John Doe V Williams College Statement of Facts Exhibit 6

Case 3:16-cv-30184-MGM Document 124-6 Filed 09/30/18 Page 1 of 98
UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS
WESTERN SECTION
Docket No.
16-CV-30184
JOHN DOE,
Plaintiff
vs.
WILLIAMS COLLEGE,
Defendant
CONTINUED DEPOSITION OF: MEAGAN BOSSONG,

taken before Kathleen M. Houghton, Notary
Public Stenographer, pursuant to the Federal
Rules of Civil Procedure, at Williams College,
Hopkins Hall, Room 203, 880 Main Street,
Williamstown, Massachusetts on May 15, 2018,
commencing at 1:00 p.m.
APPEARANCES:
(Please see Page 2.)
Kathleen M. Houghton
Court Reporter
APPEARANCES:
ROSSI LAW FIRM

P.O. Box 442
Hoosick Falls, New York 12090,
representing the Plaintiff.
BY: STACEY ELIN ROSSI, ESQUIRE
(413) 248-7622
berkshirelegal@gmail.com
LOCKE LORD LLP

111 Huntington Avenue
Boston, Massachusetts 02199,
representing the Defendant Williams
College.
BY: DARYL J. LAPP, ESQUIRE
(617) 239-0174
daryl.lapp@lockelord.com
1 I N D E X
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2 WITNESS DIRECT CROSS REDIRECT RECROSS
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3 MEAGAN BOSSONG 5
5
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6 EXHIBIT DESCRIPTION PAGE
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7 147 email, WMS 11963 8
8 148 Draft document, WMS 12081, 12083 20
9 149 email, WMS 11868, 11870, 11871, 11872 22
10 150 Diversity & Community document 23
11 151 emails, WMS 11983, 11204 24
12 152 email, WMS 12025, 12042 27
13 153 email, WMS 12048, 12051 31
14 154 email, WMS 11843, 11844 33
15 155 email, WMS 11852 - 11855 37
16 156 WMS 12073, 12074, 10076 41
17
164 An all-student email, 10/9/15 43
18
165 email, WMS 11845 - 11849 45
19
166 email, WMS 11130 - 11132 79
20
167 email, training materials, 2/20/18 83
21
22 *****
23
1 S T I P U L A T I O N S
3 It is agreed by and between the parties
4 that all objections, except objections as to
5 the form of the question, are reserved, to be
6 raised at the time of trial for the first
7 time.
9 It is further agreed by and between the
10 parties that all motions to strike
11 unresponsive answers are also reserved, to be
12 raised at the time of trial for the first
13 time.
14
15 It is also agreed that the deponent will
16 read and sign the deposition transcript.
17
18 It is further agreed by and between the
19 parties that notification to all parties of
20 the receipt of the original deposition
21 transcript is also hereby waived.
22
23 *****
1 MEAGAN BOSSONG, Deponent, having
2 been satisfactorily identified by the
3 production of a driver's license, was duly
4 sworn in and questioned and testified as
5 follows:
6 DIRECT EXAMINATION BY MS. ROSSI
7 Q. Good afternoon, Ms. Bossong. My name
8 is Stacey Elin Rossi. Can you please state
9 and spell your name for the record?
10 A. Meagan, M-E-A-G-A-N, Bossong,
11 B-O-S-S-O-N-G.
12 Q. And do you recall the parameters that
13 I provided the last time we met?
14 A. I do.
15 Q. Okay. So I won't repeat them.
16 So you're here for a 30(b)(6)
17 deposition, so do you understand that you're
18 providing answers on behalf of the College?
19 A. I do.
20 Q. Okay. And what did you do to prepare
21 for this deposition?
22 A. I scheduled it and sent whatever
23 documents I had in regard to elements that you

1 were interested in.
2 Q. Okay. Is it correct that there's a
3 hard copy of a student handbook for the
4 academic year 2013 to 2014 in the Dean's
5 Office?
6 A. I -- that was the last year that
7 there was a hard copy of the handbook
8 published. I imagine that there is.
9 Q. Was the Code of Conduct relative to
10 sexual misconduct in that handbook unchanged
11 from the previous academic year?
12 A. That I do not recall without looking
13 at the documents in front of me.
14 Q. I'm going to ask you about various
15 acronyms that are mentioned in the documents
16 that you've provided. What is RASAN,
17 R-A-S-A-N?
18 A. RASAN is the Rape and Sexual Assault
19 Network, a student peer support network on
20 campus there.
21 Q. Okay. And S-A-S-S?
22 A. SASS is Sexual Assault Survivor
23 Services, which is the 24/7 confidential line

1 that people can call for support.
2 Q. And SAPA?
3 A. SAPA is the Sexual Assault Prevention
4 and Awareness working group.
5 Q. And SAFER?
6 A. SAFER is a national organization,
7 Students Active For Ending Rape.
8 Q. What is ASR?
9 A. ASR refers to the Annual Security
10 Reports that colleges are required to publish
11 by the Jeanne Clery Campus Safety Act.
12 Q. What is the Feminist Collective?
13 A. The Feminist Collective is a student
14 group at Williams.
15 Q. And what is the Title IX Committee
16 For Student Concerns?
17 A. The Title IX Committee For Student
18 Concerns is a group of staff who meet to
19 review issues related to Title IX and student
20 concerns whether that is, for example, student
21 requests to have something remain confidential
22 even if it was reported to a responsible
23 employee or if there are questions about how

1 to best meet accommodations needs related to
2 Title IX.
3 Q. I want to show you WMS 11963 and
4 we'll mark this as Exhibit 147.
5 (Exhibit No. 147, marked.)
6 Q. (By Ms. Rossi) Can you describe this
7 email conversation for us?
8 A. This is an email conversation between
9 myself and Sarah Bolton from June of 2014
10 detailing -- I had requested a model policy
11 from the University of Rochester to pass
12 along. At that time the campus was trying to
13 come into compliance with the Violence Against
14 Woman Act, VAWA, amendments to the Clery Act,
15 and there was policy revision going on.
16 Q. Okay. And was this the first time
17 that you communicated about policy revision?
18 A. With whom?
19 Q. With anyone?
20 A. No.
21 Q. So there's other communications
22 regarding policy communications prior to this
23 date that haven't been produced?

1 A. Well, I had been working at Williams
2 for two months prior to that so I had meetings
3 with people but this is the first email that I
4 exchanged regarding.
5 Q. Okay. Thank you for the
6 clarification.
7 So in this email Dean Bolton
8 indicates that you and she had previously
9 discussed integrated sexual misconduct
10 policies; is that correct?
11 A. I don't see that from this email
12 chain.
13 Q. Right up here?
14 A. That's my email to Sarah Bolton.
15 Q. Right.
16 A. So I am saying University of
17 Rochester has an integrated policy such as we
18 have discussed.
19 Q. So is it correct that you discussed
20 with Dean Bolton integrated sexual misconduct
21 policies?
22 A. So in this context what an integrated
23 policy meant is a policy that included sexual

10
1 misconduct, dating and domestic violence,
2 stalking, retaliation, so they had already
3 come into compliance with the VAWA Amendments
4 to Clery.
5 Q. Okay. So had you and Ms. Bolton
6 discussed integrating -- having Williams
7 College's policies be similar to these
8 policies that are integrated?
9 A. Prior to 2014 Williams did not have
10 an articulated domestic and dating violence
11 policy and so we needed to add policy language
12 around domestic and dating violence to come
13 into compliance with the VAWA Amendments to
14 Clery so that we were discussing doing that
15 because at that time our policy language was
16 not in compliance.
17 Q. Okay. So is it correct that you and
18 Dean Bolton would be drafting the new policies
19 that you are discussing?
20 A. We were among a larger group of
21 people who were involved in drafting policies
22 but the two of us were involved, yes.
23 Q. Okay. Who else was involved at this

11
1 time?
2 A. At that time Justin Adkins, who was
3 assistant director of the Davis Center, in
4 consultation with Donna Denelli Hess, who is a
5 health educator at the Health Center; Jeff
6 periodically, Jeff Jones, our then general
7 counsel; Darryl Lapp; and Matt Sheehy, the --
8 I can't -- I don't know his exact title
9 without looking at it but he's in the Office
10 of the Vice President of Finance and
11 Administration.
12 Q. And were you discussing at this time
13 creating the sexual -- I'm sorry -- the
14 statement on sexual assault and other
15 misconduct?
16 A. We were looking at our sexual
17 misconduct and gender-based violence policies
18 in their entirety to make sure that they were
19 fully in compliance with the 2011 Dear
20 Colleague letter, the 2014 FAQ guidance
21 document, and the VAWA Amendments to Clery, so
22 we were looking at the policy in its entirety.
23 Q. So in this email I believe you refer

12
1 to -- you refer this particular list -- and
2 I'm not seeing it right now.
3 In any case, what other policies or
4 colleges did you look at in addition to
5 University of Rochester at the time?
6 A. My recollection is that Matt Sheehy
7 had sent along a model policy from the State
8 University of New York System. And later in
9 2014-2015 the SAPA, S-A-P-A, Sexual Assault
10 Prevention and Awareness, working group was
11 looking at the policy and I suggested to them
12 that they look at policies at other schools
13 and bring those to the table to discuss if
14 there were elements that they felt were
15 encompassed in other schools policies that
16 should be a part of the Williams policy or if
17 there were pieces that they were seeing in
18 other policies that they didn't understand
19 that we should talk through.
20 Q. Was there any particular school in
21 which you modeled the Statement on Sexual
22 Assault and Other Sexual Misconduct?
23 A. No, there were no particular schools

13
1 on which they were modeled. It was because of
2 the compliance language around the VAWA
3 Amendments to Clery, there's fairly specific
4 language that is required to be included in
5 the Annual Security Report, and so most
6 schools policy and language was coalescing
7 around similar language to those compliance
8 requirements.
9 Q. Okay. I will take this back and I am
10 going to show you WMS 12081 and 12083. Can
11 you describe these pages for us, please?
12 A. This is draft statements on sexual
13 assault and other sexual misconduct. I cannot
14 without looking tell you when this dates from
15 but the formatting would be around the time
16 that we were engaging in these conversations.
17 Q. Okay. Do you know who wrote this
18 draft?
19 A. I believe that it was -- I don't know
20 for sure. I'm sorry.
21 Q. Okay. Do you know who made the edits
22 and the markups?
23 A. The edits and the markups would have

14
1 been jointly made by Sarah Bolton, myself,
2 Jeff Jones, and then also Denise Buell and
3 Martha Tetrault, who at the time were then the
4 Title IX coordinators.
5 Q. Okay. And is it correct that
6 underlined text is text that is added into the
7 document?
8 A. No. Underlined text -- it depends on
9 what the underlining form looked like. For
10 example, if you're adding a comment to a
11 particular piece of text, it will underline to
12 highlight where it is, so that's what the
13 dotted underline -- there are both dotted and
14 solid underlines. So the dotted underline
15 would draw your attention to a particular
16 piece of text.
17 Q. So in Section 3 where the word
18 "affirmative" is underlined, was that added to
19 the document?
20 A. It appears that it was, yes.
21 Q. Okay. Do you know whose decision it
22 was to add that?
23 A. I can't recall.
15
1 Q. And why was it added?
2 A. It was added because there was a need
3 for clarification: That we had an affirmative
4 consent policy and the national conversation
5 at that time was around affirmative consent
6 policies, and so what we wanted was to provide
7 clarification and certainty to the Williams
8 community that we had an affirmative consent
9 policy.
10 Q. Okay. And in the third sentence was
11 "clearly" added?
12 A. It appears so, yes.
13 Q. Okay. And I believe it's on the back
14 of that page: In the absence of affirmatively
15 expressed consent sexual activity is a
16 violation of the Code of Conduct; was that
17 added?
18 A. Yes.
19 Q. What is affirmative consent?
20 A. Affirmative consent is a -- the pithy
21 way of describing it would be a yes means yes
22 policy; that consent is only present in the
23 presence of affirmatively or positively stated

16
1 yes.
2 Q. Okay. So is this policy, the
3 statement that we're looking at, a yes means
4 yes policy?
5 A. Yes.
6 Q. Okay.
7 A. It's an affirmative consent policy.
8 Q. And, in other words, an absence of a
9 yes means no; is that correct?
10 MR. LAPP: Objection.
11 THE WITNESS: An absence of
12 clearly communicated words or conduct
13 indicating affirmative consent would mean that
14 consent is not present.
15 Q. (By Ms. Rossi) Okay. What was the
16 purpose of adding this language to the policy?
17 MR. LAPP: Objection. Asked
18 and answered.
19 MS. ROSSI: That's okay.
20 I'll move on.
21 Q. (By Ms. Rossi) Is it correct that
22 this policy differs from the previous policy?

17
1 THE WITNESS: I -- because
2 this is undated, I can't affirmatively answer
3 that question because I don't know exactly
4 what this dates from and so without looking at
5 it with regards to the prior policy, I can't
6 -- I can't just tell you that without a firm
7 memory.
8 Q. (By Ms. Rossi) We're going to look
9 at Exhibit 50 from Ninah Pretto's deposition,
10 and if you could just take a look at -- from
11 page four, Section A? Could you read that,
12 please?
13 A. The 2013-2014 Student Code of
14 Conduct. The College's 2013-2014 Student Code
15 of Conduct applies to the allegations that
16 precede the College's adoption and the
17 Statement of Sexual Assault and Other Sexual
18 Misconduct, which went into effect in October
19 2014.
20 Q. Okay. So is it correct that this
21 document here that we're looking at, the
22 Statement on Sexual Assault and Other Sexual
23 Misconduct, went into effect October of 2014?

18
1 A. Well, this is a draft statement and
2 so I -- I don't know by just looking at what
3 this is where in the drafting process --
4 Q. Right.
5 A. -- this came from.
6 Q. Okay.
7 A. And so it would precede October 2014
8 but I can't tell you without a date on it
9 which version of the draft policy this is and
10 so in what ways it differs from what preceded
11 it.
12 Q. Okay. So I will rephrase then.
13 So is it correct that the Statement
14 on Sexual Assault and Other Sexual Misconduct
15 was not the policy before October 2014?
16 MR. LAPP: I object to the
17 form of the question.
18 THE WITNESS: We put in place
19 a new policy with regard to sexual misconduct
20 in October 2014. It provided clarifications
21 but it did not differ substantively with
22 regard to sexual misconduct and consent with
23 the prior policy.

19
1 This -- because it is a draft, I am
2 not comfortable -- it's not the published
3 version of the policy and so I'm not
4 comfortable saying this is the policy that was
5 in place in October 2014 because this is a
6 draft with comments, not the final version
7 from October 2014.
8 Q. (By Ms. Rossi) Right. But my
9 question wasn't about the draft. I asked if
10 the Statement on Sexual Assault and Other
11 Sexual Misconduct was not in effect until
12 October 2014, correct?
13 A. The final version of that was not in
14 effect until October 2014.
15 Q. Okay. Is this policy -- is the
16 Statement on Sexual Assault and Other Sexual
17 Misconduct more clear than the previous
18 policy?
20 THE WITNESS: I don't know
21 how to answer that question.
22 Q. (By Ms. Rossi) Did it provide
23 clarification?
20
1 A. I think that all of the iterations of
2 our policies were clear. It removed redundant
3 language or rephrased language that we felt
4 would better align with the Clery compliance
5 language and language that students were
6 requesting with regard to affirmative consent.
7 Q. Is this policy more clear than the
8 policy and that was in effect previously?
10 THE WITNESS: Again, I -- it
11 provides greater specificity. I suppose if
12 people find greater specificity clarifying
13 then, yes.
14 MR. LAPP: Do you want to
15 mark that?
16 MS. ROSSI: Yeah. I forgot
17 to mark that. So we'll mark that as 148.
19 Q. (By Ms. Rossi) I'm going to show you
20 WMS 11868. Would you take a look at that,
21 please --
22 A. Mm-hmm.
23 Q. -- along with the attachment? So it

21
1 would be -- I didn't attach the whole thing.
2 I only printed out two pages of the
3 attachment.
4 MR. LAPP: So we have a
5 document that's 11868, 11870 and 11871 and
6 11872.
7 Q. (By Ms. Rossi) Why did Mr. Sheehy
8 email the SUNY guidance document to these
9 recipients, do you recall?
10 A. Because in addition to bringing the
11 student policy into compliance with the VAWA
12 Amendments to Clery, at the same time Martha
13 Tetrault, who was the director of Human
14 Resources; Karen Swann, who was the associate
15 dean for institutional diversity and equity;
16 Denise Buell, the dean of the faculty; and Lee
17 Park, the assistant dean of the faculty, were
18 revising the policies for staff and faculty
19 with regard to sexual misconduct, domestic
20 violence, stalking, and retaliation, so all of
21 us were engaged in discussing policy language
22 and I understood that Vice President Sheehy --
23 Associate Vice President Sheehy thought that

22
1 the State University of New York policy, which
2 was what was attached, might be helpful in
3 that regard.
4 Q. Okay. And he mentions in there that
5 the document was getting a lot of buzz on a
6 risk management message board. Do you recall
7 what that buzz was about?
8 A. I am not a part of that message board
9 so I don't know the content of it.
10 MS. ROSSI: Okay. We'll mark
11 that is as 149.
14 this printout from your website. It is titled
15 "Diversity & Community," and I guess this is a
16 Committee on Diversity and Community.
17 A. Mm-hmm.
18 Q. And it states on the website that the
19 Committee on Diversity and Community reviewed
20 the College's discrimination and sexual
21 harassment/misconduct grievance procedures.
22 Was the Committee on Diversity and
23 Community involved in assisting the revisions

23
1 to the policy in fall 2014 leading up to fall
2 of 2014?
3 A. There are members of the Committee on
4 Diversity and Community who were involved for
5 that. So the associate dean for institutional
6 diversity is an ex officio member of the
7 Committee on Diversity and Community. At that
8 time that was Karen Swann, who was copied on
9 that email that we just referred to.
10 Q. Okay. Thanks.
11 MS. ROSSI: We'll mark that
12 as 150.
14 Q. (By Ms. Rossi) All right. I'm going
15 to show you this email that you provided me,
16 WMS 12004 and WMS 11983. And is it correct
17 that the document that was attached in this
18 email to -- one is to David Boyer -- to David
19 Boyer and to you included this College's
20 sexual misconduct policies and procedures that
21 were in effect up to and including September
22 2014?

24
1 THE WITNESS: I don't recall
2 by just looking at the paper printouts of the
3 email. I would need to look at it. I would
4 need to look at the document that was attached
5 to the email to confirm that that was true.
6 Q. (By Ms. Rossi) Okay. That's fine.
7 MS. ROSSI: We'll mark that
8 as 151.
11 this email, WMS 12025 and WMS 12042 that was
12 attached. Okay. So is it correct that this
13 attachment to this email reflects what was on
14 the website at the time of this email?
15 A. I -- assuming that this attachment is
16 sexual.assault.web -- so there's -- on the
17 email in WMS 12025 there is the name of an
18 attachment, which is a pdf document called
19 sexual.assault.web. I -- this was an email
20 conversation, which I was not privy to at that
21 time, and so without looking at it again in
22 its original context I don't know for sure
23 that this was the document that was attached

25
1 to that email. So this 12042 is a document
2 that was retrieved from the Dean of the
3 College's website but it is undated and
4 without looking at it as the actual attachment
5 to this email, I don't know if that reflects
6 the text as it was on the website on September
7 25th, 2014.
8 Q. Okay. So this document was provided
9 to me by you I assume. Did you compile all
10 the documents pertaining to the 30(b)(6)
11 deposition?
12 A. Well, no, I didn't.
13 Q. No.
14 A. Darryl Lapp compiled those documents.
15 Q. Okay. So you can't answer questions
16 regarding this document?
17 A. I can answer questions about the
18 documents that are in front of me but I didn't
19 compile this document, so I never was a
20 recipient of this email. (Indicating)
21 MS. ROSSI: Okay. Can we
22 break for a minute?
23 (Discussion off the record.)

26
1 Q. (By Ms. Rossi) Is it correct that
2 this policy was online at the time of
3 September 2014?
4 A. I believe that it would have been. I
5 don't know for sure because this is an undated
6 pull from the Williams College website. And
7 so if -- I can see that it was pulled from
8 dean.williams.edu the sexual misconduct,
9 Understanding the Williams Code of Conduct.
10 There is the language between the
11 policy preceding October 2014, the language in
12 place in October 2014-2015, and the language
13 in '15-'16 is very, very similar and so
14 without looking at them in conjunction with
15 one another, I cannot say definitively exactly
16 which date this was. September 25th was very
17 close to the October change date of the
18 policy, and I don't know without looking at it
19 in context what date it came from. So I can't
20 look at this and say, ah-ha, based on this,
21 this is from September 2014 versus
22 September -- or, excuse me, October 2014.
23 MR. LAPP: There are other

27
1 documents in the case that do that. We don't
2 have to try to infer from other undated
3 documents. There are other documents in the
4 case from which we have the policy language.
5 For example, Exhibit 78, which was produced,
6 which has all the different iterations of the
7 policy language.
8 MS. ROSSI: I just -- well,
9 okay.
10 MR. LAPP: As one example,
11 among others.
12 MS. ROSSI: All right. We'll
13 mark this as Exhibit 152.
14 (Exhibit No. 152 marked.)
15 Q. (By Ms. Rossi) Okay. So is it
16 correct that there was a policy online
17 regarding sexual misconduct prior to October
18 2014?
19 A. Yes, there would have been a policy
20 online. Although prior to that date what was
21 placed online was the student -- the language
22 from the student handbook, which for many
23 years prior to 2014 did not articulate a

28
1 separate policy.
2 Q. Okay. Who is Sarah Underhill?
3 A. Sarah Underhill was at the time a
4 trustee.
5 Q. And Leila Jere?
6 A. Leila Jere was at the time the
7 president of the Society of Alumni.
8 Q. And do you know why Keli Gail would
9 be conveying to Sarah that it would be a good
10 idea to share this handy collection of latest
11 web pages instead of outdated ones.
12 A. At the time because the national
13 conversation about sexual misconduct on
14 campuses was so prevalent, Williams alumni
15 were taking a strong interest in what was
16 going on at the College around sexual
17 misconduct. Many Williams alumni have
18 children who are students at the College and
19 so the board of trustees and the Society of
20 Alumni had become interested in how alumni
21 could better understand the College's policies
22 and what was going on in terms of proactive
23 work to both prevent and respond to sexual

29
1 misconduct; and so Keli Gail, who is the
2 assistant to the president and the secretary
3 for the board of trustees, was endeavoring to
4 pull together materials that would be useful
5 to those two groups.
6 Q. Okay. So is it fair to say that Keli
7 Gail was emailing not outdated ones she says
8 but not outdated policies to Sarah Bolton?
10 form of that question.
11 If you understand it...
12 MS. ROSSI: Yeah. I'm not
13 sure if I phrased it correctly.
14 Q. (By Ms. Rossi) Is it reasonable to
15 say that Ms. Gail was emailing the most
16 current policies of the College to Sarah
17 Bolton?
18 A. No, that is not correct.
19 Q. No.
20 A. Prior to 2013-2014 there were --
21 anyone could have a web page on the
22 Williams.edu -- not anyone but anyone in the
23 Williams community could have a web page on

30
1 the Williams.edu domain. So the student Rape
2 and Sexual Assault Network could put up
3 educational definitions of consent. The
4 Williams College Health Center could put up
5 their information about health resources and
6 so what would sometimes happen is that people
7 would forget to update the page and someone
8 would pull up a page and it would not have
9 up-to-date information about phone numbers,
10 local resources, timelines for emergency
11 contraception.
12 Q. Would the Dean's Office have the most
13 up-to-date policy on the dean's website?
14 A. The policy would have been on the
15 dean -- the Student Code of Conduct policy
16 would have been on the Dean of the College's
17 web page.
18 Q. Right. So it would be
19 dean.williams.edu?
20 A. Correct.
21 Q. Okay. Thank you.
22 Now, returning to Exhibit 152, is it
23 correct that the policy at the time as the

31
1 policy here in this document says that the
2 sexual misconduct (which includes rape and
3 sexual assault) is defined in the Williams
4 Code of Conduct as follows?
5 A. That's correct.
6 Q. Okay. I'm going to show you WMS
7 12048 and 12051. Could you please describe
8 these for us?
9 A. 12048 is an email from Sarah Bolton
10 to Cynthia Haley on Thursday, October 30th,
11 2014 at 6:55 p.m. And it says:
12 At the top of the home page, please
13 add this:
14 For a pdf version of the complete
15 policies on this site, please click here that
16 would link to this document, attached below.
17 The attachment would have been sexual
18 misconduct policies October 2014.pdf.
19 MS. ROSSI: Okay. I'm just
20 going to mark those as Exhibit 153.
23 WMS 11843, WMS 11844, and an attachment that

32
1 did not have a Bates number. Oh, wait. No,
2 sorry. Never mind, just those two Bates
3 identified documents.
4 Okay. There is a safer training that
5 is referenced in this forwarded email from
6 Isabel Abraham --
7 A. Raveson?
8 Q. Raveson. And who is Isabel?
9 A. Isabel Abraham-Raveson was a student
10 who graduated with the Class of 2015, who was
11 a part of the SAPA, Sexual Assault Prevention
12 and Awareness working group.
13 Q. Okay. Was she also part of the
14 Feminist Collective?
15 A. I believe so.
16 Q. How did these suggestions from the
17 Feminist Collective and the other students
18 come about?
19 A. The -- one of the projects for SAPA
20 in the 2014-2015 school year had been to look
21 at both the College's policies but also how we
22 educated the student body on those policies.
23 And so a project of the members was to take a

33
1 look at policy language both in Williams own
2 policies as well as at other schools, see what
3 language students felt best captured both
4 compliance and also community norms that they
5 -- and community standards that they wished to
6 be in place, and then to talk both through
7 both the policy as well as how to educate
8 students about the policy.
10 that as Exhibit 154.
12 Q. (By Ms. Rossi) Were these suggested
13 -- were suggested changes from SAPA and,
14 correct me if I'm wrong, SAPA's umbrella group
15 for all these disparate groups that helped
16 with making recommendations; is that correct?
17 A. SAPA is a working group that consists
18 of students representing interested student
19 groups, at-large student representatives of
20 students who are just interested in the issue
21 even if not necessarily attached to a
22 particular group, and staff members.
23 Q. And did they present their proposed

34
1 amendments to the wider college community?
2 A. Not to the wider college community in
3 the sense of that's not how Williams's
4 policies get made. They're not voted on like
5 ballot initiatives. They -- we discussed them
6 in SAPA meetings. Those students who had
7 constituent groups like College Council, like
8 the Junior Advisors, like the Student-Athlete
9 Advisory Council, would take the proposed
10 language back to their constituents, talk it
11 through, get suggestions, and come back to the
12 table for more discussion.
13 Q. Okay. If you can look at 154, could
14 you tell me what groups might be represented
15 here in the recipients?
16 A. I mean, these are short-form unit
17 email addresses --
18 Q. Yeah.
19 A. -- so I can't tell you who each of
20 these are. I can tell you what groups have
21 always been represented on SAPA. So they
22 would be the Rape and Sexual Assault Network;
23 Men For Consent, which is now called MASC,

35
1 M-A-S-C; the Student-Athlete Advisory Council;
2 the Junior Advisors; the Neighborhood
3 Leadership Teams; the College Council; the
4 Feminist Collective, the Queer Student Union,
5 MinCo, The Minority Coalition. It's capital
6 M, lower case I-N, capital C, long case O,
7 MinCo. We love an acronym. The Rape and
8 Sexual Assault Network; a group called SWAG,
9 S-W-A-G, Sexual Wellness At Greylock, which is
10 called now SWAN, Sexual Wellness Advocacy
11 Network; and then at-large students.
12 Q. The author of this email indicates
13 that there would be discussion and votes on
14 changes that they had discussed.
15 A. I need to look at the email to tell
16 exactly who would have been voting on that.
17 Q. Oh, yes.
18 A. I mean she does say discussing and
19 voting but the -- it was a consensus
20 decision-making model. There was not a
21 balloting process that went on.
22 Q. Okay. Was the Feminist Collective
23 present at all the discussions?

36
1 A. It's not a required -- it's a
2 regularly scheduled meeting that is twice a
3 month but students come in and out depending
4 on their workload, so not every member is at
5 every single meeting.
6 Q. Do you recall that there was a member
7 of the Feminist Collective at every meeting
8 pertaining to these revisions?
9 A. I don't recall that in particular.
10 They were a group who sent student
11 representatives but I can't recall their
12 attendance at each specific meeting.
13 Q. Okay. I'll take that back.
14 I'm going to --
15 A. And, I'm sorry, Pure Health. I
16 forgot a group. Pure Health was also a part
17 of this.
18 Q. Okay. I'm going to show you WMS
19 11852, 11853, 11854, 11855. And could you
20 take a look at that, please?
21 So the process of student input and
22 these group suggestions and discussions on the
23 Sexual Misconduct Policy, did it commence in

37
1 spring 2015?
2 A. It was an ongoing conversation
3 through several meetings in 2014-2015 and
4 continued into 2015-2016.
5 MS. ROSSI: Okay. Now, I'm
6 going to mark that, so we'll have that marked
7 155.
9 (Brief recess taken.)
10 Q. (By Ms. Rossi) Okay. Returning to
11 11844 in which there's a number of suggestions
12 that the group has made -- would like to have
13 made to the policy, do you know why these
14 students wanted to remove the sentence: Both
15 parties have the obligation to communicate
16 consent or lack of consent?
17 A. The conversation that had occurred
18 through several meetings was that it was
19 redundant given that there's earlier language
20 in the sentence that talks about the necessity
21 of all parties communicating. They just felt
22 that it was redundant to the language. So
23 because it was an affirmative consent policy,

38
1 because it was based on freely given approval
2 or agreement by all parties that it was just
3 one more sentence that was redundant and
4 unnecessary.
5 Q. Do you agree with the statement that
6 is in one of the suggestions, that consent
7 cannot be communicated through conduct?
8 A. The conversation around that was
9 quite rich. There were a number of students
10 who were talking about the necessity of having
11 disability-inclusive language in the policy,
12 so restricting it to verbal language they felt
13 might be not inclusive enough for, for
14 example, deaf students who might not
15 communicate verbally. So there was some
16 conversation about why it needed to
17 indicate -- why it needed to be about language
18 rather than verbal and also that the policy
19 should be words and conduct so that it was not
20 the case, for example, that someone was
21 coerced or compelled into saying yes when
22 their conduct might indicate that, in fact,
23 they were not consenting. So that suggestion

39
1 was the topic of lengthy conversation over
2 several meetings by the group.
3 Q. Okay. I'm going to the -- I thought
4 that there was drafts attached. Okay. I'm
5 going to show you WMS 12074, WMS 12073, and
6 WMS 12076 and 77. Can you look at these --
7 there are two Frequently Asked Questions
8 documents that were provided to me. Do you
9 know when and where these documents were
10 located on the website?
11 A. These appeared as part of the Dean's
12 Office website certainly prior to 2014. This
13 would be an example of information that we
14 removed from the website over the course of
15 '14-'15, '15-'16 to avoid communication
16 between these which are educational materials
17 and other materials on the website which are
18 policy. (Indicating)
19 Q. Okay. So these are not meant to be
20 misconstrued as policy; is that correct?
21 A. That's correct. These are
22 educational materials.
23 Q. Do you know when they were removed?

40
1 A. I don't know exactly but I remember
2 the conversation. They were there in 2014
3 when I began and in 2014-15 we were talking
4 about better formats to provide information as
5 education so, again, that they would not be
6 confused with policy on the website.
7 Q. Okay. So where it says that consent
8 must be freely given, clearly communicated,
9 verbally stated, is it correct that that was
10 not policy at the time except, yes, freely
11 given but "clear" does not appear in the
12 policy at the time and verbally, it can be
13 conduct as well so it --
15 form of the question but.
16 Q. (By Ms. Rossi) You were going to say
17 something?
18 A. Well, what I was going to say is
19 because these are not dated I can't tell you
20 which form of the -- which piece of the policy
21 was in effect at the time.
22 What I can say is that these were,
23 you know, student groups were making T-shirts

41
1 with this on it. Student groups were making
2 sticky notes with the freely given, clearly
3 communicated now for this with you, which is
4 not -- would not be construed as disseminating
5 our policy. It was education materials.
6 MS. ROSSI: Okay. We're
7 going to mark that as 156.
9 MS. ROSSI: And you have to
10 stop at 2?
11 THE WITNESS: I do have a
12 hard stop at 2.
13 (Discussion off the record.)
14 (The deposition suspended.)
15 (The deposition resumed.)
16 Q. (By Ms. Rossi) So how was the change
17 in the policy in October 2014 communicated to
18 the community?
19 A. So we changed on the website. We
20 communicated it through a series of meetings
21 with people who would interact with the
22 website, so all of the deans, the SASS, so
23 Sexual Assault Survivors Services, so people

42
1 who serve in an advisory capacity to
2 individuals who might have experienced harm;
3 and then I believe there was also an
4 all-campus email from Sarah Bolton to the
5 community pointing to the new student handbook
6 and pointing to the new policy.
7 Q. Okay. Why was that email not -- do
8 you know why that email was not produced?
9 MR. LAPP: I'm sorry, what
10 email is that? I went to a different place
11 there.
12 THE WITNESS: I thought that
13 -- Yes, I'm sorry. I thought that in October
14 of 2014 when the new policy was put on the
15 website that there was an all-campus email
16 sent by Sarah Bolton pointing people to the
17 new policy but I could be mistaken in my
18 recollection of that.
19 MR. LAPP: We'll look for
20 that email and if we can find it, we'll
21 produce it.
22 MS. ROSSI: That would be
23 great.
43
2 the email from October 2015 and we'll mark it
3 as 164.
5 MR. LAPP: Did you want to
6 amend something about your answer or, no, do
7 you want to start here?
8 THE WITNESS: In October of
9 2014 I thought that there was an email but I
10 could be mistaken.
11 MR. LAPP: Okay.
12 Q. (By Ms. Rossi) Okay. So --
13 A. I could have been thinking of this
14 email, which I see now is 2015.
15 Q. Right. Okay. And I will just take
16 this back then.
17 So I'm going to show you WMS 11845
18 through WMS 11849. Okay. So there was
19 attached to this email some draft policy
20 language; is that correct?
21 A. Yes. From the email of August 5th,
22 marked 11845, where I say: Here they are! I
23 did make changes to both of them to reflect

44
1 the language we discussed on Monday. Then,
2 yes, it sounds like there was draft policy
3 language attached to that.
4 Q. Okay. So looking at this document
5 that -- okay. Just looking at this, so is it
6 correct that this was a draft then?
8 Q. Okay. Now, is this a draft that
9 students were using?
10 A. So at this time the staff and faculty
11 policy was also being updated. The language
12 in the draft that precedes this was -- there
13 were examples where if students did these
14 things, if students did that, the intention
15 was to have the definitional language be
16 usable for the student, staff, and faculty
17 policies and so the changes that I am
18 referring to having made are in places where
19 it says the student did X or the student did
20 Z, removing that and saying if an individual
21 does, so that the definitional pieces would
22 have utility across the three policies,
23 students, staff, and faculty.

45
1 Q. Okay.
3 this as 165.
5 Q. (By Ms. Rossi) Going back to Exhibit
6 154 and looking at what they have -- what the
7 students or -- yes, Isabel's a student, so
8 what the students have quoted here as being
9 the policy language that they are working on
10 revising, why doesn't it say affirmative
11 consent?
12 A. Why doesn't it say affirmative
13 consent?
14 Q. Right. Because this is in 2015 --
15 A. Mm-hmm.
16 Q. -- and I'd assume you're making
17 revisions to the most recent policy. So why
18 doesn't it say affirmative consent?
19 A. Because affirmative consent was
20 almost what I would describe as industry
21 jargon within the group of people who are
22 having conversations about sexual misconduct
23 on college campuses. So affirmative consent

46
1 was talked about freely on list services by
2 Title IX officers, by people engaged in sexual
3 violence prevention, but it needs some
4 additional -- not everyone knows automatically
5 what affirmative consent means and so it
6 needed some additional policy language
7 flushing that out.
8 Q. Okay. So this policy here they're
9 not quoting the policy that was in place at
10 the time?
11 A. It appears to be copied from our
12 policy language but I don't know when -- so in
13 February 2015 it appears that that would be
14 copied from our policy language.
15 Q. Okay. And is it correct that it
16 doesn't state clearly indicate before --
17 clearly indicate freely given approval?
18 A. Well, it sounds like that's the
19 language from the education, the FAQ education
20 document, which was not a part of our policy
21 language.
22 Q. Okay. I'm going to show you Exhibit
23 46 from Ninah Pretto's deposition. Can you

47
1 compare this policy here with this policy here
2 and see if they are exactly the same?
3 MR. LAPP: So this policy
4 here and this policy here means Exhibit 46 as
5 compared with the second page of Exhibit 154.
6 MS. ROSSI: Yes.
7 THE WITNESS: And, I'm sorry,
8 could you repeat -- I lost the --
9 MS. ROSSI: Sure.
10 THE WITNESS: -- of your
11 question. Could you repeat your question?
12 MS. ROSSI: Sure.
13 Q. (By Ms. Rossi) Can you compare the
14 policy language here starting at "consent" --
15 A. Mm-hmm.
16 Q. -- on Exhibit 46 compared to the
17 quote here starting with "consent" on WMS
18 511844 [sic]?
19 A. This appears to be the same policy
20 language.
21 Q. So why would the people who are
22 involved in revising the policy be using an
23 outdated policy to make revisions?

48
2 THE WITNESS: It's not clear
3 to me that this is outdated policy language.
4 Q. (By Ms. Rossi) Well, it's updated in
5 2014, correct?
6 A. It was updated -- without looking at
7 the document that shows the over-time updates,
8 we made several updates in -- prior to October
9 2014 and '14-'15, so without looking at that
10 document, I can't tell whether or not it was
11 outdated.
12 Q. Okay. So we'll look at Exhibit 48
13 from Ms. Pretto's deposition. Okay. And if
14 you see here in the post October 2014 policy,
15 the changes are in italics. So the
16 statement's here: Williams College Code of
17 Conduct requires affirmative consent for all
18 sexual activity --
19 A. Mm-hmm.
20 Q. -- is present in post 2014, yet it is
21 not present --
22 A. These are from different sections of
23 the policy. This is from the definition of

49
1 consent in the policy. This is from the
2 Statement of the Sexual Misconduct Policy. So
3 they're not -- they're copied from different
4 parts of the document, so that's why those two
5 things don't match each other.
6 These are the same language.
7 Q. Mm-hmm.
8 A. This is a different section of that
9 document. (Indicating)
10 MR. LAPP: And when you say,
11 just for the record, "These are the same,"
12 you're referring to Exhibit 46 and 154. And
13 the one that's different is Exhibit 48.
14 THE WITNESS: Correct.
15 MR. LAPP: Okay. Just so we
16 know when we say here this is.
17 THE WITNESS: Sorry.
18 MR. LAPP: Yeah.
19 Q. (By Ms. Rossi) Okay. So this policy
20 language here is the only place in which it is
21 in the Code of Conduct; there's no separate
22 definition section. This is it. This is all
23 that existed before October 2014. So there is

50
1 a parallel between this pre-October '14 policy
2 to what is cited in Ninah Pretto's Exhibit 48.
3 So there's no picking and choosing from
4 different places as far as I'm aware. Could
5 you explain what you meant?
6 MR. LAPP: If you're done
7 then I'll object.
8 MS. ROSSI: Yes.
9 MR. LAPP: Okay. I object to
10 the form of the question. Thank you.
11 THE WITNESS: In exhibit --
12 the Williams College Sexual Misconduct Policy
13 is quite lengthy and in Exhibit 46 and Exhibit
14 154 there are selections that are identical
15 from the same part of the Sexual Misconduct
16 Policy.
17 This paragraph on page one of Exhibit
18 48 comes from a different part of that same
19 policy. All of it is the policy, all of it is
20 part of the Code of Conduct. It just happens
21 not to be the same piece of the document as
22 you have highlighted in Exhibits 46 and 154.
23 Q. (By Ms. Rossi) Okay. So in the post

51
1 October 2000 [sic] policy, is it correct that
2 consent means at the time of sexual conduct
3 words or conduct clearly indicate freely given
4 approval?
5 A. Yes, that is what that says --
6 Q. Right.
7 A. -- at that moment. This is from a
8 different section of the same document.
9 Q. So why would it be defined
10 differently in a different section without the
11 "clearly" part, the "clearly" term before
12 "indicate"?
13 A. I don't -- could you repeat the
14 question?
15 Q. Okay. It seems like the students
16 were using an outdated definition of consent
17 by the absence of the term "clearly" before
18 "freely"; is that correct that they were using
19 the wrong policy?
22 Q. (By Ms. Rossi) Definition. I'm
23 sorry.
52
1 A. So I -- what I do not know is whether
2 -- I would need to look at the -- our Consent
3 Policy in its entirety to tell you where the
4 word "clearly" appears before "clearly
5 indicate freely given approval or agreement"
6 and where it does not and at what point those
7 changes were made because what you're asking
8 me is why are they using an outdated form of
9 the policy and I'm not clear that they are
10 using an outdated form of the policy.
11 The other thing that I would say
12 further is that SAPA had tossed around a lot
13 of draft language, and so I cannot
14 definitively say that in this email what Isy
15 Abraham-Raveson is copying from was off of our
16 website or off of draft language that had been
17 circulating amongst the group.
18 Q. Okay.
19 A. All I'm saying is that this passage
20 in Exhibit 154 matches the passage in Exhibit
21 46.
22 Q. Okay. So we'll look again at Exhibit
23 152 and page two from the Dean's website. Is

53
1 it correct that the same language on the
2 website at the time of the 2014 email to which
3 it was attached is the same, again, as the
4 language that is being used over a year and a
5 half later by the students?
6 A. So with all due respect, because I
7 was not on this original email, I -- I don't
8 know that this was the document that was
9 attached to this email. The Bates numbers are
10 not consecutive. There have been a couple of
11 times when you have handed me an exhibits when
12 the right attachment wasn't attached to it or
13 you couldn't find it and so I can compare the
14 language that's on 12042. I can't
15 definitively say that this -- that 12042 was
16 the document that was attached to the email in
17 12025.
18 Q. Okay. Well --
19 A. Without seeing -- without looking at
20 the email and opening that attachment as it.
21 Q. Okay. Is it correct that the
22 language here is the same as the language that
23 was used in the students' email?

54
1 A. So the language in 12042 is the same
2 language as was copied and pasted into the
3 students' email in 11844.
4 Q. Okay. So assuming that it is
5 accurate, that this is attached to the
6 September 25th, 2014 email, why would the
7 students be using an outdated definition of
8 consent in making their revisions to the
9 policy?
10 MR. LAPP: Objection. Asked
11 and answered.
12 THE WITNESS: It is not clear
13 to me that this definition is outdated. If,
14 indeed, 12042 was what was on the Dean's
15 Office policy in September of 2014 and Isy's
16 email was sent in February of 2015, that's in
17 the '14-'15 academic year. So it would be the
18 policy in the same academic year, '14-'15.
19 February 2015 would precede any changes that
20 were made in October 2015, which would be part
21 of the '15-'16 academic year.
22 Q. (By Ms. Rossi) Okay. I'm going to
23 show you Exhibit 78 from Dean Sandstrom's

55
1 deposition. This is her document that
2 chronicles the definition of consent that was
3 in place over time.
4 A. Mm-hmm.
5 Q. So the changes that were made in the
6 policy in October 2014, and which were
7 reflected accurately in Exhibit 48 of Ninah
8 Pretto's -- we don't have to go into that.
9 A. Mm-hmm.
10 Q. So if the changes in the policy in
11 October 2014 included adding -- and now we're
12 talking about what she indicates is the
13 definition of consent --
14 A. Mm-hmm.
15 Q. -- includes now a statement that says
16 the Williams College Code of Conduct requires
17 affirmative consent for all sexual activity --
18 A. Mm-hmm. Everyone started copying --
19 Q. Yeah.
20 A. -- at the sentence following that.
21 So that is in the policy. It simply means
22 that the students started copying after that
23 sentence.
56
1 Q. Okay. So when was the term "clearly"
2 put into before "freely given approval"?
4 form of the question insofar as it's not clear
5 that that happened. We only see the word
6 "clearly" in the document that you wrote.
7 This is a document -- you see the word
8 "clearly" --
9 MS. ROSSI: Yeah, yeah.
10 MR. LAPP: -- in Exhibit 48,
11 which is a document you wrote.
12 MS. ROSSI: Right, right.
13 MR. LAPP: So when did you
14 put the word "clearly" in?
15 MS. ROSSI: I probably copied
16 it from some place.
17 MR. LAPP: Well, I just -- we
18 don't see that in any other College's
19 documents, it seems.
20 THE WITNESS: The only place
21 that "clearly" appears is in the FAQ document,
22 which is not the policy.
23 MS. ROSSI: Right.

57
1 THE WITNESS: It is an
2 educational document.
3 MR. LAPP: Right, right.
4 Okay.
5 MS. ROSSI: Well, it appeared
6 in the report. So it must have been --
7 MR. LAPP: I don't know --
8 this document you're looking at and relying on
9 is a document you created.
10 MS. ROSSI: Right, right.
11 MR. LAPP: So that's your
12 word.
13 It seemed to me to make more sense to
14 use actual College --
15 MS. ROSSI: I'm sorry. To
16 use what?
17 MR. LAPP: To use actual
18 College policy documents but that's not how
19 we're doing this so on we go.
20 Q. (By Ms. Rossi) Okay. So everything
21 is marked. I will take this back.
22 Can you give an example of how
23 consent through actions can be communicated?

58
1 A. Sure. So an example of consent
2 through actions would be, for example, if
3 someone said, Can I touch your genitals, which
4 is obviously not language that most college
5 students would use but I'm using it in my
6 example. Can I touch your genitals? A person
7 might take their partner's hand and guide it
8 to their genitals, which would be an action
9 way of communicating consent as opposed to
10 saying, yes, you may touch my genitals.
11 Q. And what if the person squeezes the
12 genitals instead of touching the genitals; is
13 that a violation of the --
14 MR. LAPP: Which person?
15 Which person is squeezing the genitals in this
16 hypothetical?
17 MS. ROSSI: The person who
18 asked?
19 THE WITNESS: So is -- I'm
20 sorry, I got a little lost from our example
21 here. Could you repeat the question?
22 Q. (By Ms. Rossi) May I touch your
23 genitals I think was the hypothetical

59
1 question, right?
2 A. Ah-ha.
3 Q. So if the person went ahead and
4 squeezed the genitals but the person who was
5 being squeezed thought they would just be
6 stroked, would that be a violation of the Code
7 of Conduct?
8 A. So that is probably not a fact
9 pattern sufficient to determine. A panel
10 would need to look at an entire fact pattern
11 to say whether that was a violation of Code of
12 Conduct. I -- you asked me to come up with an
13 example and so I just thought of one off the
14 top of my head, so I don't -- there's not
15 enough information in that sentence to say
16 definitively yes or no that would be a
17 violation.
18 Q. Okay. I'm going to give you another
19 hypothetical. Say there was a rear entry
20 position in which the male was engaging in
21 intercourse on top of the female and she moved
22 a bit to side to side; would that be action
23 conveying nonconsent?
60
3 THE WITNESS: Again, there's
4 really not enough information there to
5 determine -- there's contexts that --
6 Q. (By Ms. Rossi) All other things --
7 all other things being equal and consensual,
8 would that be enough?
9 A. All other things being equal and
10 consensual would mean that there was consent
11 but there's -- so in this hypothetical example
12 a reason that someone might move their
13 position during sexual intercourse might be to
14 move in such a way that it would make it more
15 pleasurable for them. Another reason that,
16 given the same set of circumstances, that a
17 person might move during the course of sexual
18 intercourse was that they, in fact, did not
19 want to be penetrated any longer and were
20 trying to move away from the other individual.
21 So absent a larger set of facts, I can't take
22 one snapshot of a movement and say it is
23 always consensual, it is always nonconsensual.

61
1 The facts are the core of how a panel would
2 make that determination.
3 Q. Okay. And, likewise, along the same
4 lines of thinking then, so shifting around
5 itself would not be an action communicating
6 nonconsent in the same context of what you
7 just said; is that correct?
9 THE WITNESS: No. No, it
10 would not be enough in and of itself to
11 communicate nonconsent. There would be a
12 whole context of information about the
13 relationship and the conduct between the
14 individuals that were engaged.
15 Q. (By Ms. Rossi) Okay. Do you think
16 that conduct can include passive inaction; is
17 that a form of conduct?
18 A. Do I think -- I don't understand that
19 question. I don't know how to answer that.
20 Q. Can you define the word conduct for
21 us?
22 A. Conduct would be behavior or action.
23 Q. So do you believe that conduct has to

62
1 be active?
2 A. I think that we are splitting hairs
3 between conduct and the existence of being.
4 So if I'm sitting passively in my chair --
5 Q. Mm-hmm.
6 A. -- I think that we're splitting some
7 semantic hairs about whether I am engaging in
8 the conduct of sitting in my chair or whether
9 I am not doing anything.
10 Q. Okay. So taking Merriam Webster's
11 definition of conduct, which is, in its
12 transitive verb form: To take part in, the
13 operation or management of, to cause oneself
14 to act or behave in a particular and
15 especially a controlled manner, and to bring
16 by or act as a medium for conveying or
17 transmitting. Under that definition would you
18 agree that passivity can be conduct?
19 MR. LAPP: I object because
20 the transitive form that you just defined is
21 conduct, not the passive form -- the
22 intransitive of conduct. You're mixing your
23 definitions.
63
1 Q. (By Ms. Rossi) Well, then in the
2 person conducting himself in --
3 MS. ROSSI: Hmm. That's a
4 good question. Thank you for calling that
5 out.
6 MR. LAPP: I think, you --
7 MS. ROSSI: Hold on.
8 Q. (By Ms. Rossi) Would you be
9 surprised to know that Merriam-Webster defines
10 the term in its noun form as a mode of
11 behavior or the act or manner or process of
12 carrying on. So given that definition does
13 the term include passivity?
14 MR. LAPP: I'm going to
15 object to the form of the question.
16 THE WITNESS: So I -- I would
17 not -- what I'm not able to argue is what
18 Merriam-Webster accepted or rejected in their
19 defining of the term conduct.
20 What is clear in the Williams College
21 policy is that consent cannot be inferred from
22 silence or passivity.
23 So to the extent that the policy is

64
1 what governs student behavior and not the
2 Merriam-Webster dictionary, passivity cannot
3 mean conduct as far as our policy goes.
4 Q. (By Ms. Rossi) And if a policy does
5 not say conduct may not be inferred by silence
6 or passivity --
7 A. It says consent may not be inferred
8 from silence or passivity.
9 Q. Yes, yes. Then in that case would
10 silence or passivity be conduct that may imply
11 consent if that clause is not in the policy?
14 Q. (By Ms. Rossi) I can rephrase if you
15 want.
16 A. Sure.
17 Q. Okay. In the case where a policy is
18 completely silent on whether or not silence or
19 passivity may be inferred as consent, in such
20 policies or under such policies would silence
21 or passivity constitute consent?

65
1 THE WITNESS: What I am able
2 to speak to you today is the legislative
3 history of Williams's policy, which is not
4 silent on that matter. And so I can't speak
5 to other policies and their legislative intent
6 if they have or don't have that information.
7 Williams has -- is declarative in
8 that piece of the Consent Policy to say that
9 silence or passivity do not in and of
10 themselves convey consent. And so it is --
11 the intention was to be clear about that and
12 it has been in our policy.
13 Q. (By Ms. Rossi) Okay. It was added
14 in October 2014. So before 2014 when the
15 policy was silent and did not have that
16 statement, then would the policy then provide
17 for silence or passivity to imply consent?
20 THE WITNESS: That -- so it
21 is not in those exact words but there are
22 elements of that same policy, which is that a
23 verbal no, no matter how slight, or

66
1 resistance, no matter how passive, which does
2 refer to passivity, is in the policy before
3 2014.
4 Q. (By Ms. Rossi) Okay. We will look
5 again at October 2014 in Dean Sandstrom's --
6 and could you please read what is stated here
7 starting with "a verbal"?
8 A. A verbal no, no matter how
9 indecisive, or resistance, no matter how
10 passive, constitutes the lack of consent.
11 Q. Okay. So is it correct here that the
12 lack of consent is defined as a verbal no, no
13 matter how indecisive, or resistance, no
14 matter or how passive?
15 A. Well, there are sentences before that
16 which articulate what consent means, which is
17 about the core point, which is that words or
18 conduct indicate freely given approval or
19 agreement without coercion by both parties in
20 the sexual contact.
21 So that -- that is also a piece of
22 the Code of Conduct. It needs to be
23 understood in its entirety, not with specific

67
1 pulled sentences. Individual sentences from
2 the policy do not in and of themselves make
3 the whole of the policy. The policy is these
4 things altogether.
5 Q. Can someone's conduct be silence?
6 A. I believe that that was just one of
7 the issues that we were debating the semantics
8 of just now, which is that if I sit here
9 silently is my conduct that I am sitting in
10 silence or am I not engaging in conduct
11 because I am sitting in silence, and that
12 again is a semantic argument.
13 Q. I will take this back and show you
14 Exhibit 144 from Mr. Gordon's deposition here.
15 So in this slide here, page two, why is the
16 definition of consent: At the time of the
17 sexual contact, words and -- "and" is
18 italicized and underlined -- conduct, and you
19 can see the rest of the sentence. Why does it
20 have "and" underlined and italicized?
21 A. So this is a training document. This
22 is not the policy. While the language is very
23 similar to the policy, it is a training

68
1 document. And so one of the pieces of the
2 training document is meant to help people
3 understand the distinction that I mentioned
4 earlier that the SAPA group was trying to hash
5 out about why one might include words -- both
6 words and conduct as a piece of the Consent
7 Policy because words alone, even if someone
8 compelled me -- if someone, for example, has a
9 hand on my neck and says, You better say yes
10 to this, that would constitute coercion. And
11 so I might say yes because I want them to take
12 their hand off my neck -- this is purely a
13 hypothetical. So while my words might convey
14 consent, the whole context of it does not.
15 Again, conduct might convey consent but I
16 might not say anything. So to the extent that
17 this is a training document, that would be a
18 distinction that we would have talked through
19 in the panel's initial training.
20 Q. Okay. And on the first slide here it
21 states that the Williams Code of Conduct
22 requires active, specific, and clearly
23 expressed consent for all sexual activity.

69
1 Now, we've discussed earlier that
2 "clearly" does not appear, at least not at the
3 time of 2014 -- October 2014, and also doesn't
4 say "active" or "specific." Why does it say
5 so here?
6 A. Because Exhibit 144, what you're
7 pointing out, are presenter notes from a
8 trainer document that are helping people
9 understand examples of ways that consent could
10 be expressed.
11 This is not -- at no point were any
12 of these slides saying here is what the policy
13 is. Please read from it the PowerPoint note.
14 It is a training document.
15 People were also provided with the
16 Code of Conduct both at the time of their
17 training and at the time that they
18 participated in any panel discussions and said
19 -- explicitly instructed that they should hold
20 up the fact pattern to the Code of Conduct,
21 not the fact pattern to the training notes on
22 a PowerPoint.
23 Q. Okay. Why did the College embark on

70
1 the process to make the changes to the policy
2 in the spring of 2015?
3 A. So that, again, that policy work was
4 ongoing through the '14-'15 academic year, so
5 it would be a continuation of conversations
6 that had been happening and people become
7 involved with other kinds of work and the
8 stakeholders or constituents in those policy
9 discussions might have been unavailable in the
10 fall and winter and so we returned to the
11 conversation in the spring when people had
12 more time.
13 Q. Well, the first email that was
14 produced started in March -- I'm sorry --
15 February of 2015?
16 A. Mm-hmm.
17 Q. So you're saying that there were
18 conversations before that that were -- were
19 they made in an email?
20 A. No. They were conversations that
21 happened in our SAPA meetings, in regular
22 meetings that happened.
23 Q. Okay. Who decided to add the

71
1 statement: Consent may not be inferred from
2 silence or passivity in the policy effective
3 October 2015?
4 A. I don't recall specifically the --
5 any changes that would have been made to the
6 policy would have been the result of consensus
7 decision-making by a number of individuals.
8 Q. Okay. So you're saying that -- or
9 before you were saying that in the policy that
10 did not have that statement, there were words
11 or language that expressed that consent may
12 not be inferred from silence or passivity; is
13 that correct?
14 A. I'm saying that in the policy that
15 preceded October 2014, the pieces where it
16 says a verbal no, no matter how slight, or
17 resistance, no matter how passive -- I can't
18 spit it out from complete memory but I could
19 read it to you from the document -- that that
20 language, if it was changed it was the result
21 of consensus decision-making where people -- a
22 number of people, students and staff, would
23 have said this language needs to be more fully

72
1 articulated to go forward with the new policy.
2 Q. So it wouldn't be duplicative in the
3 other case where both parties are required to
4 communicate consent or lack of consent, where
5 that was taken out then it was -- and I'm
6 paraphrasing from what you said -- it was
7 unnecessary extra language, but this addition
8 would not be duplicative?
9 A. If language was added, it was because
10 the consensus decision-making of the staff and
11 students who do policy work at the College was
12 that it needed further elucidation or
13 clarification. If language was taken out it
14 was because of the consensus decision-making
15 that it was duplicative of earlier language or
16 that there was a way that it could be phrased
17 with more clarity or greater granularity.
18 Q. Do you agree that without the
19 statement that consent may not be inferred
20 from silence or passivity, that one may
21 construe that consent may be inferred from
22 silence or passivity?
23 A. Could you repeat the question?

73
1 Q. Do you agree that without the
2 statement, consent may not be inferred from
3 silence or passivity, one may construe that
4 consent may be inferred from silence or
5 passivity?
6 MR. LAPP: I'm going to
7 object to that question.
8 THE WITNESS: I -- I would
9 not agree that simply by not saying a sentence
10 that means its opposite is true. No, I would
11 not agree with that.
12 Q. (By Ms. Rossi) Okay. What does the
13 term "effective" mean?
14 A. Effective with an E or affective with
15 an A?
16 Q. With an E.
17 A. Effective can have a number of
18 different meanings.
19 Q. What does it mean in the definition
20 of consent?
21 A. Okay. So effective consent means
22 that -- in a number of places it was construed
23 to mean the same thing as affirmative consent,

74
1 meaning that it has to be communicated. It
2 has to be articulated whether by words and/or
3 language, meaning that you are effective in
4 your conveying of consent or conveying of your
5 request to interact with someone sexually.
6 Q. Why was the College's Title IX
7 coordinator not involved in the policy
8 revisions?
9 A. At which point?
10 Q. Well, was -- first of all, was the
11 Title IX coordinator, Toya Camacho, involved
12 in any of the policy revisions?
13 A. Well, Toya Camacho did not become --
14 at the time of 2014 Sarah Bolton was the
15 acting interim Title IX coordinator, so she
16 was involved up until the point that Toya
17 Camacho became the Title IX coordinator.
18 Toya is also a part of the Title IX
19 Committee for Student Concerns that meets
20 weekly, which was another venue for the
21 discussion of those conversations. And the
22 only meeting that Toya does not come to is
23 SAPA on a regular basis.

75
1 Q. Okay. Thanks.
2 Okay. I'm just going to show you --
3 well, before I do this. You earlier said in a
4 meeting that started -- I forget, around noon
5 or so, that the policy that the College put
6 into place effective October 2014 was an
7 affirmative consent policy?
8 A. Mm-hmm.
9 Q. Was the College's policy before
10 October 2014 an affirmative consent policy?
11 A. My understanding was that it was and
12 that it was understood to be an affirmative
13 consent policy.
14 Q. How was it understood?
15 A. That even if it did not use the
16 explicit words "affirmative consent," that by
17 design and by language, even again though it
18 did not use the specific words of "affirmative
19 consent," that it was a yes means yes policy,
20 that positive effective consent was the
21 requirement in the College's policy.
22 Q. Okay. And that consent, could you
23 tell us whether it had to be active?

76
1 MR. LAPP: Do you want her to
2 look at the policy or?
3 MS. ROSSI: I want to know
4 what she thinks.
5 THE WITNESS: Well, so I
6 think one thing that's important to say is I
7 came on to staff in April of 2014. And so the
8 conversation that I am talking about that I
9 was most present for was April to October of
10 2014 when the policy language was further
11 clarified.
12 So in coming on to staff and
13 beginning to look at the policies with other
14 individuals, like Sarah Bolton, like Matt
15 Sheehy, like Karen Swann, like Denise Buell,
16 like Martha Tetrault, at all points our
17 conversation was that there was an affirmative
18 consent policy and what we were looking at was
19 whether there needed to be further explication
20 or further elucidation in the policy itself as
21 to what that meant.
22 Q. (By Ms. Rossi) And there would be
23 updates and clarifications; is that correct?

77
2 Q. So are they essentially the same
3 policies before and after October 2014?
4 A. They are essentially the same
5 policies. There were not dramatic -- we did
6 not change from a no means no to a yes means
7 yes policy. We did not change from some kind
8 of substantively different understanding of
9 consent prior to 2014 to a radically different
10 understanding of consent afterwards.
11 Q. All right. I'm going to show you WMS
12 1130 and this is an email from Ms. Haynes to
13 Dean Sandstrom asking to see copies of the
14 2012 to 2013 handbook and also the October
15 2014 policy.
16 You earlier stated that there is a
17 copy of the 2013 to 2014 student handbook in
18 the Dean's Office, but it's my understanding
19 that it had not been produced at all in 2013
20 to 2014 and that this policy here that she's
21 citing 2012 to 2013 was the only policy in
22 effect in the following academic year.
23 Now, are you sure that there's a

78
1 handbook --
2 A. No, I'm not sure.
3 Q. Okay.
4 A. There was a point at which we stopped
5 printing paper student handbooks. Off the top
6 of my head that could either be 2012-2013 or
7 2013-2014.
8 When you asked me earlier about that,
9 I gave you the answer that I thought was
10 correct. So if it was printed as a paper
11 handbook, then we would have retained copies
12 of the paper handbook. If it was an
13 electronic-only policy, then it is the
14 electronic-only policy that went into effect
15 at whatever date the specific policy in
16 question went into effect. And so if there
17 was a copy paper, we have paper copies on
18 hand. If it was electronic, then it is
19 effective as of whatever the date that is
20 stated in the particular policy is.
21 Q. Okay.
22 MS. ROSSI: All right we'll
23 mark that as 166.

79
2 Q. (By Ms. Rossi) Now, I'm going to
3 show you again Exhibit 144 from Aaron Gordon's
4 deposition and if you'll just indulge me,
5 these are just a couple of questions about
6 these documents that were produced after I
7 deposed you the first time and I haven't had a
8 chance to ask you so.
9 MR. LAPP: That's fine. We
10 had agreed that you could continue her --
11 finish up her personal deposition on these
12 issues.
13 MS. ROSSI: Okay. Thank you.
14 Q. (By Ms. Rossi) Were these slides
15 included in the training materials that were
16 used in the refresher training that the panel
17 got in this case do you know?
18 A. So looking only at the document that
19 is in front of me, I can't tell if this came
20 only from the initial panel training or if it
21 came from the refresher training.
22 What I can say is that what I have
23 here that's marked as Exhibit 144 --

80
1 Q. Mm-hmm.
2 A. -- is the slide which copies the
3 definitions of sexual assault and
4 nonconsensual sexual intercourse and
5 nonconsensual sexual contact. That is the
6 only thing that would have been provided to
7 the panel. The notes underneath would not
8 have been provided to a panel in any form.
9 So even when I provided the slides
10 from the training to the panel, it would not
11 have included the presenter notes. It would
12 have only been the slide itself.
13 So this is not -- the documents that
14 you have were I believe what I provided as my
15 panel training. But even though you may have
16 deposed Aaron Gordon with it, he would not
17 have been provided with these trainer notes.
18 Q. Okay. And do you know if the
19 panelists received -- and I believe that I was
20 told that they did not receive any material
21 like refresher training material in writing.
22 Do you know if they had any refresher material
23 in writing?
81
1 A. They would not have had refresher
2 material in writing. It would have been
3 slides only.
4 Q. Okay. So slides up --
5 A. Slides up on a -- I'm pointing -- at
6 a large HDMI screen. (Indicating)
7 Q. I'm going to show you this email
8 dated February 20th. So it says here that --
9 and this is an email from Attorney Lapp to me
10 and co-counsel.
11 The refresher trainings for
12 individual panelists did not include any new
13 or different materials. Instead, the
14 refresher trainings involved excerpts from the
15 training materials just described.
16 A. Mm-hmm.
17 Q. Do you know -- would you happen to
18 know what would have been included in those
19 excerpts, like which particular slides they
20 might have had in front of them?
21 A. Sure. So what they would have had in
22 front of them would have been the Code of
23 Conduct language --
82
1 Q. Like this slide or?
2 A. -- and standards of evidence and, I
3 mean, I can go back and look at it but not --
4 not all of those -- those slides would not
5 have been -- that's educational. That would
6 not have been included.
7 It would have been about
8 preponderance -- there are slides about
9 preponderance of the evidence. There are
10 slides about referring people to what -- how
11 -- how to look at the Code of Conduct that
12 they're provided on the documents but.
13 Q. Okay.
14 A. And at the time we were talking about
15 sanctioning with them, so how to think about
16 the role of sanctioning. Those would have
17 been the slides. It's not the -- all of the
18 training slides in their entirety.
19 Q. Okay.
20 MS. ROSSI: Can we mark this
21 as 167?
22 And, Attorney Lapp, is it possible
23 that we can find those refresher training

83
1 slides? I mean for mean supplemental
2 production.
3 MR. LAPP: I'll be happy to
4 talk to you about that.
6 Q. (By Ms. Rossi) In a he-said/she-said
7 sexual misconduct allegation, without any
8 evidence other than one person's word versus
9 the other, how would the accused student be
10 able to prove that the sexual encounter is
11 consensual under the College's policy?
14 THE WITNESS: So if I
15 understand correctly, what you're asking is in
16 a case where the evidence rests primarily on
17 the narrative testimony of the complainant and
18 the respondent, then the respondent would
19 need -- and I imagine would be asked by the
20 investigator -- could you describe the points
21 at which you sought or understood that you had
22 consent for each of the sexual behaviors that
23 unfolded between you? How did you seek or

84
1 understand that you had consent from your
2 partner? Those would be the things that I
3 would imagine a respondent would elucidate in
4 those moments and say here were the words that
5 took place between us, here was the conduct
6 that took place between us, here were the
7 parameters that I understood the sexual
8 encounter was going to move forward on. This
9 is how I communicated with my partner or
10 partners about that.
11 Q. And what about if the accuser's
12 statements are contradictory; how do you
13 explain those kinds of issues?
14 MR. LAPP: Objection. I'm
15 also --
16 MS. ROSSI: Yeah, no.
17 MR. LAPP: -- I'm quite
18 concerned that we are beyond the scope of this
19 deposition.
20 MS. ROSSI: We are a little
21 beyond. It's okay. We're good.
22 MR. LAPP: Okay. Good.
23 MS. ROSSI: We're good.

85
1 MR. LAPP: Thank you.
2 MS. ROSSI: Okay.
3 (The deposition concluded.)
4 *****
10
11
12
13
14
15
16
17
18
19
20
21
22
23
86
1 STATE OF MASSACHUSETTS
2 COUNTY OF HAMPDEN
3 I, Kathleen M. Houghton, a Notary Public

within and for the Commonwealth of
4 Massachusetts at large, do hereby certify that
I took the deposition of MEAGAN BOSSONG,
5 pursuant to the Federal Rules of Civil
Procedure on May 15, 2018, at Williams
6 College, Hopkins Hall, Room 203, Williamstown,
Massachusetts.
7
I further certify that the above named
8 deponent was by me first duly sworn to testify
to the truth, the whole truth and nothing but
9 the truth concerning her knowledge in the
matter of the case of JOHN DOE vs. WILLIAMS
10 COLLEGE, now pending in the United States
District Court District of Massachusetts,
11 Western Section.
12 I further certify that the within

testimony was taken by me stenographically and
13 reduced to typewritten form under my direction
by means of COMPUTER-AIDED TRANSCRIPTION; and,
14 I further certify that said deposition is a
true record of the testimony given by said
15 witness.
16 I further certify that I am neither

attorney or counsel for, related to or
17 employed by any of the parties to this action
in which this deposition was taken; any
18 attorney or counsel employed by the parties
hereto, nor financially or otherwise
19 interested in the outcome of the action.
20 Witness my hand and seal this 4th day of

June 2018.
21
___________________
22 Kathleen M. Houghton
Notary Public
23 My Commission Expires
April 3, 2020.
87
1 SIGNATURE PAGE - ERRATA SHEET
2 To be signed by deponent and returned to

counsel within thirty (30) days.
3
4 I, the undersigned, MEAGAN BOSSONG, do hereby

certify that I have read the foregoing
5 transcript of my testimony given in the matter
of JOHN DOE VS. WILLIAMS COLLEGE on
6 May 15, 2018 and that to the best of my
knowledge, said transcript is true and
7 accurate with the exception of the following
corrections listed below:
8
Page: Line:
9 _________________________________________
10 _________________________________________
11 _________________________________________
12 _________________________________________
13 _________________________________________
14 _________________________________________
15 _________________________________________
16 _________________________________________
17 _________________________________________
18 _________________________________________
19 _________________________________________
20 _________________________________________
21 DEPONENT'S
SIGNATURE:____________________DATE______
22
23 kmh
88
June 4, 2018
Daryl J. Lapp, Esquire

Locke Lord LLP
111 Huntington Avenue
Boston, Massachusetts 02199
RE: JOHN DOE VS. WILLIAMS COLLEGE
Dear Attorney Lapp,
Attached is the Signature Page-Errata

Sheet for the continued deposition of MEAGAN
BOSSONG taken on May 15, 2018 in the
above-captioned case.
Please note that according to the Rules

of Civil Procedure, the deponent has thirty
(30) days in which to make these corrections
on the transcript.
When the deponent has signed and noted

her corrections on the Signature Page -
Errata Sheet indicating the page number, line
number, and the desired correction, please
retain a copy and provide the original to
Attorney Rossi.
Thank you for your cooperation.
Very truly yours,
Kathleen M. Houghton
cc: S.E. Rossi, Esquire

enc.
' 149 [3] - 3:9, 22:11, 76:7, 76:10, 77:3, 50 [1] - 17:9 active [4] - 62:1, 1
22:12 77:9, 77:15, 77:17, 511844 [1] - 47:18 68:22, 69:4, 75:23
15 [4] - 1:13, 86:5, 77:20 5th [1] - 43:21 Active [1] - 7:7
'14 [1] - 50:1 87:6, 88:9 2014-15 [1] - 40:3 activity [4] - 15:15,
'14-'15 [5] - 39:15, 150 [3] - 3:10, 23:12, 2014-2015 [4] - 12:9, 6 48:18, 55:17, 68:23
48:9, 54:17, 54:18, 23:13 26:12, 32:20, 37:3 actual [3] - 25:4,
70:4 151 [3] - 3:11, 24:8, 2014.pdf [1] - 31:18 57:14, 57:17
'15-'16 [3] - 26:13, 24:9 2015 [12] - 32:10, 37:1, 617 [1] - 2:11 add [4] - 10:11, 14:22,
39:15, 54:21 152 [5] - 3:12, 27:13, 43:2, 43:14, 45:14, 6:55 [1] - 31:11 31:13, 70:23
27:14, 30:22, 52:23 46:13, 54:16, 54:19, added [8] - 14:6,
0 153 [3] - 3:13, 31:20, 54:20, 70:2, 70:15, 7 14:18, 15:1, 15:2,
31:21 71:3 15:11, 15:17, 65:13,
154 [10] - 3:14, 33:10, 2015-2016 [1] - 37:4 77 [1] - 39:6 72:9
02199 [2] - 2:9, 88:5
33:11, 34:13, 45:6, 2018 [6] - 1:13, 86:5, 78 [2] - 27:5, 54:23 adding [3] - 14:10,
47:5, 49:12, 50:14, 86:20, 87:6, 88:2, 16:16, 55:11
1 50:22, 52:20 88:9
79 [1] - 3:19
addition [3] - 12:4,
155 [3] - 3:15, 37:7, 2020 [1] - 86:23 21:10, 72:7
10/9/15 [1] - 3:17 37:8 203 [2] - 1:13, 86:6
8 additional [2] - 46:4,
10076 [1] - 3:16 156 [3] - 3:16, 41:7, 20th [1] - 81:8 46:6
111 [2] - 2:8, 88:5 41:8 22 [1] - 3:9 8 [1] - 3:7 addresses [1] - 34:17
11130 [1] - 3:19 16-CV-30184 [1] - 1:4 23 [1] - 3:10 83 [1] - 3:20 Adkins [1] - 11:2
11132 [1] - 3:19 164 [3] - 3:17, 43:3, 239-0174 [1] - 2:11 880 [1] - 1:13 Administration [1] -
11204 [1] - 3:11 43:4 24 [1] - 3:11 11:11
1130 [1] - 77:12 165 [3] - 3:18, 45:3, 24/7 [1] - 6:23 A adoption [1] - 17:16
11843 [2] - 3:14, 31:23 45:4 248-7622 [1] - 2:5 Advisors [2] - 34:8,
11844 [4] - 3:14, 166 [3] - 3:19, 78:23, 25th [3] - 25:7, 26:16, 35:2
79:1 Aaron [2] - 79:3, 80:16
31:23, 37:11, 54:3 54:6 advisory [1] - 42:1
167 [3] - 3:20, 82:21, able [3] - 63:17, 65:1,
11845 [3] - 3:18, 27 [1] - 3:12 Advisory [2] - 34:9,
83:5 83:10
43:17, 43:22 35:1
above-captioned [1] -
11849 [2] - 3:18, 43:18 1:00 [1] - 1:14 3 88:10
Advocacy [1] - 35:10
11852 [2] - 3:15, 36:19 affective [1] - 73:14
Abraham [3] - 32:6,
11853 [1] - 36:19 2 3 [2] - 14:17, 86:23 32:9, 52:15
affirmatively [3] -
11854 [1] - 36:19 15:14, 15:23, 17:2
30 [2] - 87:2, 88:12 Abraham-Raveson [2]
11855 [2] - 3:15, 36:19 afternoon [1] - 5:7
2 [3] - 1:18, 41:10, 30(b)(6 [2] - 5:16, - 32:9, 52:15
11868 [3] - 3:9, 20:20, afterwards [1] - 77:10
41:12 25:10 absence [4] - 15:14,
21:5 agree [6] - 38:5,
2/20/18 [1] - 3:20 30th [1] - 31:10 16:8, 16:11, 51:17
11870 [2] - 3:9, 21:5 62:18, 72:18, 73:1,
20 [1] - 3:8 31 [1] - 3:13 absent [1] - 60:21
11871 [2] - 3:9, 21:5 73:9, 73:11
2000 [1] - 51:1 33 [1] - 3:14 academic [7] - 6:4,
11872 [2] - 3:9, 21:6 agreed [5] - 4:3, 4:9,
2011 [1] - 11:19 37 [1] - 3:15 6:11, 54:17, 54:18,
11963 [2] - 3:7, 8:3 4:15, 4:18, 79:10
2012 [2] - 77:14, 77:21 54:21, 70:4, 77:22
11983 [2] - 3:11, 23:16 agreement [3] - 38:2,
12004 [1] - 23:16
2012-2013 [1] - 78:6 4 accepted [1] - 63:18
52:5, 66:19
2013 [5] - 6:4, 77:14, accommodations [1]
12025 [4] - 3:12, ah-ha [2] - 26:20, 59:2
77:17, 77:19, 77:21 - 8:1
24:11, 24:17, 53:17 4 [1] - 88:2 ahead [1] - 59:3
2013-2014 [4] - 17:13, according [1] - 88:11
12042 [7] - 3:12, 41 [1] - 3:16 AIDED [1] - 86:13
17:14, 29:20, 78:7 accurate [2] - 54:5,
24:11, 25:1, 53:14, 413 [1] - 2:5 align [1] - 20:4
2014 [56] - 6:4, 8:9, 87:7
53:15, 54:1, 54:14 43 [1] - 3:17 all-campus [2] - 42:4,
10:9, 11:20, 17:19, accurately [1] - 55:7
12048 [3] - 3:13, 31:7, 442 [1] - 2:3 42:15
17:23, 18:7, 18:15, accused [1] - 83:9
31:9 45 [1] - 3:18 all-student [1] - 3:17
18:20, 19:5, 19:7, accuser's [1] - 84:11
12051 [2] - 3:13, 31:7 46 [7] - 46:23, 47:4, allegation [1] - 83:7
19:12, 19:14, 23:1, acronym [1] - 35:7
12073 [2] - 3:16, 39:5 47:16, 49:12, 50:13, allegations [1] - 17:15
23:2, 23:22, 25:7, acronyms [1] - 6:15
12074 [2] - 3:16, 39:5 50:22, 52:21 almost [1] - 45:20
26:3, 26:11, 26:21, act [3] - 62:14, 62:16,
12076 [1] - 39:6 48 [6] - 48:12, 49:13, alone [1] - 68:7
26:22, 27:18, 27:23, 63:11
12081 [2] - 3:8, 13:10 50:2, 50:18, 55:7, altogether [1] - 67:4
31:11, 39:12, 40:2, Act [3] - 7:11, 8:14
12083 [2] - 3:8, 13:10 41:17, 42:14, 43:9, 56:10 Alumni [2] - 28:7,
acting [1] - 74:15
12090 [1] - 2:3 48:5, 48:9, 48:14, 4th [1] - 86:20 28:20
action [6] - 58:8,
144 [4] - 67:14, 69:6, 48:20, 49:23, 53:2, alumni [3] - 28:14,
59:22, 61:5, 61:22,
28:17, 28:20
79:3, 79:23 54:6, 54:15, 55:6, 5 86:17, 86:19
147 [3] - 3:7, 8:4, 8:5 55:11, 65:14, 66:3, amend [1] - 43:6
actions [2] - 57:23,
148 [3] - 3:8, 20:17, 66:5, 69:3, 71:15, amendments [2] -
5 [1] - 3:3 58:2
20:18 74:14, 75:6, 75:10, 8:14, 34:1
Amendments [5] - 24:15, 24:18, 25:4, 10:18, 14:1, 29:8, 35:14, 43:23, 44:17, college [4] - 34:1, 2
10:3, 10:13, 11:21, 31:17, 31:23, 53:12, 29:17, 31:9, 42:4, 48:15, 52:7, 54:19, 34:2, 45:23, 58:4
13:3, 21:12 53:20 42:16, 74:14, 76:14 55:5, 55:10, 70:1, College [20] - 1:12,
Annual [2] - 7:9, 13:5 attendance [1] - 36:12 Bossong [2] - 5:7, 71:5 2:10, 5:18, 26:6,
answer [7] - 17:2, attention [1] - 14:15 5:10 children [1] - 28:18 28:16, 28:18, 29:16,
19:21, 25:15, 25:17, Attorney [4] - 81:9, BOSSONG [6] - 1:11, choosing [1] - 50:3 30:4, 34:7, 35:3,
43:6, 61:19, 78:9 82:22, 88:7, 88:16 3:3, 5:1, 86:4, 87:4, chronicles [1] - 55:2 48:16, 50:12, 55:16,
answered [2] - 16:18, attorney [2] - 86:16, 88:9 circulating [1] - 52:17 57:14, 57:18, 63:20,
54:11 86:18 Boston [2] - 2:9, 88:5 circumstances [1] - 69:23, 72:11, 75:5,
answers [2] - 4:11, August [1] - 43:21 Box [1] - 2:3 60:16 86:6
5:18 author [1] - 35:12 Boyer [2] - 23:18, cited [1] - 50:2 College's [14] - 10:7,
appear [2] - 40:11, automatically [1] - 23:19 citing [1] - 77:21 17:14, 17:16, 22:20,
69:2 46:4 break [1] - 25:22 Civil [3] - 1:12, 86:5, 23:19, 25:3, 28:21,
APPEARANCES [2] - Avenue [2] - 2:8, 88:5 Brief [1] - 37:9 88:11 30:16, 32:21, 56:18,
1:17, 2:1 avoid [1] - 39:15 bring [2] - 12:13, clarification [5] - 9:6, 74:6, 75:9, 75:21,
appeared [2] - 39:11, aware [1] - 50:4 62:15 15:3, 15:7, 19:23, 83:11
57:5 Awareness [3] - 7:4, bringing [1] - 21:10 72:13 colleges [2] - 7:10,
applies [1] - 17:15 12:10, 32:12 Buell [3] - 14:2, 21:16, clarifications [2] - 12:4
approval [6] - 38:1, 76:15 18:20, 76:23 comfortable [2] -
46:17, 51:4, 52:5, B buzz [2] - 22:5, 22:7 clarified [1] - 76:11 19:2, 19:4
56:2, 66:18 BY [3] - 2:4, 2:10, 5:6 clarifying [1] - 20:12 coming [1] - 76:12
April [3] - 76:7, 76:9, clarity [1] - 72:17 commence [1] - 36:23
B-O-S-S-O-N-G [1] -
86:23
5:11
C Class [1] - 32:10 commencing [1] -
argue [1] - 63:17 clause [1] - 64:11 1:14
argument [1] - 67:12 ballot [1] - 34:5 comment [1] - 14:10
clear [10] - 19:17,
articulate [2] - 27:23, balloting [1] - 35:21 Camacho [3] - 74:11, comments [1] - 19:6
20:2, 20:7, 40:11,
66:16 based [3] - 11:17, 74:13, 74:17 Commission [1] -
48:2, 52:9, 54:12,
articulated [3] - 10:10, 26:20, 38:1 Campus [1] - 7:11 86:23
56:4, 63:20, 65:11
72:1, 74:2 basis [1] - 74:23 campus [4] - 6:20, Committee [8] - 7:15,
clearly [19] - 15:11,
ASR [2] - 7:8, 7:9 Bates [3] - 32:1, 32:2, 8:12, 42:4, 42:15 7:17, 22:16, 22:19,
16:12, 40:8, 41:2,
assault [4] - 11:14, 53:9 campuses [2] - 28:14, 46:16, 46:17, 51:3, 22:22, 23:3, 23:7,
13:13, 31:3, 80:3 became [1] - 74:17 45:23 51:11, 51:17, 52:4, 74:19
Assault [15] - 6:18, become [3] - 28:20, cannot [6] - 13:13, 56:1, 56:6, 56:8, Commonwealth [1] -
6:22, 7:3, 12:9, 70:6, 74:13 26:15, 38:7, 52:13, 56:14, 56:21, 68:22, 86:3
12:22, 17:17, 17:22, began [1] - 40:3 63:21, 64:2 69:2 communicate [4] -
18:14, 19:10, 19:16, beginning [1] - 76:13 capacity [1] - 42:1 Clery [8] - 7:11, 8:14, 37:15, 38:15, 61:11,
30:2, 32:11, 34:22, behalf [1] - 5:18 capital [2] - 35:5, 35:6 10:4, 10:14, 11:21, 72:4
35:8, 41:23 behave [1] - 62:14 captioned [1] - 88:10 13:3, 20:4, 21:12 communicated [10] -
assistant [3] - 11:3, behavior [3] - 61:22, captured [1] - 33:3 click [1] - 31:15 8:17, 16:12, 38:7,
21:17, 29:2 63:11, 64:1 carrying [1] - 63:12 close [1] - 26:17 40:8, 41:3, 41:17,
assisting [1] - 22:23 behaviors [1] - 83:22 case [13] - 12:3, 27:1, co [1] - 81:10 41:20, 57:23, 74:1,
associate [2] - 21:14, below [2] - 31:16, 87:7 27:4, 35:6, 38:20, co-counsel [1] - 81:10 84:9
23:5 berkshirelegal@ 64:9, 64:17, 72:3, coalescing [1] - 13:6 communicating [3] -
Associate [1] - 21:23 gmail.com [1] - 2:5 79:17, 83:16, 86:9, Coalition [1] - 35:5 37:21, 58:9, 61:5
assume [2] - 25:9, best [3] - 8:1, 33:3, 88:10 Code [19] - 6:9, 15:16, communication [1] -
45:16 87:6 cc [1] - 88:22 17:13, 17:14, 26:9, 39:15
assuming [2] - 24:15, better [4] - 20:4, Center [3] - 11:3, 11:5, 30:15, 31:4, 48:16, communications [2] -
54:4 28:21, 40:4, 68:9 30:4 49:21, 50:20, 55:16, 8:21, 8:22
at-large [2] - 33:19, between [12] - 4:3, certainly [1] - 39:12 59:6, 59:11, 66:22, community [8] - 15:8,
35:11 4:9, 4:18, 8:8, 26:10, certainty [1] - 15:7 68:21, 69:16, 69:20, 29:23, 33:4, 33:5,
Athlete [2] - 34:8, 35:1 39:16, 50:1, 61:13, certify [6] - 86:4, 86:7, 81:22, 82:11 34:1, 34:2, 41:18,
attach [1] - 21:1 62:3, 83:23, 84:5, 86:12, 86:14, 86:16, coerced [1] - 38:21 42:5
Attached [1] - 88:8 84:6 87:4 coercion [2] - 66:19, Community [7] - 3:10,
attached [15] - 22:2, beyond [2] - 84:18, chain [1] - 9:12 68:10 22:15, 22:16, 22:19,
23:17, 24:4, 24:12, 84:21 chair [2] - 62:4, 62:8 Colleague [1] - 11:20 22:23, 23:4, 23:7
24:23, 31:16, 33:21, bit [1] - 59:22 chance [1] - 79:8 collection [1] - 28:10 compare [3] - 47:1,
39:4, 43:19, 44:3, board [4] - 22:6, 22:8, change [4] - 26:17, Collective [7] - 7:12, 47:13, 53:13
53:3, 53:9, 53:12, 28:19, 29:3 41:16, 77:6, 77:7 7:13, 32:14, 32:17, compared [2] - 47:5,
53:16, 54:5 body [1] - 32:22 changed [2] - 41:19, 35:4, 35:22, 36:7 47:16
attachment [10] - Bolton [14] - 8:9, 9:7, 71:20 COLLEGE [4] - 1:7, compelled [2] - 38:21,
20:23, 21:3, 24:13, 9:14, 9:20, 10:5, changes [11] - 33:13, 86:10, 87:5, 88:6 68:8
compile [2] - 25:9, 40:7, 45:11, 45:13, 70:18, 70:20, 74:21 DARYL [1] - 2:10 21:16, 76:15 3
25:19 45:18, 45:19, 45:23, convey [3] - 65:10, Daryl [1] - 88:4 deponent [5] - 4:15,
compiled [1] - 25:14 46:5, 47:14, 47:17, 68:13, 68:15 daryl.lapp@ 86:8, 87:2, 88:11,
complainant [1] - 48:17, 49:1, 51:2, conveying [5] - 28:9, lockelord.com [1] - 88:13
83:17 51:16, 54:8, 55:2, 59:23, 62:16, 74:4 2:11 Deponent [1] - 5:1
complete [2] - 31:14, 55:13, 55:17, 57:23, cooperation [1] - date [10] - 8:23, 18:8, DEPONENT'S [1] -
71:18 58:1, 58:9, 60:10, 88:17 26:16, 26:17, 26:19, 87:21
completely [1] - 64:18 63:21, 64:7, 64:11, coordinator [4] - 74:7, 27:20, 30:9, 30:13, deposed [2] - 79:7,
compliance [10] - 64:19, 64:21, 65:10, 74:11, 74:15, 74:17 78:15, 78:19 80:16
8:13, 10:3, 10:13, 65:17, 66:10, 66:12, coordinators [1] - dated [2] - 40:19, 81:8 DEPOSITION [1] -
10:16, 11:19, 13:2, 66:16, 67:16, 68:14, 14:4 dates [2] - 13:14, 17:4 1:11
13:7, 20:4, 21:11, 68:15, 68:23, 69:9, copied [6] - 23:8, dating [3] - 10:1, deposition [20] - 4:16,
33:4 71:1, 71:11, 72:4, 46:11, 46:14, 49:3, 10:10, 10:12 4:20, 5:17, 5:21,
COMPUTER [1] - 72:19, 72:21, 73:2, 54:2, 56:15 David [2] - 23:18 17:9, 25:11, 41:14,
86:13 73:4, 73:20, 73:21, copies [4] - 77:13, Davis [1] - 11:3 41:15, 46:23, 48:13,
COMPUTER-AIDED 73:23, 74:4, 75:7, 78:11, 78:17, 80:2 days [2] - 87:2, 88:12 55:1, 67:14, 79:4,
[1] - 86:13 75:10, 75:13, 75:16, copy [5] - 6:3, 6:7, deaf [1] - 38:14 79:11, 84:19, 85:3,
concerned [1] - 84:18 75:19, 75:20, 75:22, 77:17, 78:17, 88:15 Dean [8] - 9:7, 9:20, 86:4, 86:14, 86:17,
concerning [1] - 86:9 76:18, 77:9, 77:10, copying [3] - 52:15, 10:18, 25:2, 30:16, 88:9
Concerns [3] - 7:16, 83:22, 84:1 55:18, 55:22 54:23, 66:5, 77:13 describe [5] - 8:6,
7:18, 74:19 Consent [4] - 34:23, core [2] - 61:1, 66:17 dean [5] - 21:15, 13:11, 31:7, 45:20,
concerns [1] - 7:20 52:2, 65:8, 68:6 correct [39] - 6:2, 21:16, 21:17, 23:5, 83:20
concluded [1] - 85:3 consenting [1] - 38:23 9:10, 9:19, 10:17, 30:15 described [1] - 81:15
Conduct [19] - 6:9, consists [1] - 33:17 14:5, 16:9, 16:21, Dean's [6] - 6:4, describing [1] - 15:21
15:16, 17:14, 17:15, constituent [1] - 34:7 17:20, 18:13, 19:12, 30:12, 39:11, 52:23, DESCRIPTION [1] -
26:9, 30:15, 31:4, constituents [2] - 23:16, 24:12, 26:1, 54:14, 77:18 3:6
48:17, 49:21, 50:20, 34:10, 70:8 27:16, 29:18, 30:20, dean's [1] - 30:13 design [1] - 75:17
55:16, 59:7, 59:12, constitute [2] - 64:21, 30:23, 31:5, 33:14, dean.williams.edu [2] desired [1] - 88:15
66:22, 68:21, 69:16, 68:10 33:16, 39:20, 39:21, - 26:8, 30:19 detailing [1] - 8:10
69:20, 81:23, 82:11 constitutes [1] - 66:10 40:9, 43:20, 44:6, deans [1] - 41:22 determination [1] -
conduct [31] - 16:12, construe [2] - 72:21, 44:7, 46:15, 48:5, Dear [2] - 11:19, 88:7 61:2
38:7, 38:19, 38:22, 73:3 49:14, 51:1, 51:18, debating [1] - 67:7 determine [2] - 59:9,
40:13, 51:2, 51:3, construed [2] - 41:4, 53:1, 53:21, 61:7, decided [1] - 70:23 60:5
61:13, 61:16, 61:17, 73:22 66:11, 71:13, 76:23, decision [6] - 14:21, dictionary [1] - 64:2
61:20, 61:22, 61:23, consultation [1] - 11:4 77:1, 78:10 35:20, 71:7, 71:21, differ [1] - 18:21
62:3, 62:8, 62:11, contact [3] - 66:20, correction [1] - 88:15 72:10, 72:14 different [14] - 27:6,
62:18, 62:21, 62:22, 67:17, 80:5 corrections [3] - 87:7, decision-making [5] - 42:10, 48:22, 49:3,
63:19, 64:3, 64:5, content [1] - 22:9 88:12, 88:14 35:20, 71:7, 71:21, 49:8, 49:13, 50:4,
64:10, 66:18, 67:5, context [6] - 9:22, correctly [2] - 29:13, 72:10, 72:14 50:18, 51:8, 51:10,
67:9, 67:10, 67:18, 24:22, 26:19, 61:6, 83:15 declarative [1] - 65:7 73:18, 77:8, 77:9,
68:6, 68:15, 84:5 61:12, 68:14 Council [4] - 34:7, Defendant [2] - 1:8, 81:13
conducting [1] - 63:2 contexts [1] - 60:5 34:9, 35:1, 35:3 2:9 differently [1] - 51:10
confidential [2] - 6:23, continuation [1] - counsel [5] - 11:7, define [1] - 61:20 differs [2] - 16:22,
7:21 70:5 81:10, 86:16, 86:18, defined [4] - 31:3, 18:10
confirm [1] - 24:5 continue [1] - 79:10 87:2 51:9, 62:20, 66:12 DIRECT [2] - 3:2, 5:6
confused [1] - 40:6 continued [2] - 37:4, COUNTY [1] - 86:2 defines [1] - 63:9 direction [1] - 86:13
conjunction [1] - 88:9 couple [2] - 53:10, defining [1] - 63:19 director [2] - 11:3,
26:14 CONTINUED [1] - 1:11 79:5 definition [13] - 48:23, 21:13
consecutive [1] - contraception [1] - course [2] - 39:14, 49:22, 51:16, 51:22, disability [1] - 38:11
53:10 30:11 60:17 54:7, 54:13, 55:2, disability-inclusive
consensual [4] - 60:7, contradictory [1] - COURT [1] - 1:1 55:13, 62:11, 62:17, [1] - 38:11
60:10, 60:23, 83:11 84:12 Court [2] - 1:22, 86:10 63:12, 67:16, 73:19 discrimination [1] -
consensus [5] - controlled [1] - 62:15 created [1] - 57:9 definitional [2] - 22:20
35:19, 71:6, 71:21, conversation [14] - creating [1] - 11:13 44:15, 44:21 discuss [1] - 12:13
72:10, 72:14 8:7, 8:8, 15:4, 24:20, CROSS [1] - 3:2 definitions [3] - 30:3, discussed [8] - 9:9,
consent [77] - 15:4, 28:13, 37:2, 37:17, current [1] - 29:16 62:23, 80:3 9:18, 9:19, 10:6,
15:5, 15:8, 15:15, 38:8, 38:16, 39:1, Cynthia [1] - 31:10 definitively [4] - 34:5, 35:14, 44:1,
15:19, 15:20, 15:22, 40:2, 70:11, 76:8, 26:15, 52:14, 53:15, 69:1
16:7, 16:13, 16:14, 76:17 D 59:16 discussing [5] -
18:22, 20:6, 30:3, conversations [6] - Denelli [1] - 11:4 10:14, 10:19, 11:12,
37:16, 37:23, 38:6, 13:16, 45:22, 70:5, Denise [3] - 14:2, 21:21, 35:18
Darryl [2] - 11:7, 25:14
discussion [3] - drafts [1] - 39:4 70:19, 77:12, 81:7, 17:9, 20:18, 22:12, financially [1] - 86:184
34:12, 35:13, 74:21 dramatic [1] - 77:5 81:9 23:13, 24:9, 27:5, fine [2] - 24:6, 79:9
Discussion [2] - draw [1] - 14:15 emailing [2] - 29:7, 27:13, 27:14, 30:22, finish [1] - 79:11
25:23, 41:13 driver's [1] - 5:3 29:15 31:20, 31:21, 33:10, FIRM [1] - 2:2
discussions [4] - due [1] - 53:6 emails [1] - 3:11 33:11, 37:8, 41:8, firm [1] - 17:6
35:23, 36:22, 69:18, duly [2] - 5:3, 86:8 embark [1] - 69:23 43:4, 45:4, 45:5, first [9] - 4:6, 4:12,
70:9 duplicative [3] - 72:2, emergency [1] - 30:10 46:22, 47:4, 47:5, 8:16, 9:3, 68:20,
disparate [1] - 33:15 72:8, 72:15 employed [2] - 86:17, 47:16, 48:12, 49:12, 70:13, 74:10, 79:7,
disseminating [1] - during [2] - 60:13, 86:18 49:13, 50:2, 50:13, 86:8
41:4 60:17 employee [1] - 7:23 50:17, 52:20, 52:22, flushing [1] - 46:7
distinction [2] - 68:3, enc [1] - 88:22 54:23, 55:7, 56:10, following [3] - 55:20,
67:14, 69:6, 79:1,
68:18 E encompassed [1] - 77:22, 87:7
District [2] - 86:10 12:15 79:3, 79:23, 83:5 follows [2] - 5:5, 31:4
DISTRICT [2] - 1:1, 1:1 encounter [2] - 83:10, exhibit [1] - 50:11 foregoing [1] - 87:4
Diversity [7] - 3:10, edits [2] - 13:21, 13:23 84:8 EXHIBIT [1] - 3:6 forget [2] - 30:7, 75:4
22:15, 22:16, 22:19, educate [1] - 33:7 endeavoring [1] - 29:3 Exhibits [1] - 50:22 forgot [2] - 20:16,
22:22, 23:4, 23:7 educated [1] - 32:22 Ending [1] - 7:7 exhibits [1] - 53:11 36:16
diversity [2] - 21:15, education [4] - 40:5, engaged [3] - 21:21, existed [1] - 49:23 form [25] - 4:5, 14:9,
23:6 41:5, 46:19 46:2, 61:14 existence [1] - 62:3 18:17, 29:10, 34:16,
Docket [1] - 1:3 educational [5] - 30:3, engaging [4] - 13:16, experienced [1] - 42:2 40:15, 40:20, 50:10,
document [45] - 3:8, 39:16, 39:22, 57:2, 59:20, 62:7, 67:10 Expires [1] - 86:23 51:21, 52:8, 52:10,
3:10, 11:21, 14:7, 82:5 entire [1] - 59:10 explain [2] - 50:5, 56:4, 60:2, 61:17,
14:19, 17:21, 21:5, educator [1] - 11:5 entirety [5] - 11:18, 84:13 62:12, 62:20, 62:21,
21:8, 22:5, 23:17, effect [10] - 17:18, 11:22, 52:3, 66:23, explication [1] - 76:19 63:10, 63:15, 64:13,
24:4, 24:18, 24:23, 17:23, 19:11, 19:14, 82:18 explicit [1] - 75:16 64:23, 65:19, 80:8,
25:1, 25:8, 25:16, 20:8, 23:21, 40:21, entry [1] - 59:19 explicitly [1] - 69:19 83:13, 86:13
25:19, 31:1, 31:16, 77:22, 78:14, 78:16 equal [2] - 60:7, 60:9 expressed [4] - 15:15, formats [1] - 40:4
44:4, 46:20, 48:7, effective [9] - 71:2, 68:23, 69:10, 71:11 formatting [1] - 13:15
equity [1] - 21:15
48:10, 49:4, 49:9, 73:13, 73:14, 73:17, extent [2] - 63:23, forward [2] - 72:1,
ERRATA [1] - 87:1
50:21, 51:8, 53:8, 73:21, 74:3, 75:6, 68:16 84:8
Errata [2] - 88:8, 88:14
53:16, 55:1, 56:6, 75:20, 78:19 extra [1] - 72:7 forwarded [1] - 32:5
especially [1] - 62:15
56:7, 56:11, 56:21, either [1] - 78:6 four [1] - 17:11
Esquire [2] - 88:4,
electronic [3] - 78:13,
57:2, 57:8, 57:9,
78:14, 78:18
88:22 F freely [11] - 38:1, 40:8,
67:21, 68:1, 68:2, ESQUIRE [2] - 2:4, 40:10, 41:2, 46:1,
68:17, 69:8, 69:14, electronic-only [2] - 46:17, 51:3, 51:18,
2:10
71:19, 79:18 78:13, 78:14 fact [6] - 38:22, 59:8,
essentially [2] - 77:2, 52:5, 56:2, 66:18
documents [17] - elements [3] - 5:23, 59:10, 60:18, 69:20,
77:4 Frequently [1] - 39:7
5:23, 6:13, 6:15, 12:14, 65:22 69:21
evidence [4] - 82:2, front [5] - 6:13, 25:18,
25:10, 25:14, 25:18, ELIN [1] - 2:4 facts [2] - 60:21, 61:1
82:9, 83:8, 83:16 79:19, 81:20, 81:22
27:1, 27:3, 32:3, Elin [1] - 5:8 faculty [6] - 21:16,
ex [1] - 23:6 fully [2] - 11:19, 71:23
39:8, 39:9, 56:19, elucidate [1] - 84:3 21:17, 21:18, 44:10,
exact [2] - 11:8, 65:21
57:18, 79:6, 80:13, elucidation [2] - 44:16, 44:23
82:12 72:12, 76:20
exactly [5] - 17:3,
fair [1] - 29:6 G
26:15, 35:16, 40:1,
DOE [4] - 1:5, 86:9, email [62] - 3:7, 3:9, fairly [1] - 13:3
47:2
87:5, 88:6 3:12, 3:13, 3:14, fall [3] - 23:1, 70:10 Gail [4] - 28:8, 29:1,
EXAMINATION [1] -
domain [1] - 30:1 3:15, 3:17, 3:18, Falls [1] - 2:3 29:7, 29:15
5:6
domestic [4] - 10:1, 3:19, 3:20, 8:7, 8:8, FAQ [3] - 11:20, 46:19, gender [1] - 11:17
example [15] - 7:20,
10:10, 10:12, 21:19 9:3, 9:7, 9:11, 9:14, 56:21 gender-based [1] -
14:10, 27:5, 27:10,
done [1] - 50:6 11:23, 21:8, 23:9, far [2] - 50:4, 64:3 11:17
38:14, 38:20, 39:13,
Donna [1] - 11:4 23:15, 23:18, 24:3, February [5] - 46:13, general [1] - 11:6
57:22, 58:1, 58:2,
dotted [3] - 14:13, 24:5, 24:11, 24:13, 54:16, 54:19, 70:15, genitals [9] - 58:3,
58:6, 58:20, 59:13,
14:14 24:14, 24:17, 24:19, 81:8 58:6, 58:8, 58:10,
60:11, 68:8
Draft [1] - 3:8 25:1, 25:5, 25:20, Federal [2] - 1:12, 58:12, 58:15, 58:23,
examples [2] - 44:13,
draft [14] - 13:12, 31:9, 32:5, 34:17, 86:5 59:4
69:9
13:18, 18:1, 18:9, 35:12, 35:15, 42:4, felt [5] - 12:14, 20:3, given [14] - 37:19,
except [2] - 4:4, 40:10
19:1, 19:6, 19:9, 42:7, 42:8, 42:10, 33:3, 37:21, 38:12 38:1, 40:8, 40:11,
exception [1] - 87:7
43:19, 44:2, 44:6, 42:15, 42:20, 43:2, female [1] - 59:21 41:2, 46:17, 51:3,
excerpts [2] - 81:14,
44:8, 44:12, 52:13, 43:9, 43:14, 43:19, Feminist [7] - 7:12, 52:5, 56:2, 60:16,
81:19
52:16 43:21, 52:14, 53:2, 7:13, 32:14, 32:17, 63:12, 66:18, 86:14,
exchanged [1] - 9:4
drafting [3] - 10:18, 53:7, 53:9, 53:16, 35:4, 35:22, 36:7 87:5
53:20, 53:23, 54:3, excuse [1] - 26:22
10:21, 18:3 final [2] - 19:6, 19:13 Gordon [1] - 80:16
54:6, 54:16, 70:13, Exhibit [43] - 8:4, 8:5,
Finance [1] - 11:10 Gordon's [2] - 67:14,
79:3 helping [1] - 69:8 51:3, 51:12, 52:5, Isabel's [1] - 45:7 26:10, 26:11, 26:12, 5
governs [1] - 64:1 hereby [3] - 4:21, 66:18 issue [1] - 33:20 27:4, 27:7, 27:21,
graduated [1] - 32:10 86:4, 87:4 indicates [3] - 9:8, issues [4] - 7:19, 67:7, 33:1, 33:3, 34:10,
granularity [1] - 72:17 hereto [1] - 86:18 35:12, 55:12 79:12, 84:13 37:19, 37:22, 38:11,
great [1] - 42:23 Hess [1] - 11:4 indicating [2] - 16:13, Isy [1] - 52:14 38:12, 38:17, 43:20,
greater [3] - 20:11, highlight [1] - 14:12 88:14 Isy's [1] - 54:15 44:1, 44:3, 44:11,
20:12, 72:17 highlighted [1] - 50:22 Indicating [4] - 25:20, it.. [1] - 29:11 44:15, 45:9, 46:6,
Greylock [1] - 35:9 himself [1] - 63:2 39:18, 49:9, 81:6 italicized [2] - 67:18, 46:12, 46:14, 46:19,
grievance [1] - 22:21 history [1] - 65:3 individual [4] - 44:20, 67:20 46:21, 47:14, 47:20,
group [18] - 7:4, 7:14, hmm [15] - 20:22, 60:20, 67:1, 81:12 italics [1] - 48:15 48:3, 49:6, 49:20,
7:18, 10:20, 12:10, 22:17, 45:15, 47:15, individuals [4] - 42:2, iterations [2] - 20:1, 52:13, 52:16, 53:1,
32:12, 33:14, 33:17, 48:19, 49:7, 55:4, 61:14, 71:7, 76:14 27:6 53:4, 53:14, 53:22,
33:22, 35:8, 36:10, 55:9, 55:14, 55:18, indulge [1] - 79:4 itself [4] - 61:5, 61:10, 54:1, 54:2, 58:4,
36:16, 36:22, 37:12, 62:5, 70:16, 75:8, industry [1] - 45:20 76:20, 80:12 67:22, 71:11, 71:20,
39:2, 45:21, 52:17, 80:1, 81:16 infer [1] - 27:2 IX [11] - 7:15, 7:17, 71:23, 72:7, 72:9,
68:4 Hmm [1] - 63:3 inferred [10] - 63:21, 7:19, 8:2, 14:4, 46:2, 72:13, 72:15, 74:3,
groups [8] - 29:5, hold [2] - 63:7, 69:19 64:5, 64:7, 64:19, 74:6, 74:11, 74:15, 75:17, 76:10, 81:23
33:15, 33:19, 34:7, home [1] - 31:12 71:1, 71:12, 72:19, 74:17, 74:18 Lapp [6] - 11:7, 25:14,
34:14, 34:20, 40:23, Hoosick [1] - 2:3 72:21, 73:2, 73:4 81:9, 82:22, 88:4,
88:7
41:1 Hopkins [2] - 1:13, information [8] - 30:5, J LAPP [53] - 2:10,
guess [1] - 22:15 86:6 30:9, 39:13, 40:4,
guidance [2] - 11:20, Houghton [5] - 1:11, 59:15, 60:4, 61:12, 16:10, 16:17, 16:23,
21:8 65:6 jargon [1] - 45:21 18:16, 19:19, 20:9,
1:22, 86:3, 86:22,
guide [1] - 58:7 initial [2] - 68:19, Jeanne [1] - 7:11 20:14, 21:4, 23:23,
88:20
79:20 Jeff [3] - 11:5, 11:6, 26:23, 27:10, 29:9,
Human [1] - 21:13
14:2 40:14, 42:9, 42:19,
H Huntington [2] - 2:8, initiatives [1] - 34:5
Jere [2] - 28:5, 28:6 43:5, 43:11, 47:3,
88:5 input [1] - 36:21
insofar [1] - 56:4 JOHN [4] - 1:5, 86:9, 48:1, 49:10, 49:15,
hypothetical [5] -
hairs [2] - 62:2, 62:7 87:5, 88:6 49:18, 50:6, 50:9,
58:16, 58:23, 59:19, Instead [1] - 81:13
Haley [1] - 31:10 jointly [1] - 14:1 51:20, 54:10, 56:3,
60:11, 68:13 instead [2] - 28:11,
half [1] - 53:5 Jones [2] - 11:6, 14:2 56:10, 56:13, 56:17,
58:12
Hall [2] - 1:13, 86:6 June [3] - 8:9, 86:20, 57:3, 57:7, 57:11,
HAMPDEN [1] - 86:2
I institutional [2] -
88:2 57:17, 58:14, 60:1,
21:15, 23:5
hand [5] - 58:7, 68:9, Junior [2] - 34:8, 35:2 61:8, 62:19, 63:6,
instructed [1] - 69:19
68:12, 78:18, 86:20 idea [1] - 28:10 Justin [1] - 11:2 63:14, 64:12, 64:22,
integrated [5] - 9:9,
handbook [10] - 6:3, identical [1] - 50:14 65:18, 73:6, 76:1,
9:17, 9:20, 9:22,
79:9, 83:3, 83:12,
6:7, 6:10, 27:22, identified [2] - 5:2, 10:8 K
42:5, 77:14, 77:17, 32:3 84:14, 84:17, 84:22,
integrating [1] - 10:6
78:1, 78:11, 78:12 imagine [3] - 6:8, 85:1
intent [1] - 65:5 Karen [3] - 21:14,
handbooks [1] - 78:5 83:19, 84:3 large [4] - 33:19,
intention [2] - 44:14, 23:8, 76:15
handed [1] - 53:11 imply [2] - 64:10, 35:11, 81:6, 86:4
65:11 Kathleen [5] - 1:11,
handy [1] - 28:10 65:17 larger [2] - 10:20,
interact [2] - 41:21, 1:22, 86:3, 86:22,
happy [1] - 83:3 important [1] - 76:6 60:21
74:5 88:20
harassment/ IN [1] - 35:6 last [2] - 5:13, 6:6
intercourse [4] - Keli [3] - 28:8, 29:1,
misconduct [1] - inaction [1] - 61:16 latest [1] - 28:10
59:21, 60:13, 60:18, 29:6
22:21 include [4] - 61:16, LAW [1] - 2:2
80:4 kind [1] - 77:7
hard [3] - 6:3, 6:7, 63:13, 68:5, 81:12 Leadership [1] - 35:3
interest [1] - 28:15 kinds [2] - 70:7, 84:13
41:12 included [8] - 9:23, leading [1] - 23:1
interested [5] - 6:1, kmh [1] - 87:23
harm [1] - 42:2 13:4, 23:19, 55:11, least [1] - 69:2
28:20, 33:18, 33:20,
hash [1] - 68:4 79:15, 80:11, 81:18, knowledge [2] - 86:9, Lee [1] - 21:16
86:19
Haynes [1] - 77:12 82:6 87:6 legislative [2] - 65:2,
interim [1] - 74:15
HDMI [1] - 81:6 includes [2] - 31:2, knows [1] - 46:4 65:5
intransitive [1] - 62:22
he-said/she-said [1] - 55:15 Leila [2] - 28:5, 28:6
investigator [1] -
83:6 including [1] - 23:21 83:20
L lengthy [2] - 39:1,
head [2] - 59:14, 78:6 inclusive [2] - 38:11, 50:13
involved [11] - 10:21,
health [2] - 11:5, 30:5 38:13 letter [1] - 11:20
10:22, 10:23, 22:23, lack [4] - 37:16, 66:10,
Health [4] - 11:5, 30:4, indecisive [2] - 66:9, license [1] - 5:3
23:4, 47:22, 70:7, 66:12, 72:4
36:15, 36:16 66:13 likewise [1] - 61:3
74:7, 74:11, 74:16, language [64] - 10:11,
help [1] - 68:2 indeed [1] - 54:14 81:14 line [2] - 6:23, 88:14
10:15, 13:2, 13:4,
helped [1] - 33:15 indicate [8] - 38:17, Isabel [3] - 32:6, 32:8, 13:6, 13:7, 16:16, Line [1] - 87:8
helpful [1] - 22:2 38:22, 46:16, 46:17, 32:9 20:3, 20:5, 21:21, lines [1] - 61:4
link [1] - 31:16 [2] - 1:1, 86:1 63:9, 63:18, 64:2 56:3, 56:10, 56:13, nonconsent [3] - 6
list [2] - 12:1, 46:1 Massachusetts [6] - message [2] - 22:6, 56:17, 57:3, 57:7, 59:23, 61:6, 61:11
listed [1] - 87:7 1:13, 2:9, 86:4, 86:6, 22:8 57:11, 57:17, 58:14, noon [1] - 75:4
LLP [2] - 2:8, 88:4 86:10, 88:5 met [1] - 5:13 60:1, 61:8, 62:19, norms [1] - 33:4
local [1] - 30:10 match [1] - 49:5 might [17] - 22:2, 63:6, 63:14, 64:12, Notary [3] - 1:11, 86:3,
located [1] - 39:10 matches [1] - 52:20 34:14, 38:13, 38:14, 64:22, 65:18, 73:6, 86:22
Locke [1] - 88:4 material [4] - 80:20, 38:22, 42:2, 58:7, 76:1, 79:9, 83:3, note [2] - 69:13, 88:11
LOCKE [1] - 2:8 80:21, 80:22, 81:2 60:12, 60:13, 60:17, 83:12, 84:14, 84:17, noted [1] - 88:13
look [24] - 12:4, 12:12, materials [9] - 3:20, 68:5, 68:11, 68:13, 84:22, 85:1 notes [6] - 41:2, 69:7,
17:8, 17:10, 20:20, 29:4, 39:16, 39:17, 68:15, 68:16, 70:9, MS [39] - 5:6, 16:19, 69:21, 80:7, 80:11,
24:3, 24:4, 26:20, 39:22, 41:5, 79:15, 81:20 20:16, 22:10, 23:11, 80:17
32:20, 33:1, 34:13, 81:13, 81:15 MinCo [2] - 35:5, 35:7 24:7, 25:21, 27:8, nothing [1] - 86:8
35:15, 36:20, 39:6, Matt [3] - 11:7, 12:6, mind [1] - 32:2 27:12, 29:12, 31:19, notification [1] - 4:19
42:19, 48:12, 52:2, 76:14 Minority [1] - 35:5 33:9, 37:5, 41:6, noun [1] - 63:10
52:22, 59:10, 66:4, matter [11] - 65:4, minute [1] - 25:22 41:9, 42:22, 45:2, number [9] - 32:1,
76:2, 76:13, 82:3, 65:23, 66:1, 66:8, Misconduct [10] - 47:6, 47:9, 47:12, 37:11, 38:9, 71:7,
82:11 66:9, 66:13, 66:14, 12:22, 17:18, 17:23, 50:8, 56:9, 56:12, 71:22, 73:17, 73:22,
looked [1] - 14:9 71:16, 71:17, 86:9, 18:14, 19:11, 19:17, 56:15, 56:23, 57:5, 88:14, 88:15
looking [24] - 6:12, 87:5 36:23, 49:2, 50:12, 57:10, 57:15, 58:17, numbers [2] - 30:9,
11:9, 11:16, 11:22, Meagan [1] - 5:10 50:15 63:3, 63:7, 76:3, 53:9
12:11, 13:14, 16:3, MEAGAN [7] - 1:11, misconduct [20] - 78:22, 79:13, 82:20,
84:16, 84:20, 84:23,
17:4, 17:21, 18:2, 3:3, 5:1, 5:10, 86:4, 6:10, 9:9, 9:20, 10:1,
85:2
O
24:2, 24:21, 25:4, 87:4, 88:9 11:15, 11:17, 13:13,
26:14, 26:18, 44:4, mean [11] - 16:13, 18:19, 18:22, 21:19, must [2] - 40:8, 57:6
44:5, 45:6, 48:6, 34:16, 35:18, 60:10, 23:20, 26:8, 27:17, object [15] - 18:16,
48:9, 53:19, 57:8, 64:3, 73:13, 73:19, 28:13, 28:17, 29:1, N 29:9, 40:14, 50:7,
76:18, 79:18 73:23, 82:3, 83:1 31:2, 31:18, 45:22, 50:9, 51:20, 56:3,
Lord [1] - 88:4 meaning [2] - 74:1, 83:7 60:1, 62:19, 63:15,
name [3] - 5:7, 5:9, 64:12, 64:22, 65:18,
LORD [1] - 2:8 74:3 misconstrued [1] -
24:17 73:7, 83:12
lost [2] - 47:8, 58:20 meanings [1] - 73:18 39:20
named [1] - 86:7 objection [3] - 48:1,
love [1] - 35:7 means [14] - 15:21, mistaken [2] - 42:17,
narrative [1] - 83:17 54:10, 84:14
lower [1] - 35:6 16:3, 16:9, 46:5, 43:10
national [3] - 7:6, Objection [7] - 16:10,
47:4, 51:2, 55:21, mixing [1] - 62:22
15:4, 28:12 16:17, 16:23, 19:19,
M 66:16, 73:10, 73:21, mode [1] - 63:10
necessarily [1] - 33:21 20:9, 23:23, 61:8
75:19, 77:6, 86:13 model [3] - 8:10, 12:7,
necessity [2] - 37:20, objections [2] - 4:4
meant [5] - 9:23, 35:20
Main [1] - 1:13 38:10 obligation [1] - 37:15
39:19, 50:5, 68:2, modeled [2] - 12:21,
male [1] - 59:20 neck [2] - 68:9, 68:12 obviously [1] - 58:4
76:21 13:1
management [2] - need [7] - 15:2, 24:3, occurred [1] - 37:17
medium [1] - 62:16 moment [1] - 51:7
22:6, 62:13 24:4, 35:15, 52:2, October [38] - 17:18,
meet [2] - 7:18, 8:1 moments [1] - 84:4
manner [2] - 62:15, 59:10, 83:19 17:23, 18:7, 18:15,
meeting [6] - 36:2, Monday [1] - 44:1
63:11 needed [6] - 10:11, 18:20, 19:5, 19:7,
36:5, 36:7, 36:12, month [1] - 36:3
March [1] - 70:14 38:16, 38:17, 46:6, 19:12, 19:14, 26:11,
74:22, 75:4 months [1] - 9:2
mark [16] - 8:4, 20:15, 72:12, 76:19 26:12, 26:17, 26:22,
meetings [8] - 9:2, most [6] - 13:5, 29:15,
20:17, 22:10, 23:11, needs [4] - 8:1, 46:3, 27:17, 31:10, 31:18,
34:6, 37:3, 37:18, 30:12, 45:17, 58:4,
24:7, 27:13, 31:20, 66:22, 71:23 41:17, 42:13, 43:2,
39:2, 41:20, 70:21, 76:9
33:9, 37:6, 41:7, Neighborhood [1] - 43:8, 48:8, 48:14,
70:22 motions [1] - 4:10
43:2, 45:2, 78:23, 35:2 49:23, 50:1, 51:1,
meets [1] - 74:19 move [6] - 16:20,
82:20 Network [5] - 6:19, 54:20, 55:6, 55:11,
member [3] - 23:6, 60:12, 60:14, 60:17,
marked [18] - 8:5, 30:2, 34:22, 35:8, 65:14, 66:5, 69:3,
36:4, 36:6 60:20, 84:8
20:18, 22:12, 23:13, 35:11 71:3, 71:15, 75:6,
members [3] - 23:3, moved [1] - 59:21
24:9, 27:14, 31:21, network [1] - 6:19 75:10, 76:9, 77:3,
32:23, 33:22 movement [1] - 60:22
33:11, 37:6, 37:8, never [2] - 25:19, 32:2 77:14
memory [2] - 17:7, MR [52] - 16:10, 16:17,
41:8, 43:4, 43:22, new [8] - 10:18, 18:19, OF [4] - 1:1, 1:11,
71:18 16:23, 18:16, 19:19,
45:4, 57:21, 79:1, 42:5, 42:6, 42:14, 86:1, 86:2
Men [1] - 34:23 20:9, 20:14, 21:4,
79:23, 83:5 42:17, 72:1, 81:12 Office [6] - 6:5, 11:9,
mentioned [2] - 6:15, 23:23, 26:23, 27:10,
markups [2] - 13:22, New [3] - 2:3, 12:8, 30:12, 39:12, 54:15,
68:3 29:9, 40:14, 42:9,
13:23 22:1 77:18
mentions [1] - 22:4 42:19, 43:5, 43:11,
Martha [3] - 14:3, Ninah [4] - 17:9, officers [1] - 46:2
Merriam [4] - 62:10, 47:3, 48:1, 49:10,
21:12, 76:16 46:23, 50:2, 55:7 officio [1] - 23:6
63:9, 63:18, 64:2 49:15, 49:18, 50:6,
MASC [2] - 34:23, 35:1 nonconsensual [3] - one [17] - 23:18,
Merriam-Webster [3] - 50:9, 51:20, 54:10,
MASSACHUSETTS 60:23, 80:4, 80:5 26:15, 27:10, 32:19,
38:3, 38:6, 49:13, 32:11, 32:13, 36:16, 65:8, 66:21, 68:6 46:8, 46:9, 46:12, prevent [1] - 28:23 7
50:17, 59:13, 60:22, 39:11, 46:20, 50:15, pieces [4] - 12:17, 46:14, 46:20, 47:1, prevention [1] - 46:3
67:6, 68:1, 68:5, 50:18, 50:20, 51:11, 44:21, 68:1, 71:15 47:3, 47:4, 47:14, Prevention [3] - 7:3,
72:20, 73:3, 76:6, 54:20, 62:12, 74:18 pithy [1] - 15:20 47:19, 47:22, 47:23, 12:10, 32:11
83:8 participated [1] - place [13] - 18:18, 48:3, 48:14, 48:23, previous [3] - 6:11,
ones [2] - 28:11, 29:7 69:18 19:5, 26:12, 33:6, 49:1, 49:19, 50:1, 16:22, 19:17
oneself [1] - 62:13 particular [10] - 12:1, 42:10, 46:9, 49:20, 50:19, 51:1, 51:19, previously [2] - 9:8,
ongoing [2] - 37:2, 12:20, 12:23, 14:11, 55:3, 56:16, 56:20, 52:9, 52:10, 54:9, 20:8
70:4 14:15, 33:22, 36:9, 75:6, 84:5, 84:6 54:15, 54:18, 55:6, primarily [1] - 83:16
online [4] - 26:2, 62:14, 78:20, 81:19 placed [1] - 27:21 55:10, 55:21, 56:22, printed [2] - 21:2,
27:16, 27:20, 27:21 parties [11] - 4:3, 4:10, places [3] - 44:18, 57:18, 63:21, 63:23, 78:10
opening [1] - 53:20 4:19, 37:15, 37:21, 50:4, 73:22 64:3, 64:4, 64:11, printing [1] - 78:5
operation [1] - 62:13 38:2, 66:19, 72:3, Plaintiff [2] - 1:5, 2:4 64:17, 65:3, 65:12, printout [1] - 22:14
opposed [1] - 58:9 86:17, 86:18 pleasurable [1] - 65:15, 65:16, 65:22, printouts [1] - 24:2
opposite [1] - 73:10 partner [2] - 84:2, 84:9 60:15 66:2, 67:2, 67:3, privy [1] - 24:20
organization [1] - 7:6 partner's [1] - 58:7 point [6] - 52:6, 66:17, 67:22, 67:23, 69:12, proactive [1] - 28:22
original [4] - 4:20, partners [1] - 84:10 69:11, 74:9, 74:16, 70:1, 70:3, 70:8, Procedure [3] - 1:12,
24:22, 53:7, 88:15 parts [1] - 49:4 78:4 71:2, 71:6, 71:9, 86:5, 88:11
otherwise [1] - 86:18 pass [1] - 8:11 pointing [5] - 42:5, 71:14, 72:1, 72:11,
procedures [2] -
outcome [1] - 86:19 passage [2] - 52:19, 42:6, 42:16, 69:7, 74:7, 74:12, 75:5,
22:21, 23:20
outdated [11] - 28:11, 52:20 81:5 75:7, 75:9, 75:10,
process [5] - 18:3,
29:7, 29:8, 47:23, passive [6] - 61:16, points [2] - 76:16, 75:13, 75:19, 75:21,
35:21, 36:21, 63:11,
48:3, 48:11, 51:16, 62:21, 66:1, 66:10, 83:20 76:2, 76:10, 76:18,
70:1
52:8, 52:10, 54:7, 66:14, 71:17 policies [32] - 9:10, 76:20, 77:7, 77:15,
produce [1] - 42:21
54:13 passively [1] - 62:4 9:21, 10:7, 10:8, 77:20, 77:21, 78:13,
produced [6] - 8:23,
passivity [18] - 62:18, 10:18, 10:21, 11:17, 78:14, 78:15, 78:20,
over-time [1] - 48:7 27:5, 42:8, 70:14,
63:13, 63:22, 64:2, 12:3, 12:12, 12:15, 83:11
own [1] - 33:1 77:19, 79:6
64:6, 64:8, 64:10, 12:18, 15:6, 20:2, position [2] - 59:20,
production [2] - 5:3,
60:13
P 64:19, 64:21, 65:9, 21:18, 23:20, 28:21,
positive [1] - 75:20
83:2
65:17, 66:2, 71:2, 29:8, 29:16, 31:15, project [1] - 32:23
71:12, 72:20, 72:22, 31:18, 32:21, 32:22, positively [1] - 15:23
projects [1] - 32:19
p.m [2] - 1:14, 31:11 73:3, 73:5 33:2, 34:4, 44:17, possible [1] - 82:22
proposed [2] - 33:23,
P.O [1] - 2:3 pasted [1] - 54:2 44:22, 64:20, 65:5, post [3] - 48:14,
34:9
PAGE [2] - 3:6, 87:1 pattern [4] - 59:9, 76:13, 77:3, 77:5 48:20, 50:23
prove [1] - 83:10
page [13] - 15:14, 59:10, 69:20, 69:21 Policy [7] - 36:23, PowerPoint [2] -
provide [5] - 15:6,
17:11, 29:21, 29:23, pdf [2] - 24:18, 31:14 49:2, 50:12, 50:16, 69:13, 69:22
19:22, 40:4, 65:16,
30:7, 30:8, 30:17, peer [1] - 6:19 52:3, 65:8, 68:7 pre [1] - 50:1
88:15
31:12, 47:5, 50:17, pending [1] - 86:10 policy [158] - 8:10, pre-October [1] - 50:1
provided [13] - 5:13,
52:23, 67:15, 88:14 penetrated [1] - 60:19 8:15, 8:17, 8:22, precede [3] - 17:16,
6:16, 18:20, 23:15,
Page [4] - 1:18, 87:8, people [19] - 7:1, 9:3, 9:17, 9:23, 10:11, 18:7, 54:19
25:8, 39:8, 69:15,
88:8, 88:14 10:21, 20:12, 30:6, 10:15, 11:22, 12:7, preceded [2] - 18:10,
80:6, 80:8, 80:9,
Page-Errata [1] - 88:8 41:21, 41:23, 42:16, 12:11, 12:16, 13:6, 71:15
80:14, 80:17, 82:12
pages [3] - 13:11, 45:21, 46:2, 47:21, 15:4, 15:9, 15:22, precedes [1] - 44:12
provides [1] - 20:11
21:2, 28:11 68:2, 69:8, 69:15, 16:2, 16:4, 16:7, preceding [1] - 26:11
providing [1] - 5:18
panel [9] - 59:9, 61:1, 70:6, 70:11, 71:21, 16:16, 16:22, 17:5, prepare [1] - 5:20
Public [3] - 1:12, 86:3,
69:18, 79:16, 79:20, 71:22, 82:10 18:9, 18:15, 18:19, preponderance [2] - 86:22
80:7, 80:8, 80:10, periodically [1] - 11:6 18:23, 19:3, 19:4, 82:8, 82:9
publish [1] - 7:10
80:15 person [9] - 58:6, 19:15, 19:18, 20:7, presence [1] - 15:23
published [2] - 6:8,
panel's [1] - 68:19 58:11, 58:14, 58:15, 20:8, 21:11, 21:21, present [7] - 15:22, 19:2
panelists [2] - 80:19, 58:17, 59:3, 59:4, 22:1, 23:1, 26:2, 16:14, 33:23, 35:23,
pull [3] - 26:6, 29:4,
81:12 60:17, 63:2 26:11, 26:18, 27:4, 48:20, 48:21, 76:9
30:8
paper [6] - 24:2, 78:5, person's [1] - 83:8 27:7, 27:16, 27:19, presenter [2] - 69:7,
pulled [2] - 26:7, 67:1
78:10, 78:12, 78:17 personal [1] - 79:11 28:1, 30:13, 30:14, 80:11
Pure [2] - 36:15, 36:16
paragraph [1] - 50:17 pertaining [2] - 25:10, 30:15, 30:23, 31:1, president [2] - 28:7,
purely [1] - 68:12
parallel [1] - 50:1 36:8 33:1, 33:7, 33:8, 29:2
purpose [1] - 16:16
parameters [2] - 5:12, phone [1] - 30:9 37:13, 37:23, 38:11, President [3] - 11:10,
pursuant [2] - 1:12,
84:7 phrased [2] - 29:13, 38:18, 39:18, 39:20, 21:22, 21:23
40:6, 40:10, 40:12, 86:5
paraphrasing [1] - 72:16 Pretto's [5] - 17:9,
40:20, 41:5, 41:17, put [7] - 18:18, 30:2,
72:6 picking [1] - 50:3 46:23, 48:13, 50:2,
42:6, 42:14, 42:17, 30:4, 42:14, 56:2,
Park [1] - 21:17 piece [7] - 14:11, 55:8
43:19, 44:2, 44:11, 56:14, 75:5
part [14] - 12:16, 22:8, 14:16, 40:20, 50:21, prevalent [1] - 28:14
45:9, 45:17, 46:6,
Q refers [1] - 7:9 4:11 37:5, 41:6, 41:9, 77:13 8

reflect [1] - 43:23 resistance [4] - 66:1, 42:22, 45:2, 47:6, seeing [3] - 12:2,
reflected [1] - 55:7 66:9, 66:13, 71:17 47:9, 47:12, 50:8, 12:17, 53:19
Queer [1] - 35:4 reflects [2] - 24:13, Resources [1] - 21:14 56:9, 56:12, 56:15, seek [1] - 83:23
questioned [1] - 5:4 25:5 resources [2] - 30:5, 56:23, 57:5, 57:10, selections [1] - 50:14
questions [4] - 7:23, refresher [8] - 79:16, 30:10 57:15, 58:17, 63:3, semantic [2] - 62:7,
25:15, 25:17, 79:5 79:21, 80:21, 80:22, respect [1] - 53:6 63:7, 76:3, 78:22, 67:12
Questions [1] - 39:7 81:1, 81:11, 81:14, respond [1] - 28:23 79:13, 82:20, 84:16, semantics [1] - 67:7
quite [3] - 38:9, 50:13, 82:23 respondent [3] - 84:20, 84:23, 85:2 sense [2] - 34:3, 57:13
84:17 regard [6] - 5:23, 83:18, 84:3 Rules [3] - 1:12, 86:5, sent [5] - 5:22, 12:7,
quote [1] - 47:17 18:19, 18:22, 20:6, responsible [1] - 7:22 88:11 36:10, 42:16, 54:16
quoted [1] - 45:8 21:19, 22:3 rest [1] - 67:19 sentence [9] - 15:10,
quoting [1] - 46:9 regarding [4] - 8:22, restricting [1] - 38:12 S 37:14, 37:20, 38:3,
9:4, 25:16, 27:17 rests [1] - 83:16 55:20, 55:23, 59:15,
R regards [1] - 17:5 result [2] - 71:6, 71:20
S.E [1] - 88:22
67:19, 73:9
regular [2] - 70:21, resumed [1] - 41:15 sentences [3] - 66:15,
safer [1] - 32:4
74:23 retain [1] - 88:15 67:1
radically [1] - 77:9 SAFER [2] - 7:5, 7:6
regularly [1] - 36:2 retained [1] - 78:11 separate [2] - 28:1,
raised [2] - 4:6, 4:12 Safety [1] - 7:11
rejected [1] - 63:18 retaliation [2] - 10:2, 49:21
rape [1] - 31:2 said/she [1] - 83:6
related [3] - 7:19, 8:1, 21:20 September [8] - 23:21,
Rape [5] - 6:18, 7:7, sanctioning [2] -
86:16 retrieved [1] - 25:2 25:6, 26:3, 26:16,
30:1, 34:22, 35:7 82:15, 82:16
relationship [1] - returned [2] - 70:10, 26:21, 26:22, 54:6,
RASAN [3] - 6:16, Sandstrom [1] - 77:13
61:13 87:2 54:15
6:17, 6:18 Sandstrom's [2] -
relative [1] - 6:9 returning [2] - 30:22, series [1] - 41:20
rather [1] - 38:18 54:23, 66:5
relying [1] - 57:8 37:10 serve [1] - 42:1
Raveson [4] - 32:7, SAPA [14] - 7:2, 7:3,
remain [1] - 7:21 review [1] - 7:19 Services [2] - 6:23,
32:8, 32:9, 52:15 12:9, 32:11, 32:19,
remember [1] - 40:1 reviewed [1] - 22:19 41:23
RE [1] - 88:6 33:13, 33:17, 34:6,
remove [1] - 37:14 revising [3] - 21:18, services [1] - 46:1
read [6] - 4:16, 17:11, 34:21, 52:12, 68:4,
removed [3] - 20:2, 45:10, 47:22 set [2] - 60:16, 60:21
66:6, 69:13, 71:19, 70:21, 74:23
39:14, 39:23 revision [2] - 8:15, several [4] - 37:3,
87:4 SAPA's [1] - 33:14
removing [1] - 44:20 8:17 37:18, 39:2, 48:8
really [1] - 60:4 Sarah [13] - 8:9, 9:14,
repeat [6] - 5:15, 47:8, revisions [7] - 22:23, sexual [40] - 6:10, 9:9,
rear [1] - 59:19 14:1, 28:2, 28:3,
47:11, 51:13, 58:21, 36:8, 45:17, 47:23, 9:20, 9:23, 11:13,
reason [2] - 60:12, 28:9, 29:8, 29:16,
72:23 54:8, 74:8, 74:12 11:14, 11:16, 13:12,
60:15 31:9, 42:4, 42:16,
rephrase [2] - 18:12, rich [1] - 38:9 13:13, 15:15, 18:19,
reasonable [1] - 29:14 74:14, 76:14
64:14 risk [1] - 22:6 18:22, 21:19, 22:20,
receipt [1] - 4:20 SASS [3] - 6:21, 6:22,
rephrased [1] - 20:3 Rochester [3] - 8:11, 23:20, 26:8, 27:17,
receive [1] - 80:20 41:22
Report [1] - 13:5 9:17, 12:5 28:13, 28:16, 28:23,
received [1] - 80:19 satisfactorily [1] - 5:2
report [1] - 57:6 role [1] - 82:16 31:2, 31:3, 31:17,
recent [1] - 45:17 scheduled [2] - 5:22,
reported [1] - 7:22 Room [2] - 1:13, 86:6 45:22, 46:2, 48:18,
recess [1] - 37:9 36:2
Reporter [1] - 1:22 Rossi [47] - 5:8, 8:6, 51:2, 55:17, 60:13,
recipient [1] - 25:20 school [2] - 12:20,
Reports [1] - 7:10 16:15, 16:21, 17:8, 60:17, 66:20, 67:17,
recipients [2] - 21:9, 32:20
representatives [2] - 19:8, 19:22, 20:19, 68:23, 80:3, 80:4,
34:15 schools [5] - 12:12, 80:5, 83:7, 83:10,
33:19, 36:11 21:7, 22:13, 23:14, 12:15, 12:23, 13:6,
recollection [2] - 12:6, 83:22, 84:7
represented [2] - 24:6, 24:10, 26:1, 33:2
42:18 Sexual [27] - 6:18,
34:14, 34:21 27:15, 29:14, 31:22, scope [1] - 84:18
recommendations [1] 6:22, 7:3, 12:9,
representing [3] - 2:4, 33:12, 37:10, 40:16, screen [1] - 81:6
- 33:16 12:21, 12:22, 17:17,
2:9, 33:18 41:16, 43:1, 43:12,
record [5] - 5:9, 25:23, seal [1] - 86:20 17:22, 18:14, 19:10,
request [1] - 74:5 45:5, 47:13, 48:4,
41:13, 49:11, 86:14 second [1] - 47:5 19:11, 19:16, 30:2,
requested [1] - 8:10 49:19, 50:23, 51:22,
RECROSS [1] - 3:2 secretary [1] - 29:2 32:11, 34:22, 35:8,
requesting [1] - 20:6 54:22, 57:20, 58:22,
REDIRECT [1] - 3:2 Section [3] - 14:17, 35:9, 35:10, 36:23,
requests [1] - 7:21 60:6, 61:15, 63:1,
reduced [1] - 86:13 17:11, 86:11 41:23, 49:2, 50:12,
required [4] - 7:10, 63:8, 64:4, 64:14,
redundant [4] - 20:2, SECTION [1] - 1:2 50:15
13:4, 36:1, 72:3 65:13, 66:4, 73:12,
37:19, 37:22, 38:3 section [4] - 49:8, sexual.assault.web
requirement [1] - 76:22, 79:2, 79:14,
refer [3] - 11:23, 12:1, 49:22, 51:8, 51:10 [2] - 24:16, 24:19
75:21 83:6, 88:16, 88:22
66:2 sections [1] - 48:22 sexually [1] - 74:5
requirements [1] - ROSSI [41] - 2:2, 2:4,
referenced [1] - 32:5 Security [2] - 7:9, 13:5 share [1] - 28:10
13:8 5:6, 16:19, 20:16,
referred [1] - 23:9 see [12] - 1:18, 9:11, Sheehy [6] - 11:7,
requires [3] - 48:17, 22:10, 23:11, 24:7,
referring [3] - 44:18, 26:7, 33:2, 43:14, 12:6, 21:7, 21:22,
55:16, 68:22 25:21, 27:8, 27:12,
49:12, 82:10 47:2, 48:14, 56:5, 21:23, 76:15
reserved [2] - 4:5, 29:12, 31:19, 33:9,
56:7, 56:18, 67:19,
SHEET [1] - 87:1 sometimes [1] - 30:6 1:12 System [1] - 12:8 trainer [2] - 69:8, 9
Sheet [2] - 88:9, 88:14 sorry [12] - 11:13, stenographically [1] - 80:17
shifting [1] - 61:4 13:20, 32:2, 36:15, 86:12 T training [20] - 3:20,
shirts [1] - 40:23 42:9, 42:13, 47:7, sticky [1] - 41:2 32:4, 67:21, 67:23,
short [1] - 34:16 49:17, 51:23, 57:15, stop [2] - 41:10, 41:12 68:2, 68:17, 68:19,
58:20, 70:14 T-shirts [1] - 40:23 69:14, 69:17, 69:21,
short-form [1] - 34:16 stopped [1] - 78:4
sought [1] - 83:21 table [2] - 12:13, 34:12 79:15, 79:16, 79:20,
show [19] - 8:3, 13:10, Street [1] - 1:13
sounds [2] - 44:2, talks [1] - 37:20 79:21, 80:10, 80:15,
20:19, 22:13, 23:15, strike [1] - 4:10
46:18 Teams [1] - 35:3 80:21, 81:15, 82:18,
24:10, 31:6, 31:22, stroked [1] - 59:6
36:18, 39:5, 43:1, specific [7] - 13:3, term [7] - 51:11, 82:23
strong [1] - 28:15
43:17, 46:22, 54:23, 36:12, 66:23, 68:22, 51:17, 56:1, 63:10, trainings [2] - 81:11,
Student [10] - 7:16,
67:13, 75:2, 77:11, 69:4, 75:18, 78:15 63:13, 63:19, 73:13 81:14
7:17, 17:13, 17:14,
79:3, 81:7 specifically [1] - 71:4 terms [1] - 28:22 transcript [5] - 4:16,
30:15, 34:8, 35:1,
shows [1] - 48:7 specificity [2] - 20:11, 35:4, 41:1, 74:19 testified [1] - 5:4 4:21, 87:5, 87:6,
sic [2] - 47:18, 51:1 20:12 student [26] - 3:17, testify [1] - 86:8 88:12
side [2] - 59:22 spell [1] - 5:9 6:3, 6:19, 7:13, 7:19, testimony [4] - 83:17, TRANSCRIPTION [1] -
sign [1] - 4:16 spit [1] - 71:18 7:20, 21:11, 27:21, 86:12, 86:14, 87:5 86:13
SIGNATURE [1] - 87:1 splitting [2] - 62:2, 27:22, 30:1, 32:9, Tetrault [3] - 14:3, transitive [2] - 62:12,
Signature [2] - 88:8, 62:6 32:22, 33:18, 33:19, 21:13, 76:16 62:20
88:14 spring [3] - 37:1, 70:2, 36:10, 36:21, 40:23, text [6] - 14:6, 14:8, transmitting [1] -
70:11 42:5, 44:16, 44:19, 14:11, 14:16, 25:6 62:17
SIGNATURE:______
squeezed [2] - 59:4, 45:7, 64:1, 77:17, THE [27] - 16:11, 17:1, trial [2] - 4:6, 4:12
______________
59:5 78:5, 83:9 18:18, 19:20, 20:10, true [4] - 24:5, 73:10,
DATE [1] - 87:21
squeezes [1] - 58:11 Student-Athlete [2] - 24:1, 41:11, 42:12, 86:14, 87:6
signed [2] - 87:2,
squeezing [1] - 58:15 34:8, 35:1 43:8, 47:7, 47:10, truly [1] - 88:18
88:13
students [26] - 20:5, 48:2, 49:14, 49:17, trustee [1] - 28:4
silence [17] - 63:22, STACEY [1] - 2:4
28:18, 32:17, 33:3, 50:11, 54:12, 56:20, trustees [2] - 28:19,
64:5, 64:8, 64:10, Stacey [1] - 5:8
33:8, 33:18, 33:20, 57:1, 58:19, 60:3, 29:3
64:18, 64:20, 65:9, staff [10] - 7:18, 21:18,
34:6, 35:11, 36:3, 61:9, 63:16, 65:1, truth [3] - 86:8, 86:9
65:17, 67:5, 67:10, 33:22, 44:10, 44:16,
37:14, 38:9, 38:14, 65:20, 73:8, 76:5, try [1] - 27:2
67:11, 71:2, 71:12, 44:23, 71:22, 72:10,
44:9, 44:13, 44:14, 83:14 trying [3] - 8:12,
72:20, 72:22, 73:3, 76:7, 76:12
44:23, 45:7, 45:8, themselves [2] - 60:20, 68:4
73:4 stakeholders [1] -
51:15, 53:5, 54:7, 65:10, 67:2
silent [3] - 64:18, 65:4, 70:8 twice [1] - 36:2
55:22, 58:5, 71:22, thinking [2] - 43:13,
65:15 stalking [2] - 10:2, two [9] - 9:2, 10:22,
72:11 61:4
silently [1] - 67:9 21:20 21:2, 29:5, 32:2,
Students [1] - 7:7 thinks [1] - 76:4 39:7, 49:4, 52:23,
similar [4] - 10:7, standards [2] - 33:5,
students' [2] - 53:23, third [1] - 15:10 67:15
13:7, 26:13, 67:23 82:2
54:3 thirty [2] - 87:2, 88:11 typewritten [1] - 86:13
simply [2] - 55:21, start [1] - 43:7
substantively [2] - three [1] - 44:22
73:9 started [4] - 55:18,
Thursday [1] - 31:10
single [1] - 36:5 55:22, 70:14, 75:4 18:21, 77:8
timelines [1] - 30:10
U
sit [1] - 67:8 starting [3] - 47:14, sufficient [1] - 59:9
47:17, 66:7 suggested [3] - 12:11, Title [11] - 7:15, 7:17,
site [1] - 31:15
33:12, 33:13 7:19, 8:2, 14:4, 46:2, umbrella [1] - 33:14
sitting [4] - 62:4, 62:8, state [2] - 5:8, 46:16
suggestion [1] - 38:23 74:6, 74:11, 74:15, unavailable [1] - 70:9
67:9, 67:11 State [2] - 12:7, 22:1
suggestions [5] - 74:17, 74:18 unchanged [1] - 6:10
slide [5] - 67:15, STATE [1] - 86:1
32:16, 34:11, 36:22, title [1] - 11:8 undated [4] - 17:2,
68:20, 80:2, 80:12, statement [10] - 11:14,
37:11, 38:6 titled [1] - 22:14 25:3, 26:5, 27:2
82:1 16:3, 18:1, 38:5,
SUNY [1] - 21:8 today [1] - 65:2 Under [1] - 62:17
slides [13] - 69:12, 55:15, 65:16, 71:1,
supplemental [1] - together [1] - 29:4 under [3] - 64:20,
79:14, 80:9, 81:3, 71:10, 72:19, 73:2
83:1 took [3] - 84:5, 84:6, 83:11, 86:13
81:4, 81:5, 81:19, Statement [7] - 12:21,
support [2] - 6:19, 7:1 86:4 Underhill [2] - 28:2,
82:4, 82:8, 82:10, 17:17, 17:22, 18:13,
suppose [1] - 20:11 top [4] - 31:12, 59:14, 28:3
82:17, 82:18, 83:1 19:10, 19:16, 49:2
surprised [1] - 63:9 59:21, 78:5 underline [3] - 14:11,
slight [2] - 65:23, statement's [1] -
Survivor [1] - 6:22 topic [1] - 39:1 14:13, 14:14
71:16 48:16
Survivors [1] - 41:23 tossed [1] - 52:12 underlined [5] - 14:6,
snapshot [1] - 60:22 statements [2] -
suspended [1] - 41:14 touch [4] - 58:3, 58:6, 14:8, 14:18, 67:18,
Society [2] - 28:7, 13:12, 84:12
SWAG [2] - 35:8, 35:9 58:10, 58:22 67:20
28:19 states [2] - 22:18,
SWAN [1] - 35:10 touching [1] - 58:12 underlines [1] - 14:14
solid [1] - 14:14 68:21
Swann [3] - 21:14, Toya [5] - 74:11, underlining [1] - 14:9
someone [7] - 30:7, STATES [1] - 1:1
23:8, 76:15 74:13, 74:16, 74:18, underneath [1] - 80:7
38:20, 58:3, 60:12, States [1] - 86:10
sworn [2] - 5:4, 86:8 74:22 undersigned [1] -
68:7, 68:8, 74:5 Stenographer [1] -
87:4
understood [6] - voting [2] - 35:16, WMS [30] - 3:7, 3:8, 10

21:22, 66:23, 75:12, 35:19 3:9, 3:11, 3:12, 3:13,
75:14, 83:21, 84:7 VS [2] - 87:5, 88:6 3:14, 3:15, 3:16,
unfolded [1] - 83:23 vs [2] - 1:6, 86:9 3:18, 3:19, 8:3,
Union [1] - 35:4 13:10, 20:20, 23:16,
unit [1] - 34:16 W 24:11, 24:17, 31:6,
UNITED [1] - 1:1 31:23, 36:18, 39:5,
United [1] - 86:10 39:6, 43:17, 43:18,
wait [1] - 32:1 47:17, 77:11
University [5] - 8:11,
waived [1] - 4:21 Woman [1] - 8:14
9:16, 12:5, 12:8,
22:1 ways [2] - 18:10, 69:9 word [8] - 14:17, 52:4,
unnecessary [2] - web [4] - 28:11, 29:21, 56:5, 56:7, 56:14,
38:4, 72:7 29:23, 30:17 57:12, 61:20, 83:8
unresponsive [1] - website [18] - 22:14, words [16] - 16:8,
4:11 22:18, 24:14, 25:3, 16:12, 38:19, 51:3,
up [14] - 9:13, 23:1, 25:6, 26:6, 30:13, 65:21, 66:17, 67:17,
39:10, 39:12, 39:14, 68:5, 68:6, 68:7,
23:21, 30:2, 30:4,
39:17, 40:6, 41:19, 68:13, 71:10, 74:2,
30:8, 30:9, 30:13,
41:22, 42:15, 52:16, 75:16, 75:18, 84:4
59:12, 69:20, 74:16,
52:23, 53:2 workload [1] - 36:4
79:11, 81:4, 81:5
Webster [3] - 63:9, writing [3] - 80:21,
up-to-date [2] - 30:9,
63:18, 64:2 80:23, 81:2
30:13
Webster's [1] - 62:10 wrote [3] - 13:17,
update [1] - 30:7
weekly [1] - 74:20 56:6, 56:11
updated [3] - 44:11,
48:4, 48:6 Wellness [2] - 35:9,
35:10
updates [3] - 48:7, Y
48:8, 76:23 Western [1] - 86:11
usable [1] - 44:16 WESTERN [1] - 1:2
whole [5] - 21:1, year [10] - 6:4, 6:6,
useful [1] - 29:4
61:12, 67:3, 68:14, 6:11, 32:20, 53:4,
utility [1] - 44:22
86:8 54:17, 54:18, 54:21,
wider [2] - 34:1, 34:2 70:4, 77:22
V WILLIAMS [4] - 1:7, years [1] - 27:23
86:9, 87:5, 88:6 York [3] - 2:3, 12:8,
various [1] - 6:14 Williams [23] - 1:12, 22:1
VAWA [6] - 8:14, 10:3, 2:9, 7:14, 9:1, 10:6,
10:13, 11:21, 13:2, 10:9, 12:16, 15:7,
21:11 26:6, 26:9, 28:14,
venue [1] - 74:20 28:17, 29:23, 30:4,
verb [1] - 62:12 31:3, 33:1, 48:16,
verbal [7] - 38:12, 50:12, 55:16, 63:20,
38:18, 65:23, 66:7, 65:7, 68:21, 86:5
66:8, 66:12, 71:16 Williams's [2] - 34:3,
verbally [3] - 38:15, 65:3
40:9, 40:12 Williams.edu [2] -
version [5] - 18:9, 29:22, 30:1
19:3, 19:6, 19:13, Williamstown [2] -
31:14 1:13, 86:6
versus [2] - 26:21, winter [1] - 70:10
83:8 wished [1] - 33:5
Vice [3] - 11:10, 21:22, WITNESS [28] - 3:2,
21:23 16:11, 17:1, 18:18,
violation [5] - 15:16, 19:20, 20:10, 24:1,
58:13, 59:6, 59:11, 41:11, 42:12, 43:8,
59:17 47:7, 47:10, 48:2,
Violence [1] - 8:13 49:14, 49:17, 50:11,
violence [6] - 10:1, 54:12, 56:20, 57:1,
10:10, 10:12, 11:17, 58:19, 60:3, 61:9,
21:20, 46:3 63:16, 65:1, 65:20,
voted [1] - 34:4 73:8, 76:5, 83:14
votes [1] - 35:13 witness [1] - 86:15
Witness [1] - 86:20

John Doe V Williams College Statement of Facts Exhibit 6

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John Doe V Williams College Statement of Facts Exhibit 6

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Case 3:16-cv-30184-MGM Document 124-6 Filed 09/30/18 Page 1 of 98

UNITED STATES DISTRICT COURT

CONTINUED DEPOSITION OF: MEAGAN BOSSONG,

(Please see Page 2.)

ROSSI LAW FIRM

LOCKE LORD LLP

8 148 Draft document, WMS 12081, 12083 20

9 149 email, WMS 11868, 11870, 11871, 11872 22

10 150 Diversity & Community document 23

11 151 emails, WMS 11983, 11204 24

12 152 email, WMS 12025, 12042 27

13 153 email, WMS 12048, 12051 31

14 154 email, WMS 11843, 11844 33

15 155 email, WMS 11852 - 11855 37

16 156 WMS 12073, 12074, 10076 41

3 It is agreed by and between the parties

4 that all objections, except objections as to

5 the form of the question, are reserved, to be

6 raised at the time of trial for the first

9 It is further agreed by and between the

10 parties that all motions to strike

11 unresponsive answers are also reserved, to be

12 raised at the time of trial for the first

15 It is also agreed that the deponent will

16 read and sign the deposition transcript.

18 It is further agreed by and between the

19 parties that notification to all parties of

20 the receipt of the original deposition

21 transcript is also hereby waived.

1 MEAGAN BOSSONG, Deponent, having

2 been satisfactorily identified by the

3 production of a driver's license, was duly

4 sworn in and questioned and testified as

6 DIRECT EXAMINATION BY MS. ROSSI

7 Q. Good afternoon, Ms. Bossong. My name

8 is Stacey Elin Rossi. Can you please state

9 and spell your name for the record?

10 A. Meagan, M-E-A-G-A-N, Bossong,

12 Q. And do you recall the parameters that

13 I provided the last time we met?

15 Q. Okay. So I won't repeat them.

16 So you're here for a 30(b)(6)

17 deposition, so do you understand that you're

18 providing answers on behalf of the College?

20 Q. Okay. And what did you do to prepare

21 for this deposition?

22 A. I scheduled it and sent whatever

23 documents I had in regard to elements that you

1 were interested in.

2 Q. Okay. Is it correct that there's a

3 hard copy of a student handbook for the

4 academic year 2013 to 2014 in the Dean's

6 A. I -- that was the last year that

7 there was a hard copy of the handbook

8 published. I imagine that there is.

9 Q. Was the Code of Conduct relative to

10 sexual misconduct in that handbook unchanged

11 from the previous academic year?

12 A. That I do not recall without looking

13 at the documents in front of me.

14 Q. I'm going to ask you about various

15 acronyms that are mentioned in the documents

16 that you've provided. What is RASAN,