many of you will no doubt remember
lindsey shepherd
she was the teaching assistant in the
department of communications at wilford
laurier university who was subjected to
a three-member panel of inquiry after
she showed a video taken from canadian
public television of me debating the
compelled speech legislation introduced
in federal bill c-16
she showed my discussion with nicholas
matt who held the opposite position
here is part of the discussion in
question
what do we do
the three-member panel included
professors nathan rambuchana her
supervisor herbert pimlott in charge of
the masters program and adria joel
manager of gendered violence and sexual
assault prevention
shepard taped the meeting and released
it publicly producing what i think was
the biggest scandal that ever enveloped
a canadian university and certainly the
only one in living memory that became
news internationally
the thing is can you shield people from
those ideas
am i supposed to comfort them and
make sure that they are insulated away
from this like is that what the point of
this is
because to me that is so
against what a university is about so
against it i was not taking sides i was
presenting both arguments
so the thing is about this is
if you're presenting something like this
it uh
you have to think about the kind of
teaching climate that you're creating
and
this is actually these arguments are
counter to the canadian um human rights
code uh ever since i know that you've
talked about
c16 ever since this past it is
discriminatory to
be targeting someone um due to their
gender identity or gender expression so
bringing something like that up in class
not critically and i understand that
you're trying to like it was critical
i i introduced it critically
how so like like i said i it was in the
spirit of debate okay and the spirit of
the debate
is slightly different than being like
okay this is this is like a problematic
idea that we want to make when we want
to unpack but that's taking sides
yes like it's taking sides for me to be
like oh look at this guy like everything
that comes out of his mouth is bs but
we're gonna watch anyway okay
so i understand the position that you're
coming from in your positionality but
the reality is
that it has created a toxic climate for
some of the students it you know it's
how many it's great
like how many okay one yeah it may speak
i have no i have no concept of of like
how many people complain like what their
complaint was you haven't shown me
the complaint yes i i understand that
this is upsetting but there's also
confidential at the end confidentiality
matters the number of people's
confidential yes
although the university apologized
publicly for its treatment of shepherd
as did rambu khanna it is not clear at
all that the powers that be so to speak
learned their lesson and the
mistreatment of shepard not only
continued but arguably intensified
so she decided to press her case legally
and presented a statement of claim
against the three and wilford laurier
early in the second week of june
it lists in painful detail the many ways
that this situation was mishandled
during and after the initial inquisition
i also discussed the situation with
howard levitt shepard's lawyer i decided
that wilford laurier had learned very
little from its public embarrassment and
that shepard's claims were valid
justifiable and necessary including her
statement that her future lack of
employability in academia was improbable
to say the least
i've been on hiring committees and i can
tell you that even then the slightest
whiff of scandal is enough to disqualify
a candidate
in consequence not only did i decide to
read and post the entirety of shepard's
claims which i will do in a few minutes
i also decided to launch a claim of my
own against the same defendants i
thought that two lawsuits might make the
point better than one i'll read some of
my claim to after shepherds and you can
all make up your own minds about the
suitability of this course of action
ontario superior court of justice
between lindsay shepard plaintiff and
nathan rambuchana adria jewell herbert
pimlott and wilford laurier university
defendants statement of claim
to the defendant
a legal proceeding has been commenced
against you by the plaintiff the claim
made against you is set out in the
following pages
if you fail to defend this proceeding
judgment may be given against you in
your absence and without further notice
to you
2. nathan rambu khanna
and to adria jewell
and to herbert pimlott
and to wilford laurier university
claim
the plaintiff claims the following
against the defendants individually and
cumulatively the following
five hundred thousand for the tort of
harassment five hundred thousand for the
tort of intentional infliction of
nervous shock five hundred thousand for
the tort of negligence a hundred
thousand for constructive dismissal
aggravated damages in the amount of five
hundred thousand general damages
in the amount of five hundred thousand
punitive damages in the amount of a
million dollars
the plaintiff resides in the town of
waterloo in the province of ontario
the defendants herbert pimlott and
nathan rambuchana are professors at the
defendant wilford laurier university
pimlott was the coordinator for the
masters program of the university and
rambu khanna at the relevant time was
the professor for the course which
shepard was a teaching assistant for
both had considerable influence over the
plaintiff's employment as a teaching
assistant and status as a master's
student
the defendant adria joel was at all
relevant times acting manager of the
university's diversity and equity office
in charge of gender violence prevention
the defendant university is a creature
of statute
created pursuant to the provisions of
the wilford laurier act
the university is vicariously liable for
all of the conduct of the individual
defendants referred to herein and at all
relevant times created an environment
supporting and facilitating acquiescing
to and implicitly and sometimes
explicitly endorsing that conduct
the constituent statute of the
university the wilford laurier act 1973
as amended 2001 and 2016
in providing the fundamental
jurisdiction and authority for the
university to operate states as its
object in section four
that the objects of the university are
for the pursuit of learning through
scholarship teaching and research within
a spirit of free inquiry and expression
the university has no other object and
no jurisdict
and no jurisdiction to operate otherwise
the university has no other object and
no jurisdiction to operate otherwise
pursuant to section 5 powers of the
university the act further states that
the university has all powers necessary
and incidental to the satisfaction and
furtherance of its objects as a
university
the constituent statute creating and
empowering the university provides it
with no other power or authority
shepard was at all relevant times a
student in the university masters
program pursuing her master's degree and
employed as a teaching assistant for a
course under rambuchana and following
that under professor judith nicholson
as a teaching assistant shepard
supported a class taught by professor
rambikana
she was generally responsible for
teaching two groups of approximately 25
students was assigned topics and was
entitled pursuant to the policies of the
university and of rambuchana to devise
her own curriculum
was an indifferent mentor who had only
met with shepard twice about his course
and only then briefly
ironically given his complaint against
her as delineated below he provided her
with very limited direction as to the
content to provide to her students in
his classes
the topic for one of her communication
classes held on november 1st 2017 was
grammar she taught three classes that
day
shepard introduced the topic of the
grammatical correctness of
gender-neutral language in the evolution
of various languages and to facilitate
discussion on the subject showed a few
minute extract from a tv ontario program
moderated by stephen paken consisting of
a debate between professor jordan
peterson of the university of toronto
psychology department and nicholas matt
from the university of toronto's sexual
diversity studies program
peterson and nicholas matt were debating
compelled gender pronouns peterson
argued against being required to use
these new words which he argued had not
developed organically matt took an
opposing position
shortly following that class rambuccana
ordered her to attend a meeting the very
next day with himself pimlott the
program coordinator for the entire
masters program and adria joel acting
director of the diversity and equity
office
both rambukana and pimlot had
considerable authority over shepard's
fate at the university apparently so did
joel
shepard had never been called into such
a meeting indeed rambikana to that point
had barely acknowledged her existence
at this session all three lambasted
shepherd viciously attacking her
personally falsely alleging that there
had been a complaint or complaints about
her tutorial and insisting that in
playing the tv ontario clip she had been
threatening to her students rambokanic
claimed that her showing this tv ontario
clip breached the charter of rights and
freedoms and federal bill c-16 which
does not even govern provincially
regulated universities created an unsafe
learning environment and was illegal
shepard was accused of targeting trans
folks even though shepard had chosen no
side had up till that point disagreed
with what she understood to be
peterson's perspective and presented the
arguments and the debate neutrally ram
buchana attacked and slandered peterson
claiming that he was part of the
alt-right and that playing a clip of
peterson without first providing any
previous context to the students was
like neutrally playing a speech by adolf
hitler shepherd argued that doing as he
asked would be taking sides and that was
not her role she was then further
rebuked for taking that position at
various points during that almost
hour-long vicious and abusive attack
shepard was reduced to tears
ironically rather than being a
present-day personification of adolf
hitler as rambuchana implied jordan
peterson has spent decades educating his
students about the evils of the
holocaust and specifically as part of
his psychological teachings has studied
and taught how individuals degenerate
ethically to the point where they take
place
to the point where they take part in
atrocities
as part of his psychological teachings
he has studied and taught how
individuals degenerate ethically to the
point where they take part in atrocities
during the meeting shepard was
effectively attacked as a protege and
supporter of peterson
pimlott continued to libel peterson
explaining that people like him live in
a fantasy world of false conspiracy and
accusing shepard of being an agent of
those ideas because she had neutrally
shown this video with its opposing
viewpoints
rambu cana falsely but imaginatively
claimed that shepard herself was
targeting people based on their gender
identity or gender expression and in
doing so had violated the federal human
rights code of bill c-16 although
shepard's conduct was in no way violent
of of that or any law
shepard asked the individual defendants
whether her job as a teaching assistant
was to shield her students from debate
and ideas rambukana asserted that it was
and then accused her of targeting
students due to their gender expression
and identity
when shepard pointed out that she had
not taken sides in this debate the three
rebuked her for creating a toxic climate
the three refused to advise shepard what
the complaint was or who complained
claiming that even the number of
complaints was confidential
as was subsequently ascertained there
had been no complaint at all
shepard protested that she did not
understand how her teaching methods
constituted any disservice to the
university since the ideas in the video
were already part of social currency
joel responded without any foundation
accusing her of spreading transphobia
rambukana added to jewel's attack by
essentially comparing her actions to
white supremacy
contrary to the allegations of the
defendants at this meeting shepard
conducted herself at this seminar
precisely as her role required and
singularly represented the principles of
the wilford laurier university act for
this she was viciously attacked by
rambikana pimlot and jewell they
continued to abuse her even after she
began sobbing accusing shepard of
causing harm to unnamed students
shepard apologized for crying during the
meeting pleading i am stressed out
because to me this is wrong so wrong
noting that the very spirit of the
university is to challenge ideas that
you already have and reminding them that
she had not taken any side or position
the meeting concluded with shepard being
advised even after she promised to show
no further videos of peterson or
anything of the like that she now had to
run all of her seminar notes past
rambuchana
to obtain specific approval for any
future clips of anyone that she attended
to show
and that rambu kanna might have to sit
in on her future classes
she was prohibited from showing any
further videos
finally they suggested to her that her
job might be in jeopardy
the conduct of the defendants was
objectively outrageous and flagrant they
had reckless disregard for the fact that
the foreseeable consequences of their
conduct would cause shepherd to suffer
emotionless stress
which it did
there are various policies of the
university which constitute a contract
between the university and its members
including shepard
article 1.01 of the procedures relating
to the prevention of harassment and
discrimination policy 6.1 of the
university notes that informal
resolution possibilities as well as
emotional academic and departmental
supports will be explored
none of this occurred
it also noted in article 1.02 of the
procedures relating to the prevention of
harassment discrimination policy 6.1
that if the concern falls outside of
this policy's jurisdiction or could be
more appropriately dealt with elsewhere
the individual will be referred to the
appropriate office that also did not
occur
under article 3.02 of policy 6.1 the
office of dispute resolution and support
will determine whether a complaint may
go forward article 3.04 states that the
office is available to provide guidance
on the preparation of a complaint or
response to a complaint that guidance
was not provided to shepherd article
5.01 of policy 6.1 states that an
investigation may be required when other
efforts to resolve the complaint have
not been successful or not appropriate
in the complaint by jackson referred to
below
no other efforts to resolve the
complaint were considered before
proceeding to the formal investigation
of shepard
article 8.03 of policy 6.1 states that
wilford laurier university's prevention
of discrimination and harassment policy
is not intended to inhibit academic
freedom it was used by rambuchana joel
and pimlot for precisely that purpose
article 8.05 notes that the university
may take disciplinary action against
those who make allegations of harassment
or discrimination which are reckless
malicious or not in good faith
although pimlott rambuchana and joel had
acted recklessly maliciously and in bad
faith and it was ultimately determined
by the university that this meeting
never should have occurred no action has
been taken by the university against
them and shepard was provided no
protection from their predations
the prevention of harassment
discrimination policy provides in
article 1.02 that each member of the
campus community is responsible for
helping to create an environment that
promotes mutual respect and
understanding for the dignity and rights
of others this policy was violated by
rambuchana pimlot and joel
the prevention of harassment
discrimination policy defines workplace
harassment in article 2.04 as engaging
in a course of vexatious comment or
conduct against a worker in the
workplace that is known or ought
reasonably to be known to be unwelcome
or workplace harassment this provision
too was violated by rambuccana pimlot
and joel
article 2.07 defines a poisoned
environment as where harassing or
discriminatory behaviors are severe and
or pervasive and cause unreasonable
interference with a person's study or
work environment a poisoned environment
may be created a poisoned work or
learning environment is one that is
intimidating hostile and or offensive a
poisoned environment can arise even from
a single incident
it may be created by the comments or
actions of any person regardless of his
or her status
rambuccana pimlott and joel created a
poisoned work environment for shepard
and thereby breached the university's
contractual obligations to shepherd
article 4.04 states that the university
will take appropriate steps to fairly
investigate respond to allegations of
discrimination and or harassment in
accordance with the procedures relating
to this policy
no such steps were taken instead shepard
was wrongly attacked by the members of
the administration until public and
alumni outcry forced the university to
retreat from its position
following this meeting being publicized
mcclatchy president of the university
was interviewed on the agenda by steve
pakin the same show from which the clip
of the debate between dr peterson and
matt was taken
she was repeatedly asked by pakin
whether shepard had done anything wrong
by showing this clip from his earlier
show
mcclatchley effectively defended the
conduct of rambucana jewel and pimlott
she refused to acknowledge that shepard
had not acted improperly despite pakin's
continuing to press her on this
shepard had the foresight to taper
inquisition when it began and after
outrage from the public and alumni
erupted the president of the university
deborah mcclatchy and rambukana issued
apologies in rambukana's forced apology
he continued to lie still insisting that
there had been a complaint and that he
had been doing his duty by addressing it
it was only when public and alumni
outrage grew that mcclatchy was
ultimately forced to admit that what
happened to ms shepard in the meeting
was shameful and that the material she
showed was entirely appropriate that was
a quote this was only after an
investigator found that there never had
been any complaint formal or informal
and that rambucana pym lots and joel's
statements to the contrary were false
and deceitful
the university admitted in this
statement from its president that this
meeting never should have happened at
all
no formal complaint nor even an informal
concern relative to university policy
had been registered as to the screening
of the video
the president only when besieged
acknowledged that these errors in
judgment were compounded by the
misapplication of the university's
policies and procedures the basic
guidelines and best practices on how to
appropriately execute the roles and
responsibilities of staff and faculty
were ignored or not understood the
procedures on how to apply university
policies and under what circumstances
were not followed and that the
institutional failure allowed this to
happen
the president noted that as there was
institutional failure the responsibility
ultimately started and ended with her
she further acknowledged that ms shepard
was targeted with vitriol by members of
the university
mcclatchy admitted that shepard was
involved in absolutely no wrongdoing and
publicly stated that the university was
taking action to ensure that this did
not occur again a claim that was and
remains
entirely false shepard has never
received redress of any kind nor has she
been consulted about the input that this
treatment has had on her and her career
prospects instead
she was subjected to continuing abuse
and a toxic climate from the university
and its representatives as described
below
in mcclatchy's apology on november 21st
2017 she states that quote supports were
in place to support student involvement
in a situation who are targeted with
extreme vitriol through the situation
end quote yet she and the university
offered shepard no such support
in mcclatchy claiming to be troubled by
the way quote everyone end quote
involved in the situation was targeted
with extreme vitriol she showed the same
and equal concern for shepherd's
predators as for shepard herself
the president also acknowledged that the
rationale for invoking the gender and
sexual violence policy did not exist
that it was misapplied and that this was
a significant overreach
shepard relies on mcclatchy's admissions
herein
mcclatchy claimed that quote laurier is
committed to the abiding principles of
freedom of speech and freedom of
expression end quote her conduct
throughout entirely betrayed that goal
in rambukana's disingenuous apology to
shepherd on november 21st 2017 he stated
open quote well i still cannot discuss
the student concerns raised about the
tutorial
end quote
but no student concern had even been
raised about the tutorial prior to his
and his co-defendants bullying of
shepard
he acknowledged that his meeting with a
panel of three people would be an
intimidating situation for shepard and
would not have invited a productive
discussion
rambuccana's apology claimed that he
quote did not do enough to try to
support her shepherd end quote when he
did absolutely nothing at all but
instead attacked her
following the public outcry the next
time shepard met with her students the
chair of the department of
communications peter erkahart attended
that tutorial and offered shepherd's
students but not shepherd emotional
support suggesting that they would be
welcome to go to the campus wellness
center he sat at the back of the room
for the entire tutorial effectively
shutting down any discussion on the
issue and undermining shepard's role in
her classroom
urkahart proceeded on behalf of the
university to publicly insult shepard
when asked by email by mclean's magazine
why he appeared in her class on that day
he responded
quote i assume she recorded it why not
ask her for the recording
end quote he then sent mcleans a second
email open quote sorry you're a pro i
should have assumed that you've already
heard that particular recording end
quote using his position of power and
authority over shepherd to intimidate
and embarrass her publicly
professor alicia slowinski who shepard
was taking a master's course from asked
in front of the class for shepard to put
away her laptop and then said in front
of other master students that she gave
this instruction because she did not
want to be recorded even when shepard
assured her that she was not recording
the class further alienating and
creating a toxic environment for
shepherd
following these events
rambuchana's course ended and shepard
was assigned to be the teaching
assistant to professor judith nicholson
a professor of communication who had
publicly taken a negative position
against shepherd prior to shepherd being
assigned to her before that semester
even started nicholson had signed an
open letter supporting pimlott and
rambuchana
this made the university assigning
shepherd to her tutelage entirely
inappropriate created a poisoned
environment for shepard and made it
impossible for her to succeed
shepard's apprehensions about
nicholson's lack of objectivity toward
her were quickly borne out
on three occasions during their
relatively brief dealings nicholson
without provocation harassed and abused
shepherd and deliberately created
difficulty for her
from the outset of their meeting
nicholson told shepard that it was her
quote academic freedom end quote and
that no one is permitted to make the
university look bad implying that
shepard had improperly done so
on the second occasion she sent out a
course syllabus with a territorial
acknowledgement i.e a reference to the
aboriginal tribe which had once been on
the land which wilford laurier was on
shepard considering this irrelevant to
the syllabus and a ludicrous act of
political correctness and virtue
signaling cut out that part of the note
and tweeted it noting that such
acknowledgements were now even on the
syllabus of university courses
nicholson demanded in front of the other
teaching assistants that she delete her
tweet
when shepard protested that all she was
tweeting was the university logo with
the course name and territorial
acknowledgement nicholson threatened to
take her to the dean if she did not
remove it nicholson also absurdly
claimed that this territorial
acknowledgement was her intellectual
property
she proceeded to complain to the dean
about shepard's tweet in an attempt to
further endanger shepard's position in
the university the dean informed
nicholson that the acknowledgement was
not her intellectual property
and called an urgent meeting with the
two departments which shepard was
associated with the communication
studies and the cultural analysis and
social theory departments at least in
part to discuss these issues
it was clear that if shepard had tweeted
positively about the land
acknowledgement she would not have been
in difficulty with nicholson
the third occasion was in march 2018
when shepard needed to reschedule her
last class of the year and utilize
polling software with a link to
available alternate days for her class
to fill out their available alternate
dates
when shepard found times that all of her
students were available to meet she
emailed nicholson to seek her approval
for the new dates
nicholson reprimanded her copying two
deans claiming falsely that shepard had
moved these classes without nicholson's
consent in advance even though the
letter was just such a request and the
request on its face was premised on
nicholson's consent
when shepard advised nicholson that she
never had any intention of changing the
date without nicholson's approval which
was why her letter explicitly requested
that approval nicholson canceled
shepard's tutorial entirely this was
despite the fact that alternate dates
were available for shepard and her
students to attend
nicholson instructed shepard students to
attend sessions of the other teaching
assistants on dates which were largely
coincident with dates which shepard and
her students had arranged since this was
to have been shepherd's last class she
never saw her students again
ethan jackson a transgender activist who
has attacked shepard throughout the
events described herein
launched a formal patently frivolous
harassment complaint against her to
which even after ms shepard had
completed her coursework at the
university so she would not see jackson
again
the university responded by proceeding
with a formal investigation despite its
inherently vexatious bad faith and
frivolous allegations which pursuant to
the applicable policies the university
should not have proceeded with
jackson had an online crowdfunding page
seeking a sex change operation which was
initially denied because of his mental
health issues
additionally jackson was banned
from the university of waterloo campus
in 2013 for protesting and
de-platforming a member of parliament
who was to give a speech on abortion by
dressing up as a giant vulva and yelling
jackson was invariably hostile to
shepherd
jackson's allegations against shepard
were that a she was on her telephone
during one class and purportedly
disengaged from participation in that
class
b
ms shepherd had made four tweets with
screenshots from jackson's controversial
social media account
c
shepard responded to jackson walking
into the printing room and angrily
ordering her to leave the room and cease
using the communications department
printer which she required for her
communications course work
by referring to him as petty and
pathetic
d
when shepard and two others were putting
up posters for a laurier society for
open inquiry meeting he claimed that
they had followed him and his colleague
as they were walking around the halls
and that shepard's posters had signage
which he found offensive posters which
he acknowledges removing from the walls
without
authorization the complaint of jackson
was made maliciously after classes were
over for the year at a time when he and
shepard would not ever be interacting
again since shepard is not enrolled in
laurier courses for the following
session
despite jackson's complaint being
inherently self-contradictory and
ludicrous the university not only
proceeded to summon shepard for an
investigation but threatened her with
repercussions if she disclosed jackson's
complaint to anyone
the attacks on shepard have rendered her
unemployable in academia resulting in
her abandoning her previous ambitions of
obtaining her phd or even teaching at a
university as a master's graduate
shepard has suffered nervous shock as a
result of the conduct of the defendants
which was the foreseeable and intended
result
in the alternative it was the reasonably
foreseeable outcome of their conduct and
the defendants were negligent in their
treatment of her
so that's shepard's claim
as i said after i reviewed this and
talked in detail to shepherd's lawyer i
concluded that wilford laurier had not
learned what needed to be learned and
launched a claim of my own this week it
reads in part
the plaintiff that's me claims against
the defendants nathan rambuchana herbert
pimlott adria joel and wilford laurier
university the following
five hundred thousand for defamation
five hundred thousand for injurious
falsehood five hundred thousand in
punitive damages pre-judgment and
post-judgment interest in accordance
with the courts of justice act costs on
a substantial indemnity basis and such
further and other relief as council may
advise and this honorable court may deem
just
the plaintiff's claim against rambuchana
pimlott joel and the university
defamatory statements on youtube
on or about november 2nd 2017 rambuccana
ordered his then teaching assistant
lindsay shepard to attend what turned
out to be a disciplinary meeting with
himself pimlott and jewell to discuss
her having shown an extract from a tv
ontario program to her students the tv
ontario program moderated by steve pakin
consisted of a debate between peterson
and nicholas matt at the meeting on or
about november 2nd 2017 rambo can of
pimlott and joel each made numerous
defamatory statements about peterson all
of which the others endorsed both
expressly and implied
the meeting's content has since been
posted online on the video sharing
website youtube and is available on the
internet where it is open to the public
and easily accessible by anyone who
wishes to view its content i'm skipping
a bit here at the meeting on or about
november 2nd 2017 rambuccana pimlott and
joel falsely and maliciously made
numerous defamatory statements about
peterson including but not limited to
the following
defamatory statements made by rambu
khanna a
peterson identified student protesters
by posting their social media accounts
for the purpose of other people bullying
and threatening them online b peterson
is basically debating whether or not a
trans student should have rights
c peterson's position would be the
equivalent of debating whether or not a
student of color should have rights or
should be allowed to be married contrary
to the charter of rights and freedoms d
peterson has engaged in the targeting of
trans students giving out their personal
information for the purpose of having
them attacked harassed so that death
threats will find them this is something
that peterson has done to his own
students peterson has done to other
students
e playing a speech by peterson is
basically like playing a speech by
hitler
f
peterson's opinion is like alt-right
opinion white supremacist opinion
anti-trans opinion anti-gay opinion
anti-woman misogynist opinion g
peterson's view is whether trans people
are people or not
defamatory statements made by pimlott
peterson is academically suspect to say
the least he does not have the
substantial academic evidence to be a
credible person
b peterson's positions don't have
credible evidence just like charles
murray with his race claims of white
superiority c peterson brings hatred and
targets groups d peterson exhibits
charlatanism e peterson has nothing
really that is credible in terms of
research
defamatory statements made by joel a
peterson's position is causing harm to
trans students by framing their identity
as invalid or their pronouns as invalid
contrary to the ontario human rights
code
b
peterson is spreading transphobia
now i'm skipping ahead a bit again
the said words in their natural and
ordinary meaning and the connotation of
the comments obvious to any reader were
meant and were understood to mean that
peterson
is comparable to adolf hitler the
greatest despot in world history
deliberately spreads hatred both
generally and in particular to students
is a member of the alt-right is unfit to
be a professor breaches the code of
ethics of his profession and university
is a white supremacist has and expresses
opinions which are uninformed and
uneducated is sexist is misogynist
is racist is homophobic is transphobic
is a deplorable person is incompetent is
a reprobate lacks integrity lacks the
appropriate ethics to be a psychologist
and professor
is a bully and abusive towards students
wants to deprive minorities of any
rights organizes attacks even death
threats on students breaches canadian
law
dehumanizes certain of his students and
lacks credibility and credentials
the statements made by rambuchana pimlot
and joel infer all of the above
including but not limited to
that peterson is unsavory sexist
misogynist dangerous racist homophobic
transphobic analogous to adolf hitler
and incompetent in his profession as an
author teacher and professor and were
false
and specifically designed to impugn his
reputation these defamatory statements
were malicious and designed specifically
to damage his personal and professional
character as a professor author lecturer
and public intellectual
well
you get the picture
that's the end of that
i'm hoping that the combination of the
two lawsuits will be enough to convince
careless university professors and
administrators blinded by their own
ideology to be much more circumspect in
their actions and their words
we'll see how that plays out