the way I carry myself, the way I live the rest of my
life. Excerpt of Chanel Miller June 02nd 2016 Victim Impact Statement.

[x] They tell you that if you’re assaulted, there’s a kingdom, a courthouse, high up on a
mountain where justice can be found. Most victims are turned away at the base of the mountain,
told they don’t have enough evidence to make the journey. Some victims sacrifice everything to
make the climb, but are slain along the way, the burden of proof impossibly high. I set off,
accompanied by a strong team, who helped carry the weight, until I made it, the summit, the
place few victims reached, the promised land. We’d gotten an arrest, a guilty verdict, the small
15 | P a g e
percentage that gets the conviction. It was time to see what justice looked like. We threw open
the doors, and there was nothing. It took the breath out of me. Even worse was looking back
down to the bottom of the mountain, where I imagined expectant victims looking up, waving,
cheering, expectantly. What do you see? What does it feel like? What happens when you arrive?
What could I tell them? A system does not exist for you. The pain of this process couldn’t be
worth it. These crimes are not crimes but inconveniences. You can fight and fight for what?
When you are assaulted, run and never look back. This was not one bad sentence. This was the
best we could hope for.

At the very start of the sentencing, the judge said that the question he had to ask himself was, Is
incarceration in state prison the right answer for the poisoning of Chanel’s life? I thought it had
been strange the way he’d phrased it. To him, my lost job, my damaged hometown, my small
savings account, my stolen pleasures, had all amounted to ninety days in county jail.

I wondered if, in their eyes, the victim remained stagnant, living forever in that twenty-minute
time frame. She remained frozen, while Brock grew more and more multifaceted, his stories
unfolding, a spectrum of life and memories opening up around him. He got to be a person.
Where was her redemption story? Nobody talked about the things she might go on to do. I had
laid my suffering bare, but I lacked a key element. The judge had given Brock something that
would never be extended to me: empathy. My pain was never more valuable than his potential.

There would be no transformation. Behind bars or not, the judge had set him free, let him return
to the recesses of his mind where he could do no wrong. So what was the meaning of all this?
What’s the objective, the end game? Not once was he forced to imagine the life of the human on
the receiving end of his actions. If anything, the fight had cemented Brock inside his distortions,
fortified his need to hold his ground.

I wondered if I was waking up to a truth that I had been the last one to realize; you are worth
three months. A smarter part of me knew this was not right, but I could not pretend to know
better. At that moment there was nothing to do but give in. I accepted that this would be one of
the most painful nights of my life. (…)

I opened up by notebook. I stared at the empty page. Then I wrote, You are worth more than
three months. Again. You are worth more than three months. My face crumpled, twisted my hand
trying to outrun my mind. Listen to what your body is trying to tell you. You are worth more than
three months. What are you going to do? I will draw, I will speak. You are worth more than three
months. I am not a burden. I am not limited, I am ever expanding. Your suffering means
something. You are worth more than three months. They could never truly have rejected me since
they had never fully known me. You are worth more than three months. The assault was never all
of me. I could feel myself fighting, driving the pen into the page. You are worth more than three
months. My hand tensed, struggling, then softening. The light in my room was gray, I parted my
blinds to peek through, outlines of trees and cars emerging. I put down my pen. Sleep. Chapter 9.
Chanel Miller. Know My Name.

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[xi] Brock Turner three felonies added up to a maximum of fourteen years in prison. My DA
recommended six years. She asked me to write a victim impact statement, two to three pages
about how this experience affected me. If I wanted to read it aloud they’d buy me a ticket home.
If I didn’t want to read it, my advocate could read it for me. I had to submit it by the end of May
so the judge had ample time to look it over beforehand. (…)

Through all my years of writing classes, teachers told us that if a topic felt too raw you put it
aside for a later time. Create distance. But this deadline had been created for me. I had also
never encountered an assignment like this, to write up a list of emotional damages. The prompt
was depressing. Why should I document the ways I might be irreversibly ruined? I had a
“Making a Victim Impact Statement” brochure that suggested questions: How do you feel when
you wake up in the morning? How often do you cry? How much of each day do you feel sad?
Have you thought about suicide?

One afternoon, I received a call from an unknown number. I let it go to voice mail. In the
message, a woman identified herself as an officer from the Probation Department. I had learned
to be wary. I called my DA, asking if I was allowed to talk to this woman. My DA said the officer
wanted my input about the upcoming sentencing and I should call her and tell her I was writing
a statement I could share.

I was surprised the officer called me. I was used to being voiceless, my opinion rarely requested.
I assumed there were minimum sentences for each felony. I imagined this would be her nice way
of letting me contribute my two cents and I expected my words to literally be worth pennies,
wishful coins thrown into a fountain.

I told the probation officer I was writing a statement. But she began asking me questions. (…) I
told her I had survived a school shooting carried out by a man who never got the help he needed.
I didn’t want Brock Turner to slip off the rails and punish more women, needed to be sure he was
in therapy, taking classes in jail. So you want no more than a year, she said. I was confused. I
had never said that. She explained that I had said “jail” and county jail has a one-year
maximum. Prison has no maximum. Oh, I said. Well, do they offer classes in prison? I wondered
why no one had explained this to me.

Most importantly I wanted Brock to own up to what he had done. I asked if she had spoken to
him and she said no, but she would be meeting with him the following week. I said it was hard
for me to fully answer her without hearing what he had to say. You want him to get it, she said.
She said she understood. The conversation had been brief. I told her I was working on a
statement and I’d be more comfortable emailing it to her when I was done. But she said my oral
statement had been fine, she’d jotted down a few notes, and that wouldn’t be necessary. You did
great, she said. We both hung up.

I felt a lingering discomfort. I wished somebody else had been there for the conversation. I told
myself I was being paranoid, she would take care of things.
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Days later I received a call from my DA, her voice fraught. Can you tell me what you said to
her? (…) She explained the probation officer had offered a lenient sentence, had said I only
cared about treatment, not incarceration, suggesting Brock didn’t belong in prison. I wondered
how I had finally been given a voice, but it had not been the one I wanted. Laws exist, I thought.
How is it possible for me to blow it at this point?

I told her I’d call the probation officer back, but my DA said it was too late, the report had been
filed. She would send me the probation officer’s recommendation along with Brock’s statements
so I could respond to them in my own statement. Distraught, I opened the report.

The probation officer had given my input a single paragraph. She had taken my words but
constructed her own sentences, shaving all context away. I just want him to get better, it said.
She gave me a voice of forgiveness and submission, the agony neatly paved over. She’d reduced
my suffering to the line, I don’t experience joy from this. She’d drawn her own conclusions: He
doesn’t need to be behind bars. This woman, who had been absent for the entire battle, had
arrived to take the victory away. For months I had been climbing out of this hole, my hands
finally gripping the edge. Now I watched the dirt turn to mud beneath my fingers as I slipped
down again.

The officer noted she had been struck by the victim’s ability to objectively digest the gravity and
ramifications of the defendant’s behavior. That word, digest. She had mistaken my strength for
digestion. Perhaps she’d expected a hysterical victim, the weeping and scathing kind. She could
not hear how my muscles had tensed, did not know the way Lucas found me laying mute on the
couch after the call, exhausted from the resurgence of memories.

As a woman, I’d tried asserting my opinion without coming off as self-serving or overcontrolling.
So I repressed pissed-off victim. Now I wondered if I had handled it too gracefully, my
composure a signal that what he’d done was of little consequence. When I’d advocated for him
to take classes and be in therapy, she mistook it as a nurturing passivity, gentle absolution. What
I meant was take note of his mental health, because in my experience, when men were upset,
lonely, or neglected, women were killed.

A moderate county jail sentence, formal probation, and sexual offender treatment is respectfully
recommended. It sunk me. Moderate suggested his crime was of low quality, low intensity,
tolerable. It was diminishing: This case, when compared to other crimes of similar nature, may
be considered less serious due to the defendant’s level of intoxication.

She had interviewed Brock, reported, the defendant expressed sincere remorse and empathy for
the victim. I wondered if her suggestion had been light because Brock had finally taken
responsibility. I opened that PDF: “I swear I never would have done any of this if she wasn’t
willing… We were just in the heat of the moment. If at any time I thought she was not
responding, I would have stopped immediately…I never meant to treat her like anything else
than an exceptional person…During the trial I didn’t want to victimize her at all. That was just
my attorney and his way of approaching the case…I have to sacrifice everything…things can go
from fun to ruined in just one evening.” He explained he’d been working on a program where he
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speaks out against the college campus drinking culture and the sexual promiscuity that goes
along with that. (…)

There was another form filled out by the officer I had spoken to. Under victim’s race, she had
checked white. Never in my life have I checked only white. You cannot note my whiteness without
acknowledging I am equal parts Chinese. The single check mark was a testament to how little
time she’d taken to know me, making the assumption I was white over the phone without
bothering to ask. Chapter 9. Chanel Miller. Know My Name.

[xii] A 2001 Gallup poll that asked adults what they were afraid of reveals that more people –
51% -- fear snakes than any other suggested possibility, including speaking in front of an
audience (40%) and heights (36%). And while children are reputed to fear the dark, only 5% of
surveyed adults do. Just 11% of adults fear thunder and lightning. Snakes Top List of
American’s Fears. Gallup.: https://news.gallup.com/poll/1891/snakes-top-list-americans-
fears.aspx#:~:text=GALLUP%20NEWS%20SERVICE&text=A%20recent%20Gallup%20poll%
20that,%25)%20and%20heights%20(36%25).

[xiii] The rape and murder of Jeanne Ann Clery continues to leave several key questions about
Title IX of the Education Amendments Act of 1972 unaddressed. These questions include but are
not limited to the following. 1) What are/were colleges/universities in the U.S.A obligations
pursuant to Title IX of the Education Amendments Act of 1972? Were colleges/universities
throughout the U.S.A required by law to denounce violence committed against women
irrespective of their racial backgrounds, their sexual orientations, their religious affiliations,
their disability status and their national origins following the enactment of Title IX of the
Education Amendments Act of 1972? If yes, were colleges/universities required to inform their
students what constitute appropriate sexual boundaries pursuant to Title IX of the Education
Amendments Act of 1972? 2) Did colleges/universities throughout the U.S.A begin informing
their students what constitute “affirmative and effective consent” following the enactment of
Title IX of the Education Amendments Act of 1972? If not, when did colleges/universities begin
to inform their incoming freshmen/transfer students about the concepts of “affirmative and
effective consent?” Did colleges/universities throughout the U.S.A begin teaching the concepts
of “affirmative and effective consent” to their incoming freshmen/transfer students following the
rape and murder of Jeanne Ann Clery (dated April 05th 1986)? If yes, why have
colleges/universities throughout the U.S.A fixated on the rape and murder of this Caucasian
woman by a Black/African American man to inform their incoming freshmen/transfer students
about what constitutes “affirmative and effective consent?” 3) Are colleges/universities
discussions pertaining to what constitutes “affirmative and effective consent” consistent with
Title IX of the Education Amendments Act of 1972 if they are first informing their
incoming/freshmen students about the rape and murder of Jeanne Ann Clery? Are
colleges/universities discussions pertaining to what constitutes “affirmative and effective
consent” consistent with their academic integrity policy if they are first informing their incoming
19 | P a g e
freshmen/transfer students about the rape and murder of Jeanne Ann Clery? 4) Were there
forces out there in the 1970s and the 1980s looking for a case where a Black/African American
man rapes and murders a Caucasian woman for the purpose of enacting a law similar to the
Jeanne Clery Act? Was the enactment of the Jeanne Clery Act the result of racist and sexist
individuals coming together for the purpose of [a] preventing racial minorities from climbing the
social ladder through academic education; [b] cracking down on interracial relationships
particularly between a Caucasian woman and a Black/African American man; [c] not applying
the same standards in circumstances where a Caucasian man sexually assaults a woman from a
racial minority (as in the case of Brock Turner and Chanel Miller following her rape on January
18th 2015 at the campus of Stanford University)? Approximately 5 (Five) Months After the
April 05th 1986 Rape and Murder of Jeanne Ann Clery: August 29th 1986 at Westminster
College (Fulton, Missouri). Federal Bureau of Investigation (FBI) Actions on June 11th 1992 on
the Case of Jeanne Ann Clery. Michael A. Ayele (a.k.a) W. Association for the Advancement of
Civil Liberties (AACL).: https://michaelayeleaacl.wordpress.com/2021/12/10/jeanne-ann-clery-
case-updated-june-11th-1992-index/

[xiv] It is regrettable that the consequences for sexually assaulting a woman of color (Chanel
Miller) ended up equating for Brock Turner the maximum sentence he would have served in the
State of Maryland had he been arrested and charged for the petty offense of Trespass: 90
days. About Chanel Miller and the San Francisco Public Library (SFPL). Michael Ayele (a.k.a)
W May 20th 2016. Habeas Corpus.
Scribd.: https://www.scribd.com/document/534418446/About-Chanel-Miller-the-San-Francisco-
Public-Library-SFPL-Michael-Ayele-a-k-a-W-May-20th-2016-Habeas-Corpus#

[xv] On a Friday night in college, graduation a few weeks away, I was walking to a friend’s
house when two police cars tore past me. I thought nothing of it. It was common to hear sirens in
Isla Vista: it was a town on the ocean bluffs inhabited solely by eighteen to twenty-two-year-olds,
every street lined with shabby wooden houses, bikes abandoned on lawns, overcrowded
balconies, orchids growing out of recycled Franzia boxes. On sunny days you’d see beautiful
girls in swimsuits holding large rafts over their heads, like ants beneath a crumb, walking down
the street to the water. Guys biked with surfboards tucked under one arm, their wetsuits peeled
halfway off like a banana. Isla Vista was a network of couches to sleep on, a friend a block away
in any direction. A wild, sunny village we called home.

But by the time I reached her apartment, the sirens had stacked, blossomed, erupted. When I
walked in the door, all five of my friends were quiet, listening. We received an email from UCSB
Emergency:

Shots fired in IV 2 detained, investigation ongoing,

20 | P a g e
That was it. A single line that dropped off with a comma. Texts began circulating; maybe it was
gang related, a robbery, a drug deal gone wrong, a drive-by, no a shootout, a bomb,
firecrackers, drunk driver. He was Persian, no Asian? It was two guys, one guy, in a car, a black
one. Someone may have died, one person, possibly three, maybe none and this was all a sick
prank.

There was a video going around, someone said it was a guy, the guy, so we huddled around the
phone, and there he was, sitting in the driver’s seat, face saturated in orange from the setting
sun. Hi, Elliot Rodger here…I don’t know why you girls aren’t attracted to me but I will punish
you all for it. I’ll take to the streets of Isla Vista and slay every single person I see there… I will
take great pleasure in slaughtering all of you… Panic erupted, one of us screamed to turn it off,
one was convulsively crying on the floor, jerking as if her stomach were being yanked by a
string. He was still speaking, contaminating our air. I shook my head, refusing to hear it. He is
coming to Isla Vista to kill girls, we are girls in Isla Vista, but we can’t be who he is talking
about. You denied me a happy life and in turn I will deny all of you life, it’s only fair. I hate all of
you. We denied you a happy life? Hate ******* who? I was livid. I grabbed the phone, walked
out of the room, set it on the bathroom counter, and walked out, firmly closing the bathroom
door behind me. I felt I had trapped him in there, the video still playing, him speaking into the
darkness to no one.

The next email told us to remain indoors. We bolted the locks, closed the blinds, got away from
the window. Our phones kept chiming. Claire’s housemate had been shot. Nothing pieced
together.

At three in the morning, we stared at the news on TV, heard mass murder. The word seven was
displayed in tall, white letters at the bottom of the screen. It seemed wrong to group the dead. It
was not seven; it was one and one and one and one and one and one and one. Each an entire
life, each with a name.

The morning light never came, the air unmoving and still. On days like these, the fog slipped in
from the ocean, erasing the water, the shore, engulfing our little houses. We blinked, exhausted,
wondering if it was safe to leave. We kneeled on the couches and carefully parted the blinds. (…)
Rumors circulated there’d be copycat crimes, some men glorifying Elliot Rodger’s actions,
hailing him as their leader, the supreme gentleman. (…) When we finally stepped outside, it was
eerily quiet. On the street people traveled in tight groups, divided into herds and packs. The
atmosphere was hushed, no one strolling, longboarding, no thumping music leaking from houses.
The press conference was scheduled for 4:00 P.M. Before it began, we separated to privately
unravel in our showers, to put on clean clothes. We regrouped inside the apartment, our safe
house, refusing to be alone.

Elliot Rodger had lived in a brown apartment building, a block away from Sweet Alley, where
I’d frequently buy bags of sour watermelon candies for long nights at the library. On Friday
evening, he killed three people in the apartment, two Chinese roommates and their visiting
friend; 142 stab wounds in total, bloodstains in the hallway, bodies dragged and covered in
towels. He carried his knives and handguns into his black BMW, drove to the Alpha Phi sorority
21 | P a g e
house, knocking hard on the door. When no one answered, he shot three women outside, two
bled to death in the grass. He sped off, fired through the glass window of Isla Vista Deli, one
male slid to the floor dead inside. He crashed his car on Del Playa, the main street, the nose of
his car crunching in, before pressing his gun to his temple. Police found him with his head blown
out, blood painting the curb. The ambulances were backlogged, students kneeled beside bleeding
students. Bullet casings littered the street alongside sprinkled glass, large shards of window. The
police found 548 rounds of unspent ammunition inside his car that he never had time to use. Six
classmates had been stolen from us, Elliot Rodger the seventh. I do not include the victims’
names here, for names are sacred, and I do not want them identified solely by what he did to
them. (…)

I never forgot one of the opening lines of Elliot Rodger’s 137-page manifesto: This is a story of
how, I, Elliot Rodger, came to be…This tragedy did not have to happen… but humanity forced
my hand. His cruelty had a narrative arc. He spoke like he had never wanted to do what he did,
he was pushed to. And it was women who had made him suffer, who left him no choice but to
execute his Day of Retribution. In his video, he’d said, I’ve been forced to endure an existence of
loneliness, rejection and unfulfilled desires all because girls have never been attracted to me.
His hostility was born of entitlement, self-pity.

I will punish all females for the crime of depriving me of sex. In Elliot’s world, the unspoken law
was that women owed him sex, we existed only to receive him. Those were the rules, that was our
purpose. Sex was his right and our responsibility. The punishment in his world for breaking his
laws, for rejecting sex, was death. (…) College is the time when everyone experiences those
things such as sex and fun and pleasure, Elliot Rodger said. In those years I’ve had to rot in
loneliness, it’s not fair…You forced me to suffer all my life, now I will make you all
suffer. Chapter 4. Chanel Miller. Know My Name.

[xvi] Gov. Jerry Brown on Friday signed legislation that expands the legal definition of rape and
imposes new mandatory minimum sentences on sexual assault offenders – measures inspired
amid national outcry over the sexual assault case of former Stanford swimmer Brock Turner.

The decision comes as heated debate raged this year over the mishandling of sexual assault
investigations on U.S college campuses by police agencies and courts. But increasing
punishment for sex offenders posed a challenge for Brown, as the state has been undertaking a
broader effort to move away from a focus on prison sentences. (…)

Assembly Bill 2888, authored by Assemblyman Evan Low (D-Campbell) and Assemblyman Bill
Dodd (D-Napa), will prohibit judges from giving convicted offenders probation when they
sexually assault someone who is unconscious or intoxicated.

22 | P a g e
Assembly Bill 701 by Assemblywomen Cristina Garcia (D-Bell Gardens) and Susan Talamentes
Eggman (D-Stockton), will expand the legal definition of rape so it includes all forms of
nonconsensual sexual assault. (…)

Rape has previously been defined as “an act of sexual intercourse” under certain conditions of
force, duress or lack of consent. Other types of sexual assault, like penetration by a foreign
object, were categorized as separate offenses. California expands punishment for rape after
Brown signs bills inspired by Brock Turner case. Los Angeles
Times.: https://www.latimes.com/politics/essential/la-pol-sac-essential-politics-updates-
california-expands-punishment-for-rape-1475260488-htmlstory.html
Your FOIA request is approved. Kane County Finance Department has no documents pertinent to your request and is
considering this request closed.

Sincerely,

Amy Ramer Holmes


Assistant Director of Finance, FOIA Officer

23 | P a g e
EXHIBIT 3.
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

September 5, 2023

Dear Michael A. Ayele:

We write in response to your September 5, 2023 request for information pursuant to the Rhode
Island Access to Public Records Act (APRA). Your specific request is noted below along with our
corresponding response.

This is Michael A. Ayele sending this message though I now go by W. You may call me W. I am
writing this letter for the purpose of filing a request for records with your office.[i] The bases for
this records request are [1] the September 2016 rumored Brock Turner “college speaking tour”
on the subject of “alcohol and promiscuity” after he had spent 90 (ninety) days in county jail for
sexually assaulting Chanel Miller while she was unconscious;[ii] [2] the dissenting opinion issued
by Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson in the
Students for Fair Admissions v University of North Carolina as well as President and Fellows of
Harvard College case. [iii]

I) Records Requested

What I am requesting for prompt disclosure are records in your possession detailing your
discussions about [1] Brock Allen Turner as a Caucasian man, who (i) began attending Stanford
University as a Freshman student sometime in (or around) the month September 2014; (ii) was
more likely than not informed what constitutes “affirmative and effective consent” in healthy
sexual relationships when he was a Freshman undergraduate student of Stanford University;[iv]
(iii) was on (or around) January 10th 2015 accused of being sexually inappropriate with a female
student who was (also) attending Stanford University;[v] (iv) was on (or around) January 18th
2015 arrested for sexually assaulting Chanel Miller behind a dumpster (on the campus of
Stanford University) while she was unconscious;[vi] (v) was on (or around) March 30th 2016
found guilty of sexually assaulting and sexually penetrating Chanel Miller while she was
unconscious despite his claims that he had not done so;[vii] (vi) was not remanded to custody on
(or around) March 30th 2016 even though he had been found guilty of sexually assaulting
Chanel Miller while she was unconscious; [viii] (vii) was on June 02nd 2016 sentenced to 6 (six)
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

months of county jail for the sexual assault he perpetrated on Chanel Miller; (viii) has gone on to
be released from the Santa Clara county jail on (or around) September 02nd 2016 after serving
90 (ninety) days of the six months jail sentence; (ix) was in the month of September 2016
reported to have seriously considered going on a “college speaking tour” to warn young people
of the risks associated with “alcohol drinking and promiscuity;” [2] Chanel Miller as a woman of
Asian descent, who (i) was very much vexed by the 6 months jail sentence handed to Brock
Turner on June 02nd 2016;[ix] (ii) believes that her life is worth significantly more than the 90
day prison sentence Brock Turner ended up serving after he had sexually assaulted her;[x] (iii)
has had a very unpleasant phone call with a probation officer in Santa Clara, California
following the conviction of Brock Turner on March 30th 2016;[xi] [3] the decision of Supreme
Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson to note that “it is not a
stereotype to acknowledge the basic truth that young people’s experiences are shaded by a
societal structure where race matters;” [4] fear of public speaking (or glossophobia) ranking as
one of American’s greatest fears. [xii]

II) Request for a Fee Waiver and Expedited Processing

The requested records do/will demonstrate that [1] Michael A. Ayele (a.k.a) W is a Black man,
who has never denied (i) having come to the United States of America (U.S.A) on an F-1 Visa in
the month of December 2009 for the purpose of obtaining a Bachelor of Arts (B.A) Degree from
Westminster College (Fulton, Missouri); (ii) having been informed what constitutes “affirmative
and effective consent” in healthy sexual relationships during Calendar Year 2010 when he was
an undergraduate student of Westminster College (Fulton, Missouri); (iii) having been informed
about the April 05th 1986 rape and murder of Jeanne Ann Clery during Calendar Year 2010
when he was an undergraduate student of Westminster College (Fulton, Missouri); (iv) having
taken issue with manner in which he was informed about the rape and murder of Jeanne Ann
Clery as well as the way he was informed about “consent;” (v) having initiated contact with the
Department of Justice (DOJ) Federal Bureau of Investigation (FBI) as well as the Central
Intelligence Agency (CIA) about the April 05th 1986 rape and murder of Jeanne Ann Clery;[xiii]
(vi) having become a member of the San Francisco Public Library (SFPL) sometime in the months
of November/December 2014; (vii) having initiated contact with the SFPL about Chanel Miller’s
memoir entitled: “Know My Name;” [xiv] [2] Chanel Miller is a woman of Asian descent, who (i)
was on January 18th 2015 sexually assaulted (by Brock Turner) behind a dumpster on the
campus of Stanford University; (ii) is an alumna of the University of California, Santa Barbara
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

(UCSB); (iii) became an alumna of the UCSB after having been traumatized by the May 23rd
2014 horrific incident near that campus; (iv) recommended for Brock Turner to seek mental
health counseling because she was afraid that he might do something similar to what Elliot
Rodger did on May 23rd 2014;[xv] (v) who has never explicitly opposed the 6 (six) year prison
sentence recommended by Alaleh Kianerci after Brock Turner was found guilty of sexually
assaulting and sexually penetrating her; [3] Supreme Court Justices Sonia Sotomayor, Elena
Kagan and Ketanji-Brown Jackson are women, who have (during the month of July 2023) been
subjected to extensive media interest for writing (in part) that “it is not a stereotype to
acknowledge the basic truth that young people’s experiences are shaded by a societal structure
where race matters.”

In my judgment, the facts presented in my request for a fee waiver and expedited processing are
not the sort to bolster public confidence in the activities, the engagements and the priorities of
the U.S government (overall), but more particularly in those of the U.S judicial branch of
government. As a Black man with a U.S college degree, who was in January 2010 informed what
constitutes “affirmative and effective consent” in healthy sexual relations, I would like to take
this opportunity to [1] condemn violence committed against women irrespective of their racial
backgrounds, their sexual orientations, their national origins, their religious affiliations and/or
their disability status; [2] condemn the rape and murder Jeanne Ann Clery was victim of on April
05th 1986 when she was an undergraduate student of Lehigh University (located in the State of
Pennsylvania); [3] condemn the sexual assault Chanel Miller was victim of on January 18th 2015
on the campus of Stanford University (located in the State of California); [4] express in writing
the outrage I felt upon learning (sometime) in June 2016 that Brock Allen Turner was very likely
going to be spending 90 (ninety) days in county jail even though he was on March 30th 2016
found guilty of sexually assaulting and sexually penetrating Chanel Miller on the campus of
Stanford University; [5] condemn the discrimination, the racism, the sexism and the many
double standards I have had to (i) bear witness to and/or (ii) experience in person; [6] condemn
gun related violence committed in the United States of America (U.S.A) and/or elsewhere
around the globe; [7] condemn the horrific incident perpetrated on May 23rd 2014 near the
UCSB by the sexist involuntary celibate (incel) Elliot Rodger.

The core issues presented in this records request are as follows. 1) Have you ever had
conversations about Americans fear of public speaking? If yes, will you promptly disclose those
records? 2) Have you ever had conversations about the privilege and the entitlement a person is
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

born into if that person feels audacious enough to go on a “college speaking tour” for the
purpose lecturing young people on subjects such as “alcohol drinking and promiscuity” after
having registered as a sex-offender? If yes, will you will promptly disclose those records? 3) Have
you ever had conversations about the privilege and the entitlement a person is born into if that
person feels audacious enough to go on a “college speaking tour” for the purpose of lecturing
young people on subjects such as “alcohol drinking and promiscuity” after having been found
guilty of sexually assaulting a woman of color? If yes, will you promptly disclose those records?
4) Have you ever had conversations about the 90-day jail sentence Brock Allen Turner served
between June 02nd 2016 and September 02nd 2016 after he had been found guilty of sexually
assaulting Chanel Miller (while she was unconscious)? If yes, will you promptly disclose those
records? 5) Have you ever had conversations about the reasons why Brock Allen Turner spent 90
days in county jail after he was found guilty of sexually assaulting Chanel Miller (while she was
unconscious)? If yes, will you promptly disclose those records? 6) Have you ever had
conversations about the strong likelihood that Brock Allen Turner was informed what
constitutes “affirmative and effective consent” when he was an undergraduate student of
Stanford University during Calendar Years 2014 – 2015? If yes, will you promptly disclose those
records? 7) Have you ever had conversations about the reasons why female undergraduate
students continue to suffer sexual violence (at alarming rates) even though the men are
informed what constitutes “affirmative and effective consent” during the course of their First
(1st) year of post-secondary academic education/training (related to Title IX sessions)? If yes,
will you promptly disclose those records? 8) Have you ever had conversations about “consent”
being a politically contentious issue when it’s being addressed/dealt with by a Black man
similarly situated to Michael A. Ayele (a.k.a) W? If yes, will you promptly disclose those records?
9) Have you ever had conversations about the dissenting opinion issued by Supreme Court
Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson in the matter of Students for
Fair Petition v University of North Carolina as well as Presidents and Fellows of Harvard College?
If yes, will you promptly disclose those records? 10) Have you ever had conversations about the
decision of Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson to
note that “it is not a stereotype to acknowledge the basic truth that young people’s experiences
are shaded by a societal structure where race matters?” If yes, will you promptly disclose those
records? 11) Have you ever had conversations about the May 23rd 2014 shooting and stabbing
incident that was perpetrated by sexist incel Elliot Rodger near the UCSB? If yes, will you
promptly disclose those records? 12) Have you ever had conversations about the reasons why
Chanel Miller recommended for Brock Allen Turner to seek mental health therapy taking into
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

account that she’s an alumna of UCSB who was traumatized by the May 23rd 2014 incident
near that campus? If yes, will you promptly disclose those records? 13) Have you ever had
conversations about the reasons why the Santa Clara County Probation Department never asked
Chanel Miller (in their discussions with them) if she was objecting to the 6-year prison sentence
that had been recommended by District Attorney Alaleh Kianerci after Brock Turner was on
March 30th 2016 found guilty of sexually assaulting Chanel Miller? If yes, will you disclose those
records? 14) Have you ever had conversations about the decision of the State of California to (i)
expand the legal definition of rape and (ii) impose mandatory minimum sentences following the
90 days of county jail served by Brock Turner for the sexual assault of Chanel Miller? [xvi] If yes,
will you promptly disclose those records?

This records request should be expedited because it puts into question the government’s
integrity about the way that people are treated in the U.S.A on account of their gender, their
racial backgrounds, their national origins and their disability status. My request for a fee waiver
should be granted because [1] I have identified operations and activities of the federal
government in concert with U.S local/state government; [2] the issues presented are
meaningfully informative about government operations or activities in order to be ‘likely to
contribute’ to and increase public understanding of those operations or activities; [3] this
records request is being filed for non-commercial purposes and any records you disclose to me
could be made available to the general public at no financial expense to them. Under penalty of
perjury, I hereby declare all the statements I have made to be true and accurate. Be well. Take
care. Keep yourselves at arms distance.

There are no responsive documents.

If you contend you have been denied access to public records, pursuant to R.I. Gen. Laws § 38-
2-8, you may appeal this decision to the Chief Administrative Officer at the Office of the
General Treasurer (Gonzalo Cuervo, 82 Smith Street, Room 102, Providence, RI 02903), or to
the Department of the Attorney General (150 South Main Street, Providence, RI 02903), or to
the Rhode Island Superior Court through judicial action.

Thank you for your interest in keeping government open and accountable to the public.
State of Rhode Island
Office of the General Treasurer

James A. Diossa
General Treasurer

Public Records Officer - TK

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