"Upon information and belief, Leachman surreptitiously spiked Plaintiff’s drink or food with a substance used to facilitate compliance with sexual assault and impair memory (sometimes referred to as date-rape drugs). Leachman then took Plaintiff to an empty house. Upon information and belief, the house was the Provost’s house. There, Leachman prepared a drink for Plaintiff, handed it to her, and insisted that she drink it. Upon information and belief, Leachman had spiked the drink with a date-rape drug. Shortly thereafter, Plaintiff experienced symptoms caused by commonly used date rape drugs."
Case No.: 1:16-cv-01038-CCE-JLW
"Leachman then engaged in sexual intercourse with Plaintiff. Shortly thereafter, Leachman invited Brian Self and Frank Jones to join them. Self agreed, and, upon information and belief, Leachman took Plaintiff to Self’s dorm room. There, Leachman and Self engaged in sexual intercourse with Plaintiff, who was still incapacitated. During that time, Jones joined them. While Plaintiff was still incapable of giving consent or permission, Leachman, using his cell phone, secretly videotaped the sexual assault of Plaintiff. Upon information and belief, Leachman showed the video to other students enrolled at Duke University, including but not limited to members of his fraternity."
Case No.: 1:16-cv-01038-CCE-JLW
"[Plaintiff] reported the rape and sexual assault to proper University officials and to the Duke Police Department. Around the same time, other students made similar reports to University Officials of Leachman and Self engaged in similar sexual misconduct with other, similarly isolated and incapacitated women.
Within weeks of [Plaintiff's] sexual assault, a student reported to Assistant Dean Christine Pesetski that he personally witnessed Leachman, Self, and another student employe the same modus operandi that was used in the drug facilitated rape of Plaintiff with a female student who was visiting from another university."
Case No.: 1:16-cv-01038-CCE-JLW
"After their sexual assault of Plaintiff, Leachman and Self harassed Plaintiff further by making sexually provocative comments directly to Plaintiff and about Plaintiff to their peers, and by engaging in further, unwanted and offensive sexual touching of Plaintiff’s body.
Months later, Mr. Leachman was confronted by police officers who asked him to produce the video. Leachman falsely told police no such video existed, but police subsequently seized Leachman’s cell phone and found the video still there."
Case No.: 1:16-cv-01038-CCE-JLW
"Leachman then engaged in sexual intercourse with Plaintiff. Shortly thereafter, Leachman invited Brian Self and Frank Jones to join them. Self agreed, and, upon information and belief, Leachman took Plaintiff to Self’s dorm room. There, Leachman and Self engaged in sexual intercourse with Plaintiff, who was still incapacitated. During that time, Jones joined them. While Plaintiff was still incapable of giving consent or permission, Leachman, using his cell phone, secretly videotaped the sexual assault of Plaintiff."
Case No.: 1:16-cv-01038-CCE-JLW
"Plaintiff was subjected to a drug-facilitated rape by fellow students, Colby Leachman, Brian Self, and Frank Jones while all of them were enrolled as undergraduate students at Duke University and while Leachman’s step- father, Peter Lange, was Duke University’s Provost.
At all times relevant to this action, the Provost was the highest- ranking official, administrator, and managing employee of Duke University. Among other powers, the Provost had plenary authority over all decisions and functions of Duke University, including decisions relating retention and dismissal of employees and students."
Case No.: 1:16-cv-01038-CCE-JLW