Doe 1 et al v. Ciolli et al

Filing 38

Docket Entry Correction: Documents 19 Amended Complaint; 21 MOTION to Expedite Discovery; (Attachments: # 1 Motion to Expedited Discovery, # 2 Memorandum in Support of Motion to Expedited Discovery, # 3 Affidavit Declaration of Doe I, # 4 Affidavit Declaration of Doe II, # 5 Affidavit Declaration of Doe II (Part 2 of 2), # 6 Affidavit Declaration of Steve Mitra (Part 1 of 2), # 7 Affidavit Declaration of Steve Mitra (Part 2 of 2), # 8 Proposed Order, # 9 Motion to Substitute She1 lhammer, # 10 Exhibit 1); 26 MOTION to Substitute Party Name

3. I leared through an acquaintance that I was the subject of a message thread on

AutoAdmit.com.
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

this message,

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
example:

. 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).

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. 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
Exhibit F.

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
members of

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.

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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 Exhi