BEFORE THE UNITED STATES HOUSE OF REPRESENTATIVES Investigation of Violations An the Matter of of Title VI of the Syracuse University Civil Rights Act of 1964 SUBMISSION ON BEHALF OF STUDENTS OF E UNIVERSITY1. TITLE VI PRomntts ANTISEMITIC DISCRIMINATION AT FEDERALLY FUNDED ‘Univensimes Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d ef seg., prohibits federally funded Universities from discriminating on the basis of race color, or national origin. Under Title VI, protection is afforded to all students enjoying federally funded programs or activities. Jewish students are a protected class under Title VI. Executive Order 13899 (Combating Anti-Semitism), 84 Fed. Reg. 68779 (Dec. 11, 2019); Dept of Educ. OCR Letters (May 25 and November 7, 2023); White House Statement (Sept. 28, 2023). Inalletter dated October 26, 2010 to federally funded schools, the Office of Civil Rights of the U.S. Department of Educations declared that antisemitic harassment under Title VI is a violation when it creates a hostile environment where “the conduct is sufficiently severe, pervasive or persistent so as to interfere with or limit a student’s ability to participate in or benefit from the services, activities, or opportunities offered by a school” or when the harassment is “encouraged, tolerated, not adequately addressed, or ignored by school employees.” When discriminatory harassment occurs ata federally funded school, schools must immediately investigate, and when such investigations expose discriminatory harassment, federally funded schools “must take prompt and effective steps reasonably calculated to end the harassment, eliminate any hostile environment and its effects, and prevent the harassment from recurring.” Following its historic hearings on December 6, 2023, the House Committee on. Workforce and Education announced that it was establishing a centralized reporting system for investigating antisemitism on college campuses in violation of Title VI of the Civil Rights Act of 1963. This fling on behalf of students of Syracuse University responds to that announcement‘Submission on Behalf of Students of Syracuse University with specific complaints of antisemitism, a hostile educational environment, and failure to take effective steps to combat antisemitic harassment at Syracuse University. TI, SYRACUSE FACULTY AND STUDENT Bopy HAVE ENGAGED IN PERSISTENT ACTS THAT THE UNIV} Has Faiuep To RECTIFY The facts enumerated below illustrate both persistent, ongoing incidents of antisemitism creating a hostile and discriminatory environment at Syracuse University (“Syracuse”), as well as Syracuse’s failure to address the occurrence of these incidents. A. TS 101 svc ny ee ke Five days after the Hamas October 7, 2023 massacre upon the State of Israel, ey qe eS incorporated an antisemitic opinion intof{i October 12, 2023 lecture in the SIR clas, refering to Israel as “Palestinian occupied land,” while issuing defamatory condemnation of Israel as an “oppressor.” Jewish students in the class felt very uncomfortable and attacked by (AIIM slander of the Jewish state. QIRGSIMMEBIB acknowledged the pain {caused in a follow up email sent on the same day as the aforementioned class (Exhibit 1), sharing that @¥j@\“feel[s] the pain that has not been adquately [sic] shared in class today.” Next, (IMENRISENM offered one lone resource for those “who wants [sic] to find out what we can do to stop the war in Gaza. QP referred QB students to the website of Jewish Voice for Peace. Despite its name, the Jewish Voice for Peace (“IVP”) is an antisemitic organization which self-describes as “Jewish” to disguise itself as aligned with the Jewish people. One of the oldest organizations fighting antisemitism, the Anti- Defamation League (“ADL”), states that “JVP uses its Jewish identity to shield the anti-Israel movement from allegations of antisemitism and to provide the movement with a veneer ofSubmission on Behalf of Students legitimacy. The group has also started to invoke its Jewish identity more frequently in an attempt to directly confront the American Jewish community about its positions on the Isracli-Palestinian conflict.” The icon attached to CERI 's email included a call to “Take Action. .. Tell Congress to stop fueling violence Tell the New York Times: The root of violence is oppression To Institutional holders of israel [sic] bonds: Divest now." (EMD cditorializing views about oppression and occupation, coupled with suggestions for aligning with Hamas and Palestinian interests and against Israel is hostile, antisemitic, and — especially in the time frame of being issued only five days after the outbreak of the most horrific war on Jews since the Holocaust — abusive of the teacher-student power dynamic by dismissing the Jewish-aligned view as illegitimate and disfavored and directing students only to resources antagonistic to Jewish supporters. a 2; rT) 's conduct was repoyled to Dean Gerald Greenberg by a parent of a student in class. Dean Greenberg responded (Exhibit 2) that the University has no prohibition on faculty expressing their personal views, and that the University administration has encouraged the faculty to be more mindful of students and what they are experiencing; no mention was made that the conduct violated any University policy or standards. Dean Greenberg did not distinguish between faculty enjoying free expression in their personal lives gs opposed, ta using the power and position of the classroom lecture to present factually oe and slanderous descriptions as objective information to be taught as part of academic mastery. B. THE WOMEN AND GENDER STUDIES DEPARTMENT STATEMENT 3. Onor about October 18, 2023, the Women’s and Gender Studies Department issued a “Statement of Solidarity” (hereinafter “the Statement”) (Exhibit 3). A relevant excerpt from the statement follows:Submission on Behalf of Students of Syracuse University. We are in solidarity with the Palestinian people in their struggle against Israeli settler colonialism and occupation and support Palestinians in Gaza who are being subjected to ongoing Isracli military violence through indiscriminate bombing, collective punishment of civilians, and the prohibition of life sustaining resources, such as water, food and electricity. ‘We .. . recommit our department to what the National Women's Studies Association has declared as an ongoing “pledge to continue to work as hard as we can to educate ‘ourselves and our communities about the historic injustice, suffering and resistance of Palestinians.” The Statement made no reference to the October 7, 2023 invasion and massacre of Israel. 4, The Chronicle of Higher Education reported on the distribution of the Statement from teachers to students as a declaration of the Syracuse Department of Women’s and Gender Studies. Standing in the shoes of the recipient students, the Chronicle posits: Tmagine being a student at Syracuse, returning to class after receiving that statement in your inbox. You've just been told the party line. Will you pose prodding questions? Will you try out counterarguments? Will you allow yourself to doubt? cS lucation, Nov. 16, 2023. er 5. Many parents and students contacted the University with great outrage over the antisemitic, targeted, hostile and frightening language of the Statement. In response to one communication from a parent! an unidentified Senior Vice President admitted to being deluged with complaints about the Statement such that “all he’s been dealing with is the statement made by the Women and Gender Studies Department” (Exhibit 4). As noted therein, the Senior Vice President recognized that the remarks in the Statement “violated the University policy when they posted their statement from a work-related platform” and that the remarks in the Statement were “so profoundly antisemitic and offensive.” + Owing to the public nature of ths filing, the names of parents and students have been redacted for privacy. Should the Committee wish to obtain identification of any redacted names, the submitter will cooperate to the fullest extent possible with any request to identify parents or students, 4‘Submission on Behalf of Students of Syracuse University 6. Notwithstanding the University’s expl recognition of the antisemitic nature of the Statement (Exhibit 4), the University issued a public statement on October 20, 2023 (Exhibit 5) which (1) downplayed the hostility, antisemitism and fearfulness of the Statement in an attempt to discount the significance of the Statement’s violative content; and (2) made no mention of the ‘Statement violating the use of University communication channels to convey personal opinions; 3) failed to declare that similar violative conduct conveying personal views through University channels would be disallowed in the future; and (4) neither made, nor demanded from the ‘Women’s and Gender Studies department, a retraction of the facially official and antisemitic University statement. 7. __ Inits October 20, 2023 communication, the University stated in pertinent part: We are also aware that some faculty and departments have issued statements of their own. about the conflict that some are experiencing as provocative and offensive. The foundational principles of free speech and academic freedom permit such statements of opinions on matters of importance. But we want to be clear—they do not speak for or on behalf of Syracuse University. Any statements made by individual faculty or departments should not be interpreted as the University’s position. We believe the free exchange of ideas and constructive public discourse can be valuable in increasing understanding, particularly in times like these. 8. The Women’s and Gender Studies department issued the Statement through University employees on University communication systems, in the official name of the University- controlled academic department where they are employed, directed at “you, our students” emphasizing the professor-student business relationship as the foundation of the communication. Basic principles of legal agency make it impossible for the University to disclaim responsibility, (as attempted in its October 20, 2023 communication) for its employees speaking in their official capacities, during business hours, and using University assets to communicate their message, ‘That the University failed to expressly pro it such use of University property and official 5‘Submission on Behalf of Students of Syracuse University. communication channels, while attempting to claim that these comments “do not speak for or on behalf of Syracuse University” is a failed attempt at disclaimer. The University allowed an official department to speak through its employees in order to represent an official position through official channels using University property. The University statement referenced no prohibition on the issuing employees continuing such conduct in the future. Tellingly, the Chronicle of Higher Education (see { 4, above), refers to the department-issued statement as “the party line.” The apparent authority of such official statements coupled with an absence of prohibition completely undercuts any suggestion that these writers do not speak for the University. This was a University statement by all outward appearances — and one which University personnel acknowledged was “profoundly antisemitic” (Exhibit 4). C. THe Ocroser 20™ Protest 9. Anunknown group planned a protest for October 20, 2023 titled “Protest to End the Gaza Occupation.” In a class titled (ae. [teats prominently displayed a poster for the protest at the front of the classroom (Exhibit 6). The RB «couraged students in the class to attend the protest urging a pro-Palestinian position. In view of the power dynamic between teacher and student, the encouragement during class session of students to pursue a political alignment of the teacher’s liking is an abuse of power and an unwarranted and hostile insistence on adherence to antisemitic views. , ESSER eae ST parr 10. Onorabout October 22, 2023 QATAR cd a class discussion as part of LS IS AT ELE TR eT) projected a list of points for class discussion on a screen at the front of the classroom (Exhibit 7). One student told (II that GJ was uncomfortable addressing these points 6Submission on Behalf of Students Syracuse University without also including the very relevant information that Hamas initiated the massacre and kidnapped hundreds of hostages, and raped, tortured and assaulted civilians in |sracl, ze RRB responded that the commentary offered by the student was “lies and propaganda.” Another student stated that she had family in Israel with first-hand information, and that the first student speaker's information was accurate. The first student speaker filed a bias claim following the incident and was contacted by a University Vice Provost. E. ANTISEMITIC VIEWS ABOUT TERRORISM AND VIOLATION OF UNIVERSITY POLICY DESIGNED TO PREVENT ANTISEMITISM. 11. Onor about October 27, 2023, a professor believed to be Renee de Nevers delivered a lecture, a portion of which she spent attempting to create justification for the actions of the October 7, 2023 Hamas massacre of Israel, claiming such actions do not meet the definition of “terrorist” and insisting as fact (not opinion) that “what is often called terrorism is people using whatever little power they actually have to try to fight back against a system that oppresses them daily.” The Professor can be seen lecturing in this video: Syracuse Video 1, Further, the professor described the Israeli military as “terrorists,” qualifying that judgment as a “fact.” To wit, she stated (again, labeling as fact, not opinion): “when we're talking about what is terrorism, we don’t talk about war as terrorism, but that’s dropping bombs on people — that is terrorism.” ‘The Israeli military, who are clearly the ones the professor is referring to “dropping bombs,” has never been designated by any government as terrorist; and the Hamas forces leading the October 7, 2023 massacre which the professor presented as factually nor meeting the description as “terrorists,” have been designated as a terrorist organization by the U.S. State Department for over 25 years.Submission on Behalf of Students of Syracuse University 12. In addition to her antisemitic (and incorrect) characterization of the Israeli army as terrorists, and her factually incorrect statement that Hamas forces are not terrorists, the professor believed to be Renee de Nevers also openly violated the University’s prohibition on distribution of the antisemitic Statement issued by the Women’s and Gender Studies department (Exhibit 3, see $3). The professor in the video expressly acknowledged to her class that the University had received bias complaints about the Statement and instructed faculty not to distribute the Statement, nor to make such statements or email students about such things. A student in the video states that she has not received the Statement, and the professor in the video states that “we are no longer allowed to send it to you, but maybe [inaudible name of alternate contact person] can send it to you.” The University having prohibited faculty from distributing the antisemitic Statement, it was an additional act of knowing antisemitism for the professor to undertake a workaround, instructing the student to obtain the forbidden statement from an alternate source, effectively engaging in the very distribution of the antisemitic Statement that the University had already prohibited. 13. Without fear of reprisal, the professor openly acknowledged she was distributing the antisemitic material that the University instructed her to refrain from distributing. The professor's unhalting readiness to redistribute the Statement suggests that the University put inadequate (or perhaps no) measures in place to truly discourage further dissemination and would tum a blind eye to these sorts of transgressions. The University’s inadequate response welcomed the continuation of a hostile, antisemitic environment. The University was made aware of this incident in the October 31, 2023 letter sent to the Chancellor (Exhibit 8), yet implemented no known further measures or prohibitions to prevent the continued open distribution of antisemitic content,Submission on Behalf of Students of Syracuse University. F, PROF. ABDULIADL AND THE OCTOBER 31 TEACH-IN FOR PALESTINE 14. The University scheduled a “Teach-In for Palestine” for October 31, 2023. The invited academic was Professor Rabab Abdulhadi. This event was calendared only 23 days after the massacre, rape, assault and murder of 1,200 people within Israel's borders. Professor Abdulhadi is identified in Wikipedia as a “controversial figure” and has a long history of antisemitic diatribe, and also has connections with designated-terrorist organization the Popular Front for the Liberation of Palestine (“PFLP”). In 2019, Professor Abdulhadi was hosting an online webinar lecture with Leila Khaled, a member of terrorist-designated PFLP. Zoom, Facebook and YouTube all cancelled livestreams of the webinar due to reasons related to policies against providing material support for terrorism in violation of the Antiterrorism Act of 1996, 18 U.S.C. § 2339B. Against this background a group of concerned Syracuse students and parents prepared a petition seeking cancellation of the Teach-In for Palestine event based upon its content and concern for the safety of Jewish students. (/ col) |) for Palestine Caneelation ot Scores if not hundreds of parents and students contacted Syracuse to cancel the Teach-In for Palestine (Exhibit 8). 15. As the date of the Teach-In for Palestine approached, the University was alerted to security concems and cancelled the event. In its cancellation notice, (Exhibit 9), the University based its cancellation on not being “able to confidently ensure the safety of the attendees” (emphasis supplied). The petitioning Jewish students expressing concern and fear clearly would not have been the attendees at the teach-in; the petitioning Jewish students further provided no reason for the university to suggest that they posed any risk to those who would attend the ‘Teach-In for Palestine. Thus, the University’s implication that the Jewish community was posing a safety risk to those interested in attending was unfounded, and the implication contributed to a 9Submission on Behalf of Students of Syracuse University false and dangerous impression that Jews were threatening the prospective attendees. It also left the Jewish students believing that their concerns were ignored, which left many feeling voiceless, These missteps elevated the safety risk to the Jewish community on campus. G. IGNORING Hamas’ TERRORIST DESIGN, 16. Inan incident of unknown date believed to be early November, a parent reported (Exhibit 10) hearing from their child that: A professor III nade every single Jewish kid feel unsafe. He stood there in front of the entire class, and blamed Israel for every single thing that happened and then refused to let anyone speak or take questions. One girl spoke up and said, would you please at least declare Hamas a terrorist organization. Another student stood up and said shut the f*ck up and the professor said nothing. There are a good amount in the class. because well it’s SU. The kids (all shaken and crying) are currently at Hillel and I hope meeting with higher ups. H. NOVEMBER 9 “SHUT IT DOWN FOR PALESTINE” PROTEST 17. A protest rally was scheduled for November 9, 2023 advertised as “Shut it Down for Palestine,” in a flyer distributed on campus (Exhibit 11). At the protest, a leader with a megaphone called out “From the River to the Sea, Palestine Will be Free,” provoking the condemnation of County Executive Ryan McMahon who stated “we all know what this chant means. It is clearly antisemitic and this ignorant rhetoric is not acceptable in Onondaga County.” McMahon Tweet. Congressional Representative Brandon Williams rebuked the rally's chants, declaring “[t]his type of incendiary, repulsive, and anti-Semitic language should NEVER be spoken, especially in CNY. These chants call for the annihilation of Israel and anyone who refuses to call them out for this behavior is complicit.” Williams Tweet, Just two days before this protest rally, the entire country was focused on the meaning of this phrase as Congressional Representative Rashida Tlaib was censured by this body for uttering it, The House voted overwhelmingly to pass H. Res. 845, making unmistakably clear that “the phrase ‘from the river 10‘Submission on Behalf of Students of Syracuse University to the sea’ .. . is widely recognized as a genocidal call to violence to destroy the state of Israel and its people.” The video of the students chanting throughout the campus without complaint, along with the County Executive’s condemnation, can be seen here: 18. After the marching portion of the protest, including the call and response chanting of “From the River to the Sea, Palestine Will be Free,” the students gathered for a stationary portion of the protest. During this second portion, the speaker called out student organizations by name, stating: “Zeta Beta Tau, Sigma Delta Tau, Alpha Epsilon Phi, Students Supporting Israel, Chabad SU, and CSN, you are complicit in genocide.” Each of the named groups is a social organization primarily, if not entirely, for Jewish students. The video footage of these statements can be seen here: © ¢ Video 2, 19. After the November 9, 2023 protest rally, Vice Chancellor Gretchen Ritter and Senior Vice President Allen Groves issued a joint statement (Exhibit 12) providing, in part: ‘We have learned that one of the speakers specifically called out a number of Jewish student organizations by name, accusing them of being “complicit” in genocide. Video of this conduct is already circulating and creating fear among members of our community. This kind of reprehensible behavior put a group of our students, based on their identity, at risk of harassment, retaliation and potential violence, although we are not aware of any current threats. We are investigating the statements and working to identify the speaker. 20. Upon inquiry, the University has stated that the investigation was inconclusive and the speaker could not be identified. The extraordinarily hostile and threatening content of the statements based on the students” identity as Jews called for a scorched-earth investigation. No advertisements of any sort were seen circulating through the university seeking information about the investigation; no tip lines were observed set up for the reporting of information relevant to the investigation. Hundreds of protestors were in attendance; video footage was widely published through multiple news sources; personal videos were available on the devices iSubmission on Behalf of Students of Syracuse University of the hundreds of attendees; and University-owned surveillance cameras were positioned throughout the location where the remarks were delivered, In light of the omnipresent camera coverage coupled with eye-witness observation by hundreds, it strains credulity that an investigation could not uncover the identity of a speaker who was not just a mere attendee, but was the leader of the protest delivering remarks over a megaphone in public before a crowd of hundreds. If the speaker could not be identified, it was because the University made no effort or did not want the speaker’s identity to become known. 21. _Inall of the widespread video coverage of the protest, the protest is shown to be led by a woman ina (aaa. : 2 QB who is holding 2 GEER. Photographs of the (Giie attached (Exhibit 13), and @ can clearly be seen on the video footage linked in { 17, above. The Q§BBEBPSo dressed is believed to be a RB RD coed GDS in tee EERE Program. The naming of the individual student organizations referenced in 18 above was made over a megaphone from a GMEBBP sounding voice. While it is unclear whether or not (AIIM was in fact the spokesperson at the moment the Jewish organizations were named, there is no doubt that jj was involved in the protest in a leadership capacity. {aii staan, leadership role as a speaker with a megaphone during the marching portion of the protest, and that (had o history of (SLi ERRe viewpoints. As such, @ is at the very least a person of interest in the investigation of the identity of the speaker who 12on on Behalf of $ e University delivered the remarks over a megaphone deseribed as “reprehensible behavior pufting] a group ‘of our students, based on their identity, at risk of harassment, retaliation, and potential violence” (Exhibit 12), placing student members of those organizations in fear and at risk when they were called out as complicit in genocide. 1. ScHOOL oF ARCHITECTURE PROMINENT POSTER 22. On November 14, 2023, a letter was prominently displayed at the School of Architecture, referencing the Middle East conflict with no mention of Hamas, no mention of the October 7, 2023 massacre, and no mention of significant other salient facts relating to the conflict in the Middle East. The lengthy statement condemned Israel's alleged genocide of Gaza, and described Israel as an apartheid regime and colonial settler. Further, the letter criticized the University’s denouncement of the antisemitic conduct atthe November 9, 2023 protest, where individyal student groups were singled at wy aeons of genocide. Tht full letter is attached (Exhibit 14), both as a reproduced letter and as a photograph of the letter posted on site. 23. Dean Michael Speaks responded to the November 14, 2023'letterthat had smeared Israel's self-defense against a historic massacre and lauded the reprehensible behavior of placing fellow students in fear by singling out of named student groups and holding them responsible for genocide. In his response, (Exhibit 15) Dean Speaks thanked the letter writers for a “thoughtful communication,” and assured the students that Syracuse “welcomes you and all students to express your views and discuss these and other issues.” Inasmuch as the letter writers were praising antisemitic communications acknowledged by the University to be “reprehensible” and placing students in fear based on their Jewish identity, (Exhibit 12,see also 18 above), Dean Speaks’ approval and encouragement of the letter is hostile, discriminatory and antisemitic. 13on Behalf of Students oF INKED TO DISRUPT wy CO! 24. On or about December 8, 2023 students began secing flyers containing QR codes on cafeteria tables in Slocum Hall. Examples of the flyers are attached (Exhibit 16). The flyers referenced happenings relating to the Middle East, such as “cease fire” and refences to Palestinian injury and death tolls. The QR codes lead to websites of materials distributed by US Campaign for Palestinian Rights and Shut It Down For ' alestine. Neither of these groups is a recognized student organization at Syracuse. The online materials provide instructions relating to pro-Palestine protest toolkits, along with instructions for disrupting transportation systems and jamming up telephone networks. As these were not approved student organizations subject to University compliance and oversight, and they express hostility toward Jewish interests coupled with disabling the ability to communicate and travel, the appearance of these flyers reasonably made Jewish students feel unsafe. K. CLASS CANCELLATION TO ATTEND PRO-PALESTINIAN LABOR STRIK! 25. OnDecenber 11,223, Se referenced in one of the letters sent from concemed students and parents to the school’s issued the communication administration (Exhi it 8). BAB stated that class was cancelled as “part of a global labor strike to protest the increasingly genocidal conditions in Gaza.” (Exhibit 17) EMD referred students to a variety of resources to gain perspectives on Gaza, including the openly antisemitic Jewish Voice for Peace referenced in { 1, above. All of the resources listed in R's ‘communiqué aligned with Palestinian viewpoints and none aligned with Jewish viewpoints, reinforcing these antisemitic positions to her students, 14sity, 26. Throughout the month of December, the main student center of the University, the Schine Center, was populated with certain users that communicated messages concerning the conflict in the Middle East. The users adomed Palestinian flags, waved signs with messages of support for Palestinians, chanted in loud voices, and many wore face coverings and head coverings sufficient to obscure their identities. The loud chanting in unison by masked protestors, coupled with the shoulder-to-shoulder human chain formations made access to and use of the Schine Center difficult, uncomfortable and frightening for Jewish students. Among the slogans chanted were: “IDF, what do you say? How many kids did you kill today?” Photos of the gatherings in the Schine Center are attached (Exhibit 18). Students are seen wearing attire stating “Intifada,” (calling for a violent revolution against Jews) and “you cannot take a neutral stance on genocide.” A video of a representative demonstration is attached here: Syracuse Video 3. M. _ FAILURE TO Resronp To INQUIRIES ABOUT JEWISH CONCERNS 27. Throughout the fall and winter of 2023, a community of concemed parents and alumni actively participated in a WhatsApp chat group and learned from one another that many complaints to the University concerning antisemitism were going unanswered. The group collectively wrote a January 2, 2024 letter cataloguing many complaints. The parents worked in ‘concert with a Jewish civil rights group named EndJewHatred, and the letter concluded by asking the University administrators to contact counsel for EndJewHatred, Mr. Gerard Filitt Over 2,000 individuals emailed this letter were emailed to the University. Mr. Filitti has never received a response to these letters. The letter specifies in detail a collection of underlying facts summarized in {ff 28-30, below (Exhibit 19): 15Submission on Behalf of Students. S Universit 28. The letter raised concems about Professor Amy Kallendar's new course, “Israel and Palestine: Historical Approaches.” Professor Kallendar is rated on the AMCHA List of Anti- Israel Professors, which raised concem about the balance of a course she would teach on Israel and Palestine. The group voiced their concerns in the letter: The framing of Professor Kallander’s new course within a colonialist perspective, under the guidance of a professor who supports the Boycott Divestment Sanctions (“BDS”) boycott movement against Israel, raises serious questions about its unbalanced and biased coverage of the course content, coupled with a likelihood to single out Pro Israel and Jewish students. A comprehensive curriculum should address the full spectrum of historical and contemporary realities on both sides of a conflict. This would require Professor Kallander’s course to include at least some of the terrorism that has shaped Israeli policies and society, such as specific bombings, the 1972 murder by Palestinian militants of 11 Israeli athletes at the Munich Olympic Massacre, the 1976 kidnapping of 106 Jewish and Israeli hostages from a flight hijacked by Palestinians, the 2nd intifada uprising led by Palestinians in the early 2000's where innocent people were blown up in busses and clubs throughout Israel by suicide bombers, and of course now, the Hamas-led massacre of October 7, 2023. 29. — Concurrently with the offering of a new course taught by a ranking anti-Israel Professor, the University announced that within 24 hours of Israel’s capture of Gazan poet Mosab Abu Toha (whose published writings are hostile to Israel), Syracuse extended the poet an offer of employment. Curious about the record timing of the poet’s employment offer, coupled with the seemingly growing collection of Palestinian-viewpoint faculty, parents and alumni became concerned about the dearth of viewpoint diversity issues and other issues this new hire presented. 30. Members of the WhatsApp community chat had also been conversing for months about the incendiary WGS Statement (Exhibit 3) issued in mid-October. The statement, having been issued by the Women’s and Gender Studies department, was developed under the leadership of department chair, Himika Battacharya. Parents and alumni had lodged multiple complaints with the administration as to how a department chair could faithfully lead a department without recognition that the department statement was “profoundly antisemitic and offensive” 16Submission on Behalf of Students of Syracuse University (Evhibit 4). A petition seeking Professor Battacharya’s termination circulated and secured over 7.700 signatures. The parent and alumni letter questioned not only the quality of Professor Battacharya’s leadership, but also questioned why the administration would not acknowledge or respond to the petitioner, who had urged the administration for a response to her child’s complaint that the “profoundly antisemitic and offensive” WGS Statement unfairly discriminated against her as a Jew, and created a hostile educational environment. The January 2, 2024 letter (Exhibit 19) mentioned that Senior Vice President Steven Bennett stated on a Zoom session hosted by the Hillel organization with nearly a thousand parent participants that he would not respond to or even acknowledge a complaint that came in the form of a petition. 31. Additional communications of parents and students addressing issues particular to Jewish students consistently go unanswered by the Syracuse administration. ‘The submitters of this filing lack access to a comprehensive database of complaints, but several representative communications attached as exhibits are illustrative of the repeating pattern that efforts to promote rectifying or preventing hostilities toward Jewish students are routinely ignored. One ‘communication concerned an opportunity for senior administrators at Syracuse to join their peers at universities nationwide to screen unreleased raw footage of the events of October 7. These efforts aim to address antisemitism by combatting denial and minimization of the antisemitic atrocities committed in the massacre. Many universities began participating in such screenings in November, and Syracuse was invited by a November 20, 2023 email from a parent to senior administrators asking Syracuse to join its peer universities in these efforts (Exhibit 20); Syracuse failed to respond in any fashion to the opportunity. 32. Another communication concemed an invitation from a parent group to host a group of nine Syracuse administrators, all-expenses-paid, for a visit to Israel with dedicated security detail 17ean Submission on Behalf of Students of Syracuse University to-explore the region in the aftermath of the October 7 massacre, meet with local officials and learn firsthand not only about the atrocities but also about the history of Israel to enhance faculty understanding of a crisis that grips both the greater world and the immediate campus. (Exhibit 21). Again, Syracuse failed to respond in any fashion and did not even explore the possibility of using this tool to address its antisemitism problem. 33. Yet another communication is an email from a concerned parent seeking to address the hostile and discriminatory setting presented by the Professor who twisted and tortured the definition of terrorism to suit her personal narrative, as described in 4 11-12, above (Exhibit 22). The sender was told that her email would be referred to an appropriate department. No response was given. 34. The three representative communications above, along with countless others on the subject of violative Jewish discrimination, did not receive any reply from any Syracuse official, stymying the ability of students and parents to even bring antisemitism to the attention of the administration and collaborate to fix the persistent problem. 35. Along with the rest of the country, Syracuse is facing a historic rise in antisemitism as recognized by Vice Chancellor, Provost and Chief Academic Officer Gretchen Ritter and Senior Vice President and Chief Student Experience Officer Allen Groves in their November 9, 2023 email (Exhibit 12). They described “reprehensible behavior” which put Jewish students at risk; a Senior Vice President expressly acknowledged in writing that the WGS Statement (Exhibit 1) was “profoundly antisemitic” (see 4 4). Against this background, for Syracuse to decline any response and not even explore the possibility of using the offered tools to address its antisemitism problem exposes perhaps a lack of desire to address the problem and a violative failure to “take prompt and effective steps reasonably calculated to end the harassment, 18Submission on Behalf of Students of Syracuse University any hostile environment and its effects, and prevent the harassment from recurring,” as required under Title VI. Dept of Educ, OCR Letter, (October 26, 2010). TIL. Covcuusion 36. The foregoing incidents, actions, and failures to act, constitute an ongoing repetition of hostile, antisemitic harassment that interferes with Jewish students’ ability to fairly access their education in violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq. This document is part of a larger filing involving 20 universities and colleges. Inquires may be directed to counsel for the 20-college consortium, Mr. Gerard Fi gerard@thelawfareproject.com. 19