Doe 1 et al v. Ciolli et al
MOTION to Expedite Plaintiffs' Motion for Expedited Discovery by Doe 1, Doe 2. (Attachments: # 1 Memorandum in Support Plaintiffs' Memorandum of Law in Support of Motion for Expedited Discovery, # 2 Affidavit Declaration of Doe I, # 3 Affidavit Declaration of Doe II, # 4 Affidavit Declaration of Doe II (Part 2 of 2), # 5 Affidavit Declaration of Steve Mitra. (Additional attachment(s) added on 4/11/2008: # 1 Memorandum in Support Plaintiffs' Memorandum in Support of Motion for Expedited Discovery, # 2 Affidavit Declaration of Doe I, # 3 Affidavit Declaration of Doe II, # 4 Affidavit Declaration of Doe II (Part 2 of 2), # 5 Affidavit Declaration of Steve Mitra, # 7 Affidavit of Steve Mitra Part 1, # 8 Affidavit of Steve Mitra Part 2) (Kunofsky, L.). Modified on 4/11/2008 (Kunofsky, L.). (Additional attachment(s) added on 4/11/2008: # 9 Proposed Order) (Kunofsky, L.). Modified on 10/6/2008 to correct text (S-D'Onofrio, B.).
Doe 1 et al v. Ciolli et al
Doc. 21 Att. 2
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
DOE I, and DOE II,
Case No~ 3:07CV00909(CFD)
Individuals, whose true names are unkown, using the following pseudonyms: pauliewalnuts; neoprag; ST ANFORDtroll; :D;
lkjhgf; yalelaw; Spany; ylsdooder; HI; David
Car; vincimus; Cheese Eating Surrender
Monkey; A horse walks into a bar; The Ayatollah of Rock-n-Rollah; DRACULA;
Sleazy Z; Whamo; Ari Gold; U gly Women; playboytroll; Dean_Harold _ Koh; krOnz;
reminderdood; r~ygold; who is; Joel Schellhammer; Prof. Brian Leiter; hitlerhitlerhitler; lonelyvirgin; Patrick Zeke -:patrick8765~hotmaii.com?; Patrick Bateman
-:batemanhs08~hotmaii.com?; (DOE I) got a 157 LSA T; azn, azn, azn; Dirty Nigger; leaf; 114 guner; kibitzer; yaieîs2009; AK47,
DECLARTION OF DOE I IN SUPPORT OF PLAINTIFFS' MOTION FOR EXPEDITED DISCOVERY!
I, DOE I, declare as follows:
1. I am a plaintiff in this action. I have knowledge of the facts set forth herein, and
if called to testify as a witness thereto, could do so competently under oath.
2. I am a third-year student at Yale Law School ("YLS").
1 The exhibits attached to this declaration, as well as the statements in this declaration taken from
those exhibits, have been redacted to replace my name with DOE I and co-plaintiffs name with DOE II, in accordance with this Cour's Order of June 18,2007 granting Plaintiffs' motion to
3. I leared through an acquaintance that I was the subject of a message thread on
4. The first thread that was posted about me on AutoAdmit.com was authored by a
poster using the pseudonym "STANFORDtroll" and was titled "Stupid Bitch to Attend Yale
Law." In the message, "STANFORDtroll" told my classmates to "watch out" for me. A true
and correct copy of
this post is attached hereto as Exhibit A (see p. 4).
5. Later, I leared that dozens of additional message threads about me had been
posted on AutoAdmit.com. Many message threads contained sexual threats, and others
contained false information about me. For example, one message thread titled "Stupid Bitch to
Attend Yale Law" contained messages such as:
· "i'll force myself on her, most definitely." A true and correct copy of
which was posted by defendant "neoprag", is attached hereto as Exhibit A (see p. 7);
· "I think I will sodomize her. Repeatedly." A true and correct copy ofthis message,
which also was posted by "neoprag", is attached hereto as Exhibit A (see p. 11); and
. ''just don't FUCK her, she has herpes." A true and correct copy ofthis message,
which was posted by defendant ":D", is attached hereto as Exhibit A (see p. 15).
6. The threatening, false and offensive comments about me that were posted by the
defendants on AutoAdmit.com continued to proliferate while I was a student at YLS. For
. A defendant posting under the pseudonym "Dirty Nigger" threatened "I wish to rape
(DOE I) and (DOE II) in the ass." A true and correct copy of
this post is attached
hereto as Exhibit B (see p. 2).
One pseudonymous poster named "Spany" posted a message stating "( c )learly she
deserves to be raped so that her little fantasy world can be shattered by real life." A
tre and correct copy of
this post is attached hereto as Exhibit C (see p. 2).
. Another pseudonymous poster-"ylsdooder"-threatened: "i would like to hate-fuck
(DOE I) but since people say she has herpes that might be a bad idea." A true and correct copy of this post is attached hereto as Exhibit D.
· A pseudonymoÚs poster "lkjhgf' falsely stated that I had bribed officials at YLS to
gain admission. A true and correct copy of this post is attached hereto as Exhibit E
(see pp. 24-25).
. Another defendant using the pseudonym "(DOE I) got a 157 LSA T" falsely suggested
that I had kiled my parents or raped co-plaintiff
DOE II. A true and correct copy of
this post is attached hereto as Exhibit E (see p. 27).
· A pseudonymous p0ster "yalelaw" falsely stated that I had engaged in a lesbian affair
with an administrator at YLS. A true and correct copy of
this post is attached hereto
as Exhibit E (see p. 37).
· "STANFORDtroll" started a thread titled '.'(DOE I) of
Yale Law got a 159 on the
LSA T" and falsely claimed that I received a lower-than-expected LSA T score for a
Yale Law student. A true and correct copy of this post is attached hereto as
7. After I discovered the messages on AutoAdmit.com, I sent approximately five
emaIl messages to the site administrators over a year-and-a-half period, asking them to remove
the offensive, threatening and defamatory messages about me that were posted on the website.
Anthony Cioll, the site administrator, sent me an email response stating that the messages would
not be removed.
8. In June 2007, a pseudonymous poster "Patrick Zeke" sent an email to many
the YLS Faculty with the subject heading: "Yale Law Faculty concerning pending
lawsuit." The author ofthe email made false and harful statements about me, including:
"(DOE I) is barely capable of reading (159 LSA T)," and "it seems like the risk of contracting
herpes from (DOE I) would convince any rational person to go to a prostitute first." A true and
correct copy of this email is attached hereto as Exhibit G.
9. Patrick Zeke's defamatory emaIl was then posted as a thread on the AutoAdmit
website by pseudonymous poster "lonelyvirgin." A true and correct copy of
this post is attached
hereto as Exhibit H (see pp. 1-2).
10. As a result of the threats of
violence, defamatory attacks, and other offensive
comments about me that were posted by defendants on AutoAdmit.com, I suffered extreme
emotional distress, including stress, fearful feelings, insomnia and severe anxiety. During this
time period, I frequently slept for only 3 or 4 hours each night and often had violent nightmares.
11. The emotional distress that I suffered caused my performance at work to
deteriorate. For example, in June 2007 while I was meeting with my supervisor at a sumer job,
I received a copy of
the "Patrick Zeke" email that was sent to the YLS faculty. I became
extremely upset after the meeting, and for several days afterwards I was distracted from my work
and slept terribly.
12. The stress and aniety that I experienced as a result of
the defendants' conduct
also created rifts in my relationships with my classmates and colleagues. For example, in the
Spring of 2007, several students with whom I worked at the Yale International Human Rights
Clinic confronted me to say that they noticed I was distracted while I was at the clinic and
appeared disengaged in work projects. I was distracted and felt disengaged from the work
clinic because of the extreme emotional distress that I was experiencing. After the confrontation
at the clinic, I felt uncomfortable around my colleagues, was no longer was invited to their social
gatherings, and felt as though my relationship with them outside of work had ended.
13. As a result of the stress, aniety, and insomnia that I suffered, I withdrew socially
and often isolated myself from my friends at schooL. I often did not attend social events at Yale
or where Yale students might be present-my friends, however, often did attend these events.
As a result, I rarely saw my friends outside of class and thus my relationships with them
14. My academic performance also deteriorated. Because of
the stress that I
experienced, I often could not attend classes and I was forced to take a reduced number of units
for my clical courwork. As a result, I received an incomplete in two classes on my Sprg
15. Due to the severe emotional distess that I sufered, I eventuly was forc to
tae a leave of absence from school for the Fall
16. I was deeply offende, mentay distss and frghtened by the invasion of my
privacy and the publication of personal inormation about me on the AutoAdmt website. .I was
equay offended and dissed by the appropriaton of my name without my permssion and t
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