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06:53:37 1 IN THE UNITED STATES DISTRICT COURT 3 MR. BAXTER 8

FOR THE SOUTHERN DISTRICT OF IOWA
2 EASTERN DIVISION 4 MR. CARROLL -
3 BUSINESS LEADERS IN CHRIST, ) 5
an unincorporated association,)
4 ) CASE NO. 3:17-CV-00080 6 O B J E C T I O N S
Plaintiff, ) )
5 vs. ) 7 Mr. Carroll posed objections on pages 95, 116, and 178.
) DEPOSITION OF
6 THE UNIVERSITY OF IOWA: LYN ) WILLIAM R. NELSON
REDINGTON, in her official ) Volume 1 August 8, 2018 8
7 capacity as Dean of Students )
and in her individual ) 9 E X H I B I T S
8 capacity; THOMAS R. BAKER, in )
his official capacity as ) 10 (The below-listed exhibits were marked for
9 Assistant Dean of Students and)
in his individual capacity; ) 11 identification by the reporter at the end of the day,
10 and WILLIAM R. NELSON, in his )
official capacity as Executive) 12 with the exception of exhibits marked with asterisks
11 Director, Iowa Memorial Union,)
and in his individual )
12 capacity, ) 13 (*), which were emailed to the reporter and marked on
Defendants. )
13 14 August 20, 2018.)
14 APPEARANCES 15
15 ATTORNEY ERIC BAXTER, of The Becket Fund for INITIAL
Religious Liberty, 1200 New Hampshire Ave.
16 NW, Suite 700, Washington DC 20036, appeared 16 REFERENCE
on behalf of the Plaintiff.
17
ATTORNEY DANIEL BLOMBERG, 1124 Park West
18 Blvd., Mount Pleasant, SC 29466, appeared on
behalf of the Plaintiff. 17 Deposition Exhibit Number 1
19
ATTORNEY GEORGE CARROLL, of the Iowa Attorney
20 Generals Office, 1305 E. Walnut Street,
Des Moines, IA 50319, appeared on behalf of 18 Deposition Exhibit Number 2 12
21 the Defendants.
22 DEPOSITION OF WILLIAM NELSON,
19 Deposition Exhibit Number 3 14
23 taken in Room BVC 111, University of Iowa Research Park,
2500 Crosspark Road, Coralville, Iowa, on the 8th day of 20 Deposition Exhibit Number 4
24 August, 2018, commencing at 8:52 a.m., before Sandra E.
Edwards, Certified Shorthand Reporter in and for the
25 State of Iowa. 21 Deposition Exhibit Number 5
22 Deposition Exhibit Number 6
23 Deposition Exhibit Number 7
24 Deposition Exhibit Number 8
25 Deposition Exhibit Number 9

3 4

1 Deposition Exhibit Number 10 1 Deposition Exhibit Number 34 147

2 Deposition Exhibit Number 11 129 2 Deposition Exhibit Number 35

3 Deposition Exhibit Number 12 131 3 Deposition Exhibit Number 36

4 Deposition Exhibit Number 13 4 Deposition Exhibit Number 37 170

5 Deposition Exhibit Number 14 125 5 Deposition Exhibit Number 38

6 Deposition Exhibit Number 15 131 6 Deposition Exhibit Number 39

7 Deposition Exhibit Number 16 132 7 Deposition Exhibit Number 40

8 Deposition Exhibit Number 17 133 8 Deposition Exhibit Number 41

9 Deposition Exhibit Number 18 134 9 Deposition Exhibit Number 42

10 Deposition Exhibit Number 19 134 10 Deposition Exhibit Number 43

11 Deposition Exhibit Number 20 134 11 Deposition Exhibit Number 44

12 Deposition Exhibit Number 21 134 12 Deposition Exhibit Number 45

13 Deposition Exhibit Number 22 134 13 Deposition Exhibit Number 46 113

14 Deposition Exhibit Number 23 14 Deposition Exhibit Number 47 120

15 Deposition Exhibit Number 24 15 Deposition Exhibit Number 48

16 Deposition Exhibit Number 25 16 Deposition Exhibit Number 49

17 Deposition Exhibit Number 26 17 Deposition Exhibit Number 50

18 Deposition Exhibit Number 26-A 18 Deposition Exhibit Number 51

19 Deposition Exhibit Number 27 19 Deposition Exhibit Number 52

20 Deposition Exhibit Number 28 20 Deposition Exhibit Number 53 121

21 Deposition Exhibit Number 29 21 Deposition Exhibit Number 54 121

22 Deposition Exhibit Number 30 22 Deposition Exhibit Number 55

23 Deposition Exhibit Number 31 23 Deposition Exhibit Number 56

24 Deposition Exhibit Number 32 24 Deposition Exhibit Number 57

25 Deposition Exhibit Number 33 147 25 Deposition Exhibit Number 58

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1 Deposition Exhibit Number 59 1 Deposition Exhibit Number 84
2 Deposition Exhibit Number 60 2 Deposition Exhibit Number 85
3 Deposition Exhibit Number 61 3 Deposition Exhibit Number 91
4 Deposition Exhibit Number 62 4 Deposition Exhibit Number 92 * 18
5 Deposition Exhibit Number 63 5 Deposition Exhibit Number 98
6 Deposition Exhibit Number 64 6 Deposition Exhibit Number 102 24
7 Deposition Exhibit Number 65 7 Deposition Exhibit Number 104 23
8 Deposition Exhibit Number 66 8 Deposition Exhibit Number 105 28
9 Deposition Exhibit Number 67 9 Deposition Exhibit Number 106 32
10 Deposition Exhibit Number 68 10 Deposition Exhibit Number 108 38
11 Deposition Exhibit Number 69 11 Deposition Exhibit Number 109 43
12 Deposition Exhibit Number 70 12 Deposition Exhibit Number 110 49
13 Deposition Exhibit Number 71 13 Deposition Exhibit Number 111 52
14 Deposition Exhibit Number 72 14 Deposition Exhibit Number 112 54
15 Deposition Exhibit Number 73 15 Deposition Exhibit Number 113 * 56
16 Deposition Exhibit Number 74 16 Deposition Exhibit Number 114 81
17 Deposition Exhibit Number 75 157 17 Deposition Exhibit Number 115 85
18 Deposition Exhibit Number 76 18 Deposition Exhibit Number 116 85
19 Deposition Exhibit Number 77 19 Deposition Exhibit Number 118 99
20 Deposition Exhibit Number 78 20 Deposition Exhibit Number 119 104
21 Deposition Exhibit Number 79 21 Deposition Exhibit Number 121 181
22 Deposition Exhibit Number 80 22 Deposition Exhibit Number 122 183
23 Deposition Exhibit Number 81 107 23 Deposition Exhibit Number 125 184
24 Deposition Exhibit Number 82 24 Deposition Exhibit Number 126 185
25 Deposition Exhibit Number 83 25 Deposition Exhibit Number 127 186
7 8
1 Deposition Exhibit Number 128 199 1 PROCEEDINGS
2 Deposition Exhibit Number 131 205 2 (August 8, 2018; 8:52 a.m.)
3 Deposition Exhibit Number 132 220 3 (Present are the deponent, Mr. Baxter,
4 Deposition Exhibit Number 133 227 4 Mr. Blomberg, and Mr. Carroll.)
5 Deposition Exhibit Number 140 231 5 WILLIAM NELSON,
6 Deposition Exhibit Number 141 235 6 the witness, was duly sworn to testify the truth, the
7 Deposition Exhibit Number 143 236 7 whole truth, and nothing but the truth, was examined,
8 Deposition Exhibit Number 150 237 8 and testified as follows:
9 Deposition Exhibit Number 154 242 9 EXAMINATION
10 Deposition Exhibit Number 167 247 10 BY MR. BAXTER:
11 Deposition Exhibit Number 173 * 160 11 Q. Good morning.
12 Deposition Exhibit Number 174 * 162 12 A. Good morning.
13 Deposition Exhibit Number 175 * 160 13 Q. Would you please state your name for the record?
14 Deposition Exhibit Number 184 253 14 A. William R. Nelson.
15 Deposition Exhibit Number 192 258 15 Q. And could you please -- who's your employer?
16 Deposition Exhibit Number 220 122 16 A. The University of Iowa.
17 Deposition Exhibit Number 221 17 Q. And how long have you been at the University?
18 18 A. I just -- completed my 15th year.
19 (All original exhibits entrusted to the reporter were 19 Q. And what positions or roles have you held at the
20 returned to Plaintiff's counsel following completion of 20 University?
21 the transcript.) 21 A. I came to the University as the Director of
22 22 Student Life. Then I became -- I was promoted and
23 23 became -- the Director of Student Life title, and then
24 24 became, in addition, Associate Director of the Iowa
25 25 Memorial Union. I became the -- Director of the Iowa
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1 Memorial Union, I became the Executive Director of the 1 the functions, programs, and services from the Iowa
2 Iowa Memorial Union, and just recently named Associate 2 Memorial Union. So I retained those original
3 Dean of Students and Director of -- Executive Director 3 responsibilities and then just kept adding more.
4 of the Iowa Memorial Union. 4 So in the Executive Director of the Iowa Memorial
5 Q. And can you briefly just tell me what was 5 Union capacity, again, I have provided administrative
6 involved in each of those responsibilities? 6 oversight for that operation, which consists of a book
7 A. Um-hum. So as the Director of Student Life, I 7 store, the University Club, facilities, operations,
8 was responsible for the Office of Student Life, which is 8 guest and events services. We have a hotel, and the
9 now the Center for Student Involvement and Leadership. 9 Center for Student Involvement and Leadership is a part
10 The name just changed. So that was providing 10 of that operation. We have a welcome center.
11 administrative oversight to Fraternity/Sorority Life, 11 And then again continuing to maintain those
12 our campus programs and student activities area, our 12 responsibilities, and then just recently named Associate
13 major annual events area. Student Legal Services 13 Dean of Students in the reorganization of the Division
14 reported up through me. Our multi cultural programs and 14 of Student Life, and so I'll have some larger
15 cultural centers program reported up through me. I -- I 15 responsibilities with the Dean of Students operation.
16 maintained that, those responsibilities. 16 MR. CARROLL: I'm sorry to interrupt. Two
17 Then, as I referenced, I just received some 17 things: Will you speak up a little bit and slow down
18 additional responsibilities when I was named Associate 18 just a little bit?
19 Director for the Iowa Memorial Union and just assumed 19 THE WITNESS: I certainly -- certainly.
20 additional responsibilities in the area of assessments 20 MR. CARROLL: I mean, I know you're --
21 for the Iowa Memorial Union, and sharing some of the 21 you're not used to being deposed, but she's the only one
22 administrative oversight with the then-Director. 22 that's important in here today. So if you can please
23 Then, the -- again, continued to maintain my 23 speak up a little bit.
24 responsibilities for the Center for Student Involvement 24 THE WITNESS: I'm happy to do that.
25 and Leadership, but then became solely responsible for 25 (A discussion was held off the record.)

11 12
1 BY MR. BAXTER: 1 to testify on your own behalf and on behalf of the
2 Q. And as the Associate Dean of Students, who were 2 University; you understand that?
3 you replacing? 3 A. Yes.
4 A. I'm not replacing anyone. There was a 4 Q. And your counsel just mentioned a few of these,
5 restructuring of the Division of Student Life, and the 5 that it's important as far as ground rules that you try
6 Vice President for Student Life, Melissa Shivers, named 6 to give verbal responses. The reporter can't take a
7 two Associate Deans: Dr. Angie Reams, who will be 7 head shake or a nod.
8 primarily doing Student Care and Assistance, and then 8 A. Okay.
9 me. 9 Q. Let's try not to talk over each other, so that
10 Q. And is the position that was previously held by 10 she can get everything down that we say. And if you
11 Lyn Redington still open? 11 need any breaks, let me know. We'll try to take a break
12 A. Correct. 12 every hour or 90 minutes, but if you need a break, we'll
13 Q. And so now you will report directly to Melissa 13 be happy to accommodate that.
14 Shivers? 14 I'm gonna ask you now to look at the binder in
15 A. In the interim I am reporting to Melissa, and 15 front of you, the exhibit behind Tab Number 2, and do
16 then we are in the process of searching for a 16 you recognize this document?
17 replacement for Dr. Redington, and then I will, upon 17 A. Yes.
18 their hire, report to that person. So in the interim, 18 Q. Have you reviewed it?
19 to Melissa. 19 A. Yes.
20 Q. And have you ever been deposed before? 20 Q. And you are prepared today to testify on topics
21 A. I have not. 21 one, two, nine, ten, and 11, and parts of four and five;
22 Q. And do you understand, generally, the purpose of 22 is that correct?
23 why we're here today? 23 A. Correct.
24 A. I believe so. 24 Q. And have you read all of these topics previous to
25 Q. Okay. And you understand that you're here both 25 coming to this deposition?
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1 A. Yes. 1 A. Probably two.
2 Q. And other than speaking with your attorney, what 2 Q. Okay. I'm gonna ask you to look at the document
3 did you do to prepare for this deposition? 3 behind Tab Number 3. Do you recognize what this is?
4 A. I compiled all of my documents that I had 4 A. Yes.
5 received from you related to the suit, and I got 5 Q. What is it?
6 information from some of the staff who are direct 6 A. The Defendants' Fourth Supplemental Response to
7 reports, so that I had accurate information from them. 7 Plaintiff's First Request for Production.
8 Q. And who did you -- who specifically did you speak 8 Q. And did you review this document in preparation
9 with? 9 for your deposition?
10 A. Andy Kutcher is our Student Organization 10 A. Yes.
11 Development Coordinator. Paul Mintner is his immediate 11 Q. And did you assist the University in gathering
12 supervisor. Paul is one of the Associate Directors for 12 documents in response to this request?
13 the Center for Student Involvement and Leadership. And 13 A. Yes.
14 then just, again, a review of the documents I've 14 Q. And who are the other individuals who helped, if
15 provided. 15 any, provide documents in response to the requests in
16 Q. And when you say documents that you've provided, 16 this document?
17 are those documents that you -- that you created or 17 A. To my knowledge, Andy Kutcher assisted. Kristi
18 documents anyone in the University created relevant to 18 Finger, Paul Mintner, Tom Baker, Lyn Redington. I
19 this lawsuit? 19 believe -- I don't know if it's in response to this or
20 A. Both. 20 other part --
21 Q. And do you know about -- approximately how many 21 Q. I'm gonna ask you not to look at the documents.
22 documents you reviewed or how many pages of documents? 22 A. Okay. Please. Okay. Um-hum.
23 A. A lot. Hundreds. 23 Q. So you're saying you're not sure if it was this
24 Q. Okay. Like, if you think about a ream of paper, 24 or other parts but --
25 was it one ream of paper? Two reams of paper? 25 A. I know the Center for Diversity and Enrichment

15 16
1 provided some information related to number -- one of 1 Q. Now, are you aware of any documents that would be
2 the Interrogatories, 4 or 5. I can't recall which one, 2 relevant to this lawsuit that have not been produced?
3 without looking at it. 3 A. I'm not aware of any.
4 Q. Okay. In the document in front of you I'd like 4 Q. I'm gonna ask you to flip now to Document Number
5 to draw your attention to documents listed as the 5 91.
6 Requests numbered 11 through 15. Do you see that they, 6 A. Excuse me. Pardon me.
7 in the Response section, all of them say, "Defendants 7 MR. CARROLL: Eric, excuse me, are we
8 will supplement"? 8 marking these as exhibits?
9 A. Um-hum. 9 MR. BAXTER: You're gonna keep the -- the
10 Q. And then -- 10 reporter already has the binder, so you're just gonna
11 MR. CARROLL: "Yes"? 11 have them behind the tabs. You will keep your binder,
12 A. Excuse me, I apologize. Yes. I apologize. 12 she'll keep her binder, and they will be marked in that
13 Q. Thank you. Documents 21 through 24. 13 way.
14 A. Could you repeat the -- 11 through -- 14 MR. CARROLL: Okay. So --
15 Q. Fifteen. 15 MR. BAXTER: They're premarked.
16 A. (Pause.) And then again, after 15? 16 MR. CARROLL: Okay. And the --
17 Q. Well, I'll represent to you there are a dozen or 17 MR. BAXTER: They're premarked.
18 more responses that say, "The University will 18 MR. CARROLL: So Tab 2 is Exhibit 2?
19 supplement." Does that mean the University is still 19 MR. BAXTER: Exactly.
20 gathering documents that will be produced in this 20 MR. CARROLL: Okay.
21 litigation? 21 BY MR. BAXTER:
22 A. I don't know that. 22 Q. I'm gonna ask you to switch that document out
23 Q. As far as you know, is anyone at the University 23 with this one. That's the wrong document. You have the
24 still searching for documents to produce in this matter? 24 complaint --
25 A. I don't know that. 25 MR. BAXTER: You gave me 24:7 in there.
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1 MR. BLOMBERG: It was corrected. 1 Q. Okay.
2 MR. BAXTER: Oh, it was corrected? 2 A. There was a document that had several -- Exhibit
3 MR. BLOMBERG: Yeah. 3 A, Exhibit B, Exhibit C. I believe this was one of the
4 MR. BAXTER: That one's corrected. You're 4 exhibits which was the first time I saw that.
5 right. 5 Q. So prior to commencing this lawsuit, you never
6 BY MR. BAXTER: 6 saw this document?
7 Q. Okay. Do you recognize that document? 7 A. Correct. This actual document.
8 A. Yes. 8 Q. Okay. I'm gonna ask you to turn to the exhibit
9 Q. What is it? 9 behind Document Number -- behind Tab 92.
10 A. It's a Confidential Inquiry Complaint Form. 10 A. I don't have a Tab 92, unless they're out of
11 Q. Concerning what? 11 sequence.
12 A. Complainant Marcus Miller filing a violation 12 Q. I'm gonna ask you to take a look at this
13 against Business Leaders in Christ. 13 document.
14 Q. And have you seen this document previously? 14 MR. CARROLL: Yeah, no -- no, you're
15 A. Yes. 15 correct. You're missing tabs.
16 Q. And when did it first come to your attention? 16 A. (Pause.) Okay.
17 A. The case or the document? 17 Q. Do you recognize that document?
18 Q. The document. 18 A. Yes.
19 A. When I received the materials. 19 Q. And what is it?
20 Q. From? 20 A. This was a communication that was sent to Hannah
21 A. From -- the University. 21 Thompson from the Office of Equal Opportunity and
22 Q. Okay. So the University -- someone at the 22 Diversity, Constance Shriver Cervantes.
23 University would have sent you this complaint form? 23 Q. And you were cc'd on that letter?
24 A. It was a -- well, it was in the -- an exhibit, I 24 A. I was.
25 believe, that I received from you all. 25 Q. And what was the purpose of that letter?

19 20
1 A. Notifying the organization, specifically Miss 1 in violation of University policy."
2 Thompson, that a complaint had been filed against 2 Q. Do you know what that language is referring to?
3 Business Leaders in Christ. 3 A. The University has an anti-retaliation policy
4 Q. And when you received that document, the 4 that issues frequently in judicial cases, so that the
5 complaint that we just looked at under Tab 91 was not 5 respondent and -- doesn't retaliate in a direct or
6 with that letter, as far as you recall? 6 indirect way.
7 A. I don't recall. 7 Q. So do you read that language to mean that if
8 Q. Okay. 8 someone -- a complaint is filed against someone, that
9 MR. CARROLL: Eric, just so the record's 9 individual cannot speak to anyone about the complaint
10 clear, can you read off the page numbers, the Bates 10 that was filed against them?
11 stamps, so that later we're not debating what we were 11 A. Well, they certainly will need to speak to the
12 talking about? 12 Office of Equal Opportunity and Diversity when they are
13 BY MR. BAXTER: 13 involved in the investigation and hearing.
14 Q. So the document that's labeled as Exhibit 92 is 14 Q. Could they speak to a lawyer?
15 Plaintiff's Production Number 27 and 28. Do you see the 15 A. I believe they have that right.
16 second highlighted language there? Could you read that? 16 Q. Okay. Could they speak to family and friends?
17 A. The second highlighted -- 17 A. I -- I don't know that.
18 Q. Yes. 18 Q. Okay. So you don't know if the University would
19 A. "Failure to maintain confidentiality may be 19 take action against them if they spoke to family and
20 regarded --" excuse me. 20 friends about a complaint that was filed against them?
21 (The reporter requested that the witness 21 A. I don't know that for certain.
22 speak more slowly.) 22 Q. Are you the person who would be responsible for
23 THE WITNESS: I apologize. I apologize. 23 enforcing that?
24 A. (Continuing) "Failure to maintain 24 A. No.
25 confidentiality may be regarded as a form of retaliation 25 Q. So who is Constance Cervantes?
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1 A. She is a staff member in the Office of Equal 1 Q. Do you know who Constance's supervisor was?
2 Opportunity and Diversity. 2 A. I believe Jennifer Modestou.
3 Q. And do you know what her responsibilities are? 3 Q. Okay. And then Jennifer Modestou would -- would
4 A. She is -- I know that part of her responsibility 4 answer to Georgina?
5 is investigative case -- investigating cases that are 5 A. I believe so.
6 given to her for investigation. 6 Q. Who is Anita Cory?
7 Q. And when you received that letter, would that 7 A. Dr. Cory, at the time, was one of the Associate
8 have triggered any action on your part? 8 Directors of the Center for Student Involvement and
9 A. No. 9 Leadership and is -- at the time had responsibility
10 Q. Well, what is the purpose of your receiving that 10 related to student organization investigations, but not
11 letter? 11 investigations of Human Rights Policies. All -- if a
12 A. Notification. 12 student organization is accused of a Human Rights Policy
13 Q. And why is it important for you to be notified? 13 violation, a complaint is filed against -- those are
14 A. Because, depending on the outcome of the 14 automatically adjudicated -- investigated by the Office
15 investigation, I may or may not be involved in 15 of Equal Opportunity and Diversity.
16 resolution. 16 Q. And so Anita wouldn't have had a role in that?
17 Q. Okay. Other individuals cc'd on the letter 17 A. Not in the -- she would not be responsibile for
18 include Georgina Dodge. Who is Georgina? 18 directing the investigation.
19 A. Georgina Dodge, at that time, was the 19 Q. What would her responsibility be?
20 University's chief diversity officer, and Equal 20 A. The adjudicator could involve Dr. Cory, and I --
21 Opportunity and Diversity reported -- reports though 21 believe -- there was the -- I apologize. If Dr. Cory
22 that office, to that person. 22 was involved in the conversation with Constance -- was
23 Q. Would she have been Constance's direct 23 related to BLinC or 24:7. I can't recall which or both.
24 supervisor? 24 Q. She was involved with both.
25 A. No. 25 A. Okay.

23 24
1 Q. So Anita Cory's role would have been only if the 1 A. Communication between Kristi Finger and myself.
2 adjudicator involved her? 2 Q. Okay. I'm gonna ask you to step back now to
3 A. Correct. 3 Document 102.
4 Q. And what kind of things could she ask her to do? 4 A. Oh, excuse me.
5 A. Be part of the investigation because there could 5 Q. Do you recognize this document?
6 be some nuances related to student organizations that 6 A. I don't.
7 Dr. Cory would be able to provide context and 7 Q. Do you know whose handwriting that is?
8 understanding for that Constance could not. 8 A. (Pause.) I'm not for certain. I'm not for sure
9 Q. And when you said "adjudicator," is that 9 whose handwriting this is.
10 referring to Constance? 10 Q. Okay. Did you ever have a meeting with Constance
11 A. Correct. 11 Cervantes about the investigation of BLinC?
12 Q. And who is Susan Sayer [sic]? 12 A. Yes.
13 A. Sue Sager at the time was the faculty or staff 13 Q. Would it have happened on May 26, 2017?
14 advisor to BLinC. 14 A. There was a meeting on May 26 with Constance, and
15 Q. And do you have any knowledge about how 15 I can't recall if it was about 24:7 or about BLinC or
16 the office -- the EOD -- is it called EOD? 16 about both, but certainly one, if not both.
17 A. EOD. 17 Q. And is there a reason why you remember the
18 Q. How EOD conducts investigations? 18 specific date?
19 A. Not in specifics. 19 A. Yes, because I'd been preparing very diligently
20 Q. Do you have a Tab 94? 20 with dates and numbers, frankly.
21 A. I do not. 21 Q. You see at the top of this document, it says,
22 Q. I'm gonna ask you to look at Tab Number 104. Do 22 "Bill and Kristi." Was Kristi in that meeting with you?
23 you recognize that document? 23 A. Yes.
24 A. Yes. 24 Q. Okay. And that -- does that refer to Kristi
25 Q. And what is it? 25 Finger?
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1 A. Kristi Finger. 1 what this would have referred to?
2 Q. And what's Kristi Finger's role at the 2 A. I don't.
3 University, or what was her role at the time of this 3 Q. Okay. It says, "In advance of most recent case
4 investigation? 4 allowed groups to discriminate at leadership level, not
5 A. Kristi Finger was the Coordinator for Student 5 membership level." Do you remember what that might have
6 Organization Development. She is now one of the 6 referred to?
7 Assistant Directors for Guests and Event Services in the 7 A. I do not.
8 Iowa Memorial Union. She transitioned into that role. 8 Q. Going down, it says -- do you see where it says,
9 I can't recall exactly when she made that transition. 9 "Model constit [sic] requirements, three things actually
10 Q. In her new role, does that mean she no longer has 10 required. HR -- HR policy one of these."
11 involvement with the student groups? 11 A. Yes.
12 A. In a different -- she is involved in a different 12 Q. Does that trigger what this conversation would
13 way. She works in student organizations in the 13 have been about? I'm not asking you to speculate. I
14 reservation of space on campus, outside, and in -- and 14 just want to know if you have any recollection of what
15 within the Iowa Memorial Union. 15 happened at the meeting.
16 Q. Okay. And what -- why would -- why -- do you 16 A. Based on this note, I'm assuming that there --
17 know why Ms. Cervantes would have wanted to meet with 17 one of the requirements for -- of constitutions is the
18 you and Kristi? 18 inclusion of the University of Iowa's Human Rights
19 A. To get more context and understanding about 19 Policy.
20 student organization rules and regulations, I recall. 20 Q. Okay. Did you have any discussion about the
21 Q. Okay. This says here, "Question has arisen. 21 importance of having men's clubs, women -- a men's glee
22 Institute -- instant knowledge versus what we have done. 22 club, a women engineering club, or black student clubs?
23 Practice, question mark, none. Philosophy and 23 A. I recall part of our conversation being about
24 interpretation, historical and longstanding." Does 24 some of our student organizations that have missions
25 it -- do you know -- remember what the conversation -- 25 around -- protected classes of our Human Rights Policy.

27 28
1 Q. Okay. At that time what was your understanding 1 105. Do you recognize this document?
2 of the University's policy regarding, for example, a 2 A. Yes.
3 men's glee club? 3 Q. And what is it?
4 A. We would allow them to register. 4 A. A communication from Constance to Tom Rocklin,
5 Q. Okay. 5 William Nelson, and Tom Baker.
6 A. Allow them to function as long as they didn't 6 Q. Okay. And what was -- what is the email about?
7 violate policy. 7 A. The -- appears to be Connie's communication about
8 Q. Okay. And what -- is that your recollection at 8 the final draft of her findings related to the BLinC
9 that time of what the policy was? Without looking at 9 case.
10 the notes. Is -- is that what -- is that your statement 10 Q. And why don't you take a second and flip -- just
11 of what the policy is now or what the policy was at the 11 flip through the rest of the document -- is what's
12 time when you -- the BLinC investigation? 12 attached the draft for the BLinC -- the draft findings
13 A. The University -- the University of Iowa's Human 13 from the BLinC investigation?
14 Rights Policy on May 17th is the same as it is today. 14 A. I believe so.
15 Q. Have there been no changes since May 17? 15 Q. Okay. So back to the email. The email -- the
16 A. Since -- not -- not since this point in time. 16 next to the last paragraph in the email from Constance
17 Q. Okay. I'm gonna ask you to go back to Exhibit 17 says, "For your consideration it is the recommendation
18 104. At the bottom you see where -- where you e-mailed 18 of EOD that after this Finding is issued, BLinC's
19 Tom Baker, Tom Rocklin, Anita Cory, and Kristi Finger 19 recognition as a University organization be suspended
20 and you said, "Once the draft is finalized and issued, 20 until the violation is corrected." Do you see that?
21 the below highlighted action is recommended." Do you 21 A. Um-hum.
22 know what that refers to? 22 Q. So now looking above at your email, where it
23 A. I can't recall what I meant by "the highlighted 23 says, "Once the draft is finalized and issues --" that
24 action is recommended -- the below highlighted action." 24 refers to the Findings, correct?
25 Q. Okay. I'm gonna ask you to flip over to Document 25 A. Correct.
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1 Q. And then "the below highlighted action," does 1 Q. And when you read that email, do you remember
2 that refer to Constance's recommendation that the 2 what your response was to it before you wrote your
3 email -- that BLinC be suspended? 3 response?
4 A. Cor -- I believe so. 4 A. That could be true.
5 Q. And then looking back to Tab Number 104, am I 5 Q. And what -- did you have any thoughts about what
6 correct this is you forwarding -- or at least forwarding 6 kind of problems might arise -- or what implications
7 the email to Kristi Finger? 7 might arise?
8 A. Kristi -- yeah, communicated with me and then I, 8 A. I would -- I'm not certain I understand your
9 in turn, was communicating back to Kristi. 9 question.
10 Q. So below that at the bottom you said, "Once the 10 Q. Well, at the time you received this email, did it
11 draft is finalized," that would be -- you forwarded -- 11 trigger any thoughts, in your mind, about what
12 how did you -- she was on the original email, right? 12 implications there might be for other faith-based groups
13 A. Yes, yes. 13 if BLinC were to be sanctioned?
14 Q. And then she responded and said, "What are the 14 A. Yeah. My -- my thought was that there -- if
15 implications for our other faith-based groups that have 15 there were groups who were in violation of Human Rights
16 Statements of Faith for their student leaders?" Do you 16 Policy, then -- and there could be, and if we received a
17 see that? 17 complaint for a violation, that we would need to
18 A. Correct. 18 investigate.
19 Q. What -- what's your understanding of what her 19 Q. And do you recall, did you read the draft that
20 concern was at that time? 20 Connie sent -- reasonably promptly after she sent it?
21 A. I believe Kristi's concern was that there were -- 21 A. I -- I -- I believe I did.
22 were similar situations or could be similar situations. 22 Q. Would that have been the first time you learned
23 We hadn't received any complaints, but absent the 23 anything about the facts of the situation with BLinC?
24 complaint, she, I believe -- as I'm recalling, there 24 A. No. I believe some of the facts were in --
25 should be concern related to other groups. 25 discussed in that -- May 26th meeting.

31 32
1 Q. Okay. Do you remember what Constance told you 1 Q. So you're not aware of any comments to the draft?
2 about the facts at that time? 2 A. I can't recall. I apologize for not recalling --
3 A. I do not remember. 3 Q. That's fine.
4 Q. Okay. Was there any other time, prior to 4 A. -- but I simply can't.
5 receiving the draft, that you would have learned about 5 Q. And did you provide any written comments or oral
6 the facts of the BLinC situation? 6 responses to the draft?
7 A. I don't know. I can't recall if I had any other 7 A. I don't recall.
8 communication with Connie. I may have, but I simply 8 Q. Okay. It's not a trick question.
9 can't recall. 9 A. No, I know. I'm not -- my effort is nothing
10 Q. Okay. When you -- so prior to receiving the 10 other than an earnest effort to try to recall.
11 draft, you had no input into what -- did you have any -- 11 Q. I appreciate that. Thank you. I'm gonna ask you
12 let me start that again. Prior to receiving the draft, 12 to look at Document 106. Do you recognize this
13 did you have any input in what would have been included 13 document?
14 in the Findings? 14 A. I do.
15 A. I -- I had conversation with Connie again on May 15 Q. And what is it?
16 26. I'm not certain I can account for what she would or 16 A. This is the -- the official Finding of the formal
17 wouldn't include, based on our conversation. 17 complaint of discrimination against BLinC. Excuse me.
18 Q. And beyond that did you have any other input into 18 Q. And why would you have been -- am I correct that
19 the draft? 19 you are cc'd on this document on the last page?
20 A. I can't recall. 20 A. Yes, I -- yes.
21 Q. If you look at the email from Constance again at 21 Q. Okay. And what was the purpose -- what would
22 105 -- well, she's says, "Attached is the final draft." 22 have been the purpose of you receiving this document?
23 Do you know if anybody made any comments in response to 23 A. Given her findings that the Human Rights Policy
24 receiving the draft? 24 was violated, in my capacity as Executive Director of
25 A. I'm not certain who responded to her. 25 the Iowa Memorial Union, I am responsible, at the
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 33 34

1 resolution stage, if policy was violated and if 1 Q. And do you have any obligation, under the rules

2 sanctions are warranted. That's why she would have 2 governing -- I assume there are rules governing this

3 communicated with me. 3 process; is that correct?

4 Q. So say that again. Your responsibility at that 4 A. Correct.

5 point would be -- 5 Q. And under those rules do you have any obligation

6 A. So -- so I am the -- in the discipline of 6 to look beyond the Finding to confirm its accuracy?

7 Registered Student Organizations, it gets to a 7 A. No.

8 resolution stage, and I am involved at that stage as 8 Q. Okay. You noticed on the document behind Tab 106

9 the -- I have the authority to issue sanctions -- issue 9 at the very bottom of the page -- first page --

10 sanctions if policies are violated and sanctions are 10 A. Oh, excuse me. I'm there.

11 warranted. 11 Q. -- it says -- this is the memo from Constance --

12 Q. And so what would be the procedure you would 12 the Finding from Ms. Cervantes, correct?

13 follow upon receiving this memo? 13 A. Correct.

14 A. I would -- understand the doc -- read the 14 Q. And it says, "The following documents were

15 document, understand the document to my fullest 15 reviewed: Copy of Facebook Messenger notes of meeting

16 capability, and then would commence the resolution 16 dates, email from Complainant to Student B, email from

17 process. 17 Student B to Complainant, constitution of Business

18 Q. Okay. And how does the resolution process 18 Leaders in Christ," and so forth. There's additional

19 unfold? 19 documents on the second page, correct?

20 A. So that would involve scheduling a meeting with 20 A. Correct.

21 the student representative or representatives, allowing 21 Q. Would you have reviewed any of these documents in

22 them the opportunity to bring an advisor with them, and 22 connection with your review of the Findings and decision

23 then we would hold a meeting to -- discuss the case, not 23 to make sanctions?

24 necessarily to dispute the findings, but to discuss the 24 A. Yes, I reviewed some of them, as I recall. For

25 case. 25 sure, some of them. I can't recall all of them.

35 36

1 Q. Okay. Would they have been sent to you from Ms. 1 EOD?

2 Cervantes, or how did you gain access to them? 2 MR. CARROLL: Just so we're clear, are you

3 A. I have some. I had -- some I have access to on 3 talking about student groups?

4 my own. The constitution, for example, is available on 4 MR. BAXTER: Any kind of findings.

5 our student organization database management. Same with 5 A. Right. I would only be the recipient related to

6 our -- constitution and guidelines. I can't recall if 6 the Registered Student Organizations. In -- I can

7 Constance provided supplementary documents to me. 7 recall in my career at Iowa, three.

8 Q. So do you have any recollection of having 8 Q. And who were those pertaining to?

9 reviewed a copy of Facebook Messenger notes? 9 A. BLinC, 24:7, and UI Feminist Union.

10 A. I -- I don't recall doing that. I may have, but 10 Q. Okay. And in reviewing those three, would it

11 I don't recall. 11 have been your normal practice to ask the investigator

12 Q. Okay. Do you have a document -- and just to 12 for all the documents that were reviewed in the process

13 explain, we -- FedEx didn't get all of our documents 13 of the investigation?

14 here on time so we have a more complete binder that's 14 A. I don't believe I did that.

15 arriving. 15 Q. In any of the three instances?

16 A. Okay. 16 A. I can recall in -- it appeared to me that the

17 Q. But is there a Tab 88 in that binder? 17 relevant -- excerpts from these other -- from social

18 A. I -- goes from 85 to 91. 18 media or other documents were -- would be included in

19 Q. Okay. You have no recollection at this moment of 19 the finding. I remember there being lots of quotes,

20 having reviewed Facebook Messenger notes? 20 lots of just a direct -- you know, this particular fact

21 A. (Pause.) I -- I don't recall. I may have, but I 21 came from this particular document. I don't recall

22 simply don't recall. 22 giving a -- the -- kind of the -- the chronology of any

23 Q. Okay. Would it be your normal practice in 23 form of, like, email communication that, you know --

24 reviewing -- let me ask you this: How often do you 24 person by person by person by person, but that the

25 receive findings from an investigation conducted by the 25 relevant opinions were extracted from those -- those

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 37 38
1 kind of communications and put into the Finding. 1 A. Correct.
2 Q. So in making sanctions that's decisions, was your 2 Q. What is your understanding of what Ms. Cervantes
3 practice just to rely on the written document from the 3 found in her Findings?
4 investigator in deciding whether to issue sanctions? 4 A. That there was a violation of the University of
5 A. Primarily, yes. 5 Iowa's Human Rights Policy, that the Complainant was
6 Q. So you have made no independent effort to confirm 6 denied a leadership opportunity because he had stated he
7 whether the Finding accurately reflected the facts? 7 was gay.
8 A. Correct. I accepted the Findings from the Office 8 Q. Okay. And in -- on your recollection, was --
9 of Equal Opportunity and Diversity. 9 were there any other facts that might have called that
10 Q. And why did you do that? 10 into question?
11 A. Because they are the office charged with doing 11 A. The Findings, I know, referenced email -- I
12 so, and I -- respect their work. 12 believe email communication, in which the Res --
13 Q. Okay. So if they issue a finding of no probable 13 Respondent admitted that -- because the Respondent
14 cause in an investigation, and you receive that, what 14 offered the leadership opportunity to the Complainant.
15 would you do after that? 15 After doing so the Complainant, through his admission
16 A. If you mean no probable cause, being no policy 16 that he was gay -- she said that the student -- the
17 violation -- 17 Respondent said that she would have to get back to him,
18 Q. Correct. 18 and then a -- a period of time passed and she got back
19 A. Nothing would move forward. I won't -- I'm not 19 to the Complainant and retracted the leadership
20 involved unless there is a policy violation in terms of 20 opportunity offer.
21 action. 21 Q. Okay. I'm gonna ask you to flip to Document 108.
22 Q. Would you -- would you receive a report even if 22 A. I have 106 and then 109.
23 there were no policy violations? 23 MR. BLOMBERG: Look at the bottom.
24 A. Yes, I would. 24 A. Oh, excuse me. I apologize. I have it.
25 Q. But you would take no action after that? 25 Q. And do you recognize that document?

39 40
1 A. Yes. 1 Q. Do you see in the second paragraph, the second
2 Q. And what is it? 2 sentence, says, "Section IV (B) calls upon the Executive
3 A. May I review it quickly? 3 Director of the IMU to schedule a time to meet and
4 Q. Yes. 4 discuss the case with the student organization
5 A. (Pause.) Tom Baker's -- Tom Baker's forwarding 5 representatives before determining whether or not the
6 of the Human Rights violation being confirmed by Connie, 6 actions of BLinC's student leaders violated one or more
7 his forwarding that to me. 7 of the established rules for student organizations."
8 Q. What was Tom Baker's role in this? 8 A. Correct.
9 A. Tom Baker participated in the investigation with 9 Q. So one purpose of the meeting was to determine
10 Connie. He was involved in some part or all of her 10 whether there were grounds for a violation; is that
11 interviews with some or all of the students. 11 correct?
12 Q. Do you know what his employment relationship is 12 A. Are you referencing the meeting that occurred on
13 with respect to Ms. Cervantes? 13 September 1st?
14 A. At the time Tom was the Associate Dean of 14 Q. Well, the meeting that's referred to here. It
15 Students, and Tom had a role in -- a liaison role with 15 did happen on September 1st. So when he refers to the
16 both the Office of Equal Opportunity and Diversity and a 16 meeting, is the purpose of the meeting -- he says you
17 liaison role with the Office of the General Counsel, and 17 have to schedule a meeting before determining whether or
18 Mr. Baker will need to define that more specifically. 18 not the actions violated one of the rules, correct?
19 Q. Okay. So do you know why he would have been the 19 A. Yes. The -- our policy requires that I meet with
20 person who sent this letter to you? 20 the students.
21 A. I think that's our protocol, as a participant in 21 Q. And is one of the purposes -- what is the purpose
22 the process. Again, this -- as I reference this, this 22 of that meeting?
23 isn't a usual practice over time, so -- again, I 23 A. Again, as I referenced earlier, it's not to
24 reference, I believe, three. So saying a protocol might 24 dispute the facts at the meeting, but it is to ask --
25 not be appropriate, but he advanced the document to me. 25 give the students the opportunity to provide additional
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1 context, to ask additional questions, for me to then 1 In the very next sentence it says, "In the BLinC case,
2 share what the process looks like moving forward. 2 the student who expressed an interest in the position of
3 Q. So you wouldn't make a decision about sanctions 3 vice president self-reported --"
4 until after that meeting; is that correct? 4 (The reporter requested that the witness
5 A. Official final sanctions would occur after that 5 speak more slowly.)
6 meeting. 6 Q. (Continuing) I'll reread that. "In the BLinC
7 Q. Did you go -- would you go into that meeting with 7 case, the student who expressed an interest in the
8 an assumption of what the sanctions would be? 8 position of vice president, self-reported to the
9 A. I go into the meeting knowing that the EOD 9 interviewer that he was gay. No further discussion took
10 violated -- ruled there -- was a policy violation and 10 place between the student applicant and the group
11 sanctions could be warranted, and part of the process of 11 leaders with regard to the student's actual sexual
12 the meeting is, I believe, to get a better idea, based 12 practices."
13 on the conversation with the students, of what is 13 A. Um-hum.
14 appropriate for a sanction. 14 Q. Do you have any recollection of why Tom would
15 Q. Okay. In the last paragraph on that page you 15 have thought that was significant?
16 say, in the second sentence, it says, "The Human Rights 16 A. I don't. And I -- based on Connie's Findings,
17 Policy does not require that their creed be modified"; 17 she references additional communication between the
18 is that correct? 18 Complainant and the Respondent.
19 A. That's -- that is how that reads. 19 Q. If, in the context that's described in this
20 Q. Okay. And do you remember what that -- why he 20 letter, do you think it would have been important for
21 would have thought that was important to say? 21 there to be a discussion between the student applicant
22 A. No. 22 and the group leaders with regard to the student's
23 Q. Okay. He then says, two sentences later, "No 23 actual sexual practices?
24 further discussion took place between the student 24 A. Could you repeat that, please?
25 applicant and the group leaders --" let me start over. 25 Q. Is there a difference between -- well, Mr. Baker

43 44
1 seems to be saying that the Complainant self-reported 1 Q. Okay. And you were cc'd on this letter, correct?
2 that he was gay, correct? 2 A. Correct.
3 A. Correct. 3 Q. And the letter's dated July 14th, 2017?
4 Q. And that seems to be saying that he was denied a 4 A. Correct.
5 position in BLinC for that reason, correct? 5 Q. And the meeting you held with BLinC was on
6 A. I don't know what Tom was inferring. 6 September 1st, 2017; is that correct?
7 Q. Okay. In the second sentence he seems to suggest 7 A. Correct.
8 that there was no further discussion of actual sexual 8 Q. And so this letter came in before that meeting?
9 practices, correct? 9 A. Correct.
10 A. That's what he wrote. 10 Q. In the second paragraph, could you read that,
11 Q. Okay. And do you read that to say that he thinks 11 please, to yourself?
12 there should have been? 12 A. Yes. To myself?
13 A. Again, I don't know what his intent was, but I, 13 Q. Please.
14 as I shared, I recall from Connie's Finding and the 14 A. (Pause.) I have read it.
15 materials in the Finding, that there were subsequent 15 Q. Okay. What's your understanding of what Mr.
16 conversations between the Complainant and the 16 Estell was trying to express?
17 Respondent. 17 A. Frankly, I was a bit confused with that paragraph
18 Q. Okay. I'm gonna ask you to look at 18 because I know that the communication between the
19 document exhibit -- or the document behind Tab 109. 19 Complainant and the Respondent did not involve Jacob
20 A. (Nodding.) 20 Estell. It was between -- I don't know if I can say the
21 Q. Do you recognize this document? 21 name or not, but it was -- the Respondent who was named
22 A. I do. 22 initially, the then-president, and so the communication
23 Q. Okay. What is it? 23 that occurred that we were talking about earlier between
24 A. A communication from, I believe -- yes, Mr. 24 the then-president of the student organization BLinC and
25 Estell to Dean Redington. 25 then the -- Complainant.
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1 Q. And you see on the second page with Jacob's 1 A. Oh, excuse me. Yes. Correct, I apologize.
2 signature, it says "President, Business Leaders in 2 Q. "The student was not eligible to be a leader in
3 Christ"? 3 BLinC only because he stated that he disagrees with, and
4 A. Um-hum. 4 would not try to live by, BLinC's Christian principles,
5 Q. And you're aware that he became the president 5 which means he would not effectively lead our group,"
6 after Hannah Thompson, who was the original president, 6 correct?
7 correct? 7 A. That is what it -- that's what he wrote.
8 A. Correct. 8 Q. Do you understand the distinction of what Jake
9 Q. And that he would have had authority to speak on 9 was trying to make there?
10 behalf of BLinC, correct? 10 A. I think he was -- I'm not certain -- but I
11 A. Correct. 11 believe he was trying to state that the Complainant was
12 Q. And what's your understanding then of what he was 12 not categorically denied the opportunity because he
13 trying to express in the second paragraph? 13 admitted to be gay. Rather he was denied the
14 A. He was stating that the group did not 14 opportunity because he wouldn't live by BLinC's
15 discriminate against the Complainant based on sexual 15 principles.
16 orientation, but the original communication, involving 16 Q. And if that were true, would that have violated
17 Hannah Thompson, directly did so. 17 the Human Rights Policy, as you understood it at that
18 Q. So the sentence starting, "The student 18 time?
19 participated in BLinC before asking for a leadership 19 A. Repeat that again.
20 position, and remains welcome to participate, even as a 20 Q. So you said that your understanding was that
21 leader, regardless of his orientation." 21 Jacob was trying to say that Marcus Miller, who was the
22 A. Um-hum. 22 Complainant, correct?
23 Q. Correct? 23 A. Correct.
24 A. Um-hum. 24 Q. That he was not denied a leadership position
25 Q. Then the next -- 25 because of his sexual orientation?
47 48
1 A. Correct. 1 Leaders in Christ's Statement of Faith, and in the --
2 Q. But rather that he was denied a leadership 2 Doctrine of Personal Integrity, there's a connection
3 position because he disagreed with BLinC's Christian 3 between the two.
4 principles; is that correct? 4 Q. Now, that statement was submitted to the
5 A. Correct. 5 University after the September 1st meeting, correct?
6 Q. If that statement were true, that Mr. Miller was 6 A. The -- the updated statement that included the
7 denied a leadership position only because he refused to 7 Doctrine of Personal Integrity was submitted after, yes.
8 live by BLinC's Christian principles, would that have 8 Q. Okay. And do you recall that that statement did
9 violated the Human Rights Policy? 9 not exist in the constitution prior to the September 1st
10 A. Yes. 10 meeting?
11 Q. Why? 11 A. Correct, it was added after.
12 A. Because it would be discriminatory based on his 12 Q. So on July 14th that statement was not in the
13 sexual orientation. 13 constitution, correct?
14 Q. So he just -- Mr. -- Mr. Estell just says, right, 14 A. Correct.
15 that he was -- only denied a leadership position because 15 Q. So just, hypothetically, if Marcus Miller were
16 he disagreed with Christian principles. Doesn't say 16 not gay but indicated that he did not agree with BLinC's
17 anything about sexual orientation. If he had been 17 Christian principles and was denied a leadership
18 denied the position just because he refused to abide by 18 position for that reason, at that time, as you
19 the Christian principles of BLinC, would that alone have 19 understood the policy then, would that have violated the
20 been a violation of the Human Rights Policy, as you 20 Human Rights Policy?
21 understood the policy at that time? 21 A. No.
22 A. Yes. 22 Q. So it was simply because the belief that Marcus
23 Q. Why? 23 Miller disagreed with -- concerned homosexuality, that
24 A. As I -- as I stated, because it references 24 you believe there was a violation?
25 that -- the -- I'm trying to think back to the Business 25 A. I believe there was a violation because he
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1 admitted to the then-president that he was gay, and the 1 communication, yes.
2 offer for the vice president position was retracted 2 Q. And do you have any reason to think that that
3 after he made the admission. 3 email was -- or that the letter was dated incorrectly?
4 Q. Hypothetically, if Mr. Miller was not gay, but 4 A. No, no.
5 simply disagreed with BLinC's Christian views on 5 Q. And at 110 -- Tab 110, what's your -- what's your
6 homosexuality, and was denied a leadership position for 6 understanding of what this is?
7 that reason, would that have violated the Human Rights 7 A. This is a communication from Lyn -- Dr. Lyn
8 Policy? 8 Redington, the then-Dean of Students and Assistant Vice
9 A. No. I apologize. That took me a while to -- 9 President for Student Life, sharing that with me. I --
10 connect. 10 frankly, the -- I think this was sent to Lyn in error
11 Q. That's fine. Thank you. Okay. I'm going to ask 11 because the process didn't require the student to
12 you -- to look at the document numbered 110. Do you 12 send -- I think -- I believe the student was under the
13 recognize this document? 13 understanding that he should communicate with the Dean.
14 A. Yes. 14 And I think that was just a simple -- I'm assuming that
15 Q. And this email is dated the same day as the 15 was just a simple error on Jacob's part and that the
16 letter from Jacob Estell, correct? 16 commun -- so she was simply sending that to me as -- a
17 A. Correct. 17 note that this was -- again, the resolution -- I begin
18 Q. And that letter from Jacob Estell was sent to you 18 the resolution stage. Dr. Redington is involved in the
19 via email; is that correct? 19 appeal stage, so she's getting it to me because I'm the
20 A. I was -- if I'm understanding, it was copied on 20 next step.
21 the letters you sent to Dr. Redington. 21 Q. Okay. And so she was basically just forwarding
22 Q. Correct. And you would have received that -- if 22 Jacob's letter back to you, and she says, "I believe
23 the letter is accurate, you would have received that on 23 BLinC can appeal the sanction, not the Finding." Is
24 July 14, correct? 24 that true?
25 A. Correct. Yes, I was copied on that 25 A. Correct.

51 52
1 Q. And then she says, "I can guess how he saw the 1 confusing the resolution stage with the appeal stage.
2 report which precipitated this letter, but that doesn't 2 Q. Okay. I'm gonna ask you to look at Document 111.
3 really matter." Do you know what she's referring to 3 Do you recognize this document?
4 there? 4 A. I don't.
5 A. I do not. 5 Q. Okay. It's dated the same -- it's also dated
6 Q. And in the appeal to Lyn Redington, as far as you 6 July 14, 2017, correct?
7 understand the procedures, is there a process there 7 A. Um-hum.
8 where a student organization could contest the factual 8 Q. And -- can you answer "yes" or "no"?
9 findings? 9 A. Excuse me. Yes. I apologize. Yes.
10 A. I believe -- again, this is probably a more 10 Q. Thank you. It then says, "Lyn, Met on
11 appropriate question for Connie -- but the Findings 11 Wednesday," and then there's a list of people with Bill,
12 again are a part of the EOD process, and there -- I 12 Tom, Bill, and so forth, correct?
13 believe there's a process to challenge the finding at 13 A. Um-hum.
14 that level. 14 Q. So this -- if you -- was that a "yes" or "no"?
15 Q. So once it gets to you, as far as you know, no 15 A. Yes.
16 one looks beyond the findings? 16 Q. Okay. And on July 14th -- that was a Friday,
17 A. Correct. 17 July 14, 2017 -- I'll represent to you that was a
18 Q. Did you have any further discussion with Lyn 18 Friday. So Wednesday would have been two days before
19 Redington about Jake's letter? 19 that, correct?
20 A. Yeah, we may have talked about the next line. 20 A. Correct.
21 Again, I think part of Lyn's urgency in getting the 21 Q. And do you recall this meeting? This would have
22 document to me was, again, knowing that she had a role 22 been two days then before you received the letter --
23 in the appeals process, that -- wanting to get it to me 23 A. Right.
24 to begin the resolution process quickly -- or not 24 Q. -- from Jake.
25 necessarily quickly -- but just so that we weren't 25 A. I'm not able to place this in any kind of
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1 context. I apologize. 1 the -- I -- a short time -- I can't -- I'm not for
2 Q. It says, "Letter re sanctions will come from 2 certain of the length of time of her tenure, but it was
3 Bill," correct? 3 short. I believe that this is some form of an
4 A. Correct. 4 explanation that -- again, that the resolution and
5 Q. Or J.T. Timmons? 5 sanctions happen from Bill and J.T. and not from her,
6 A. Correct. 6 which could be the reference related to the whole notion
7 Q. Who's J.T. Timmons? 7 why Jake had sent that note to her because he wrote in
8 A. That's what's confusing. J.T. Timmons is the 8 that note to Lyn, I remember, "That my understanding is
9 Director of Recreational Services, and so J.T. has a 9 you, Dr. Redington, do sanctions," and that's not
10 role that's parallel with my role when it involves 10 correct. So I'm not -- I don't know whose handwriting
11 sports clubs. That's why I'm a bit confused on how J.T. 11 this is. But I'm thinking that this is a cryptic
12 is brought into this, because J.T. -- Bill Nelson, I, do 12 explanation to Lyn that she doesn't manage the
13 resolution related to Registered Student Organizations. 13 resolution and sanctions part, that she manages the
14 J.T. Timmons does resolution related to sports clubs. 14 appeals process.
15 Q. Okay. Do you ever -- do you remember ever being 15 Q. Okay. And then you see below that it says,
16 in a meeting with J.T. Timmons about the BLinC 16 "Waited on sanctions until 24:7." Do you see that?
17 investigation? 17 A. Um-hum.
18 A. I don't. 18 Q. Is it fair to assume that "Waited on sanctions,"
19 Q. This refers to sanctions, though, correct? Do 19 that means that you were waiting on sanctions for BLinC
20 you see where it says, "Letter re sanctions will come 20 until 24:7?
21 from Bill"? 21 A. I don't know what that means. I apologize.
22 A. Yeah, I'm making a -- an assumption, that this is 22 Q. Okay. I'm gonna ask you to look at Document 112.
23 somewhat of an explanation to Lyn about our process. 23 Do you recognize this document?
24 Lyn was new. Lyn's -- only served in the role of Dean 24 A. From -- not from the original -- not from 7/19
25 for less than two years. So this would have been on 25 but perhaps in the document production process. I --

55 56
1 Q. Okay. You have no original recollection -- you 1 weren't communicated to BLinC until after our --
2 don't know whose handwriting this is? 2 September 1 meeting. I believe September 13.
3 A. I don't. I -- I don't. 3 Q. In your mind, by this time had you already
4 Q. Okay. And it refers to the BLinC appeal. This 4 settled on sanctions?
5 was five days after the last note, correct? 5 A. No.
6 A. Um-hum. 6 Q. How do you know that, or how do you remember
7 Q. And it says, "BLinC appeal," correct? 7 that?
8 A. Um-hum. Yes. 8 A. Because I hadn't spent time with the students
9 Q. Thank you. 9 yet.
10 MR. CARROLL: I know. It's hard. 10 Q. Okay.
11 A. Yes. I apologize to you. 11 A. This -- oh --
12 Q. Then it says, "Drafter: Draft brief email to 12 Q. Go ahead.
13 Jacob to -- have to outline sanctions. First will come 13 A. Reading this confirms my speculation about the --
14 from Nelson," correct? 14 previous page -- was again, someone needed to
15 A. Um-hum. 15 communicate -- someone was instructing Lyn to
16 Q. Told to -- is that a "yes" or "no"? 16 communicate to Jacob that I'm the next step in the
17 A. Yes: 17 process, not her --
18 Q. "Told to wait on sending Bill Nelson letter," 18 Q. Okay.
19 correct? 19 A. -- which was what I was stating earlier.
20 A. Correct. 20 Q. Thank you. I ask you to look at Tab 113.
21 Q. Had the sanctions already been decided by this 21 A. I -- I don't have 113.
22 time? 22 Q. I am gonna ask you to take a look at what I am
23 A. No. 23 gonna hand you as a document that's behind Tab 113. Do
24 Q. How do you know that? 24 you recognize that document?
25 A. Because I issue the sanctions and the sanctions 25 A. Yes.
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1 Q. And what is it? 1 Miller, would you have produced it in this case?
2 A. It's a communication from Marcus Miller to Lyn 2 A. If there -- if there was an email from me to
3 Redington; Marcus asking to schedule a meeting with 3 Marcus, I would have produced it. I can't recall there,
4 Dr. Redington. 4 if I did or not.
5 Q. And then what does the top half of the email say? 5 Q. Okay. Would you -- are you willing to
6 A. Related to -- oh, a communication from Lyn asking 6 double-check your email to make sure you haven't emailed
7 me to respond to Marcus' previous request. 7 Marcus Miller?
8 Q. And did you respond to Marcus Miller? 8 A. I can, yes.
9 A. I don't know if I did or not. 9 MR. BAXTER: Okay. Counsel, I'll follow up
10 Q. Did you ever have any direct communications with 10 with you on that. No further questions on that
11 Marcus Miller? 11 document.
12 A. No. 12 A. If I were to follow up with him, it was simply to
13 Q. You never emailed him? 13 acknowledge Lyn asked me to do so, but -- yeah, I don't
14 A. I have never spoken to Marcus. I've never met 14 recall.
15 Marcus. I may have emailed him. 15 Q. So is there any reason why you wouldn't have
16 Q. Is there any -- why would you have emailed him? 16 reached out to him when she specifically asked you to?
17 In what circumstances might you have emailed him? 17 A. I -- again, if I would have reached out to him, I
18 A. I can say I might not have emailed him simply 18 would have just been acknowledging that the case -- the
19 because of his role, and then me needing to meet with 19 case is still pending and not resolved. I simply don't
20 the students. 20 recall if I did. That's why I -- what I would have
21 Q. Did you -- when you searched your emails -- did 21 said.
22 you search your emails in response to document 22 Q. Okay. We've been going a little over an hour.
23 production -- 23 Do you want to take a short break? Are you okay if we
24 A. Yes. 24 go on?
25 Q. -- issues? If there were an email to Marcus 25 A. I am okay to keep going a little bit.

59 60
1 Q. Okay. And you mentioned previously the meeting 1 Q. And had you communicated with Tom before going
2 that took place on September 1st, 2017, correct? 2 into the meeting?
3 A. Correct. 3 A. Yes.
4 Q. And can you remind me what was the purpose of 4 Q. And was that communication via email?
5 that meeting? 5 A. I know we had face-to-face communication.
6 A. Yes. The purpose of the meeting was to -- I -- I 6 Q. Do you recall if there were any email
7 wrote the students. Well, my secretary was -- attempted 7 communications?
8 to schedule meetings through the -- the month of August, 8 A. There -- there could have been. Could have been
9 several outreaches from my secretary to Jacob. He 9 about process and flow. There could have been
10 responded. We met on the -- 1st of September. I 10 communication, yes, electronic communication.
11 believe I communicated both to you and to Jacob about 11 Q. Okay. There have been no such emails produced.
12 the -- the flow of the meeting. I did so at the end of 12 Will you recheck your email and find me such emails?
13 August related to that, but it was, again, to -- hear 13 A. I will. As I share, I definitely remember
14 the facts of the case, as presented by Mr. Baker, in 14 face-to-face communication. Tom's office is directly
15 general, to allow the students to ask questions, make 15 down the hall, and so a lot of our -- majority of our
16 additional comments. Again, I -- I believe I was clear 16 communication is face-to-face.
17 in the August communication that this was not about 17 Q. And what was the substance of those discussions
18 disputing the findings, and so the meeting happened on 18 concerning the September 1 meeting or the -- BLinC
19 September 1st. 19 finding?
20 Q. Okay. Why was Tom Baker there? 20 A. Process, his role, finding the appropriate time
21 A. To share the Findings on behalf of EOD. 21 for the meeting. Yeah, meeting flow, what he would be
22 Q. Okay. He was there as a representative of EOD? 22 doing which would be again presenting the facts, so the
23 A. I didn't -- I don't -- I can't say that. I know 23 meeting flow.
24 that he was the University official that was sharing the 24 Q. Did you have any discussion about Tom's personal
25 information. 25 views about the findings?
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1 A. His personal views, no. 1 MR. CARROLL: Excuse me. Just so I'm clear,
2 Q. And did you ever express your own personal views 2 what meeting are we talking about?
3 to Tom? 3 MR. BAXTER: This is the September 1st --
4 A. No. 4 MR. CARROLL: Okay. Just so you understand.
5 Q. Did you have any personal views about the 5 THE WITNESS: Yes, yes. This -- yes. Thank
6 findings? 6 you.
7 A. (No response.) 7 BY MR. BAXTER:
8 Q. What were your personal views? 8 Q. The meeting that took place on September 1st,
9 A. Personal views were -- I accepted the Findings 9 2017. And who was at that meeting?
10 from EOD. 10 A. Tom Baker, myself, two students, and --
11 Q. Did you have any personal views about the actions 11 Q. Do you remember their names?
12 that BLinC had taken, that were the subject of the 12 A. Yes. Jacob Estell, Brett Eikenberry, and then
13 investigation? 13 you, Mr. Baxter, and I believe Mr. Blomberg.
14 A. Any -- personal views, I -- I think about 14 Q. Mr. Blomberg, correct?
15 professional views, in my professional context, and my 15 A. Blomberg, excuse me.
16 personal views and my professional views align. I -- 16 Q. Um-hum. Do you recall at that meeting that early
17 again, based on the Findings from EOD, I believe that 17 in the meeting Tom raised that issue, do you recall,
18 there was a -- a violation. 18 that Christian Legal Society, the CLS, had been allowed
19 Q. Okay. Did you and Tom have any disagreements 19 to maintain registered status even though it had
20 about what would happen in the meeting? 20 requirements in its constitution that forbade sexual
21 A. I don't believe so. 21 relationships outside of marriage?
22 Q. Do you recall the substance of what happened in 22 A. Yes.
23 the meeting? 23 Q. In fact, at that meeting Tom said that groups can
24 A. In generalities, yes. 24 require leaders to be abstinent outside of the
25 Q. Okay. Do you recall -- 25 institution of marriage, that the focus needs to be on
63 64
1 that need to ask about sexual relationships outside of 1 outside of any marriage would be permissible?
2 marriage; do you remember that? 2 A. If applied universally, to all.
3 A. I remember the -- the -- the subject being 3 Q. Would a religious requirement that leaders
4 that -- as long as the requirement is both to those who 4 abstain from homosexual sexual relationships be
5 identify as homosexual and those who identify as 5 acceptable?
6 heterosexual. 6 A. If it was applicable to all.
7 Q. Okay. Do you recall that Tom took the position 7 Q. Okay. And do you recall Tom saying that the
8 that BLinC was distinguishable from the CLS situation 8 University could not tell an environmental organization
9 because BLinC failed to ask follow-up questions about 9 that it had to allow a climate denier to be -- I'm
10 Marcus Miller's practices or whether he was involved in 10 sorry. Do you recall Tom saying that the University
11 a sexual relationship? 11 would not -- could not tell a student group focused on
12 A. I believe Tom stated something of that general 12 environmental issues to have a climate denier as its
13 nature. 13 leader?
14 Q. So you and Tom both agreed that it would be okay 14 A. I recall Tom using the -- this analogy of that
15 for a student group to require its leaders to abstain 15 nature.
16 from sexual relationships outside of marriage, correct? 16 Q. Okay. So at the time of that meeting it was the
17 A. If it applied to both heterosexuals and 17 University's policy that groups could require their
18 non-heterosexuals. 18 leaders to embrace the group's mission; is that correct?
19 Q. Okay. So a religious requirement to abstain from 19 A. Say that again.
20 marriage outside -- to abstain from sexual relationships 20 Q. Is it permissible for a student organization at
21 outside of marriage between a man and a woman -- or 21 the University of Iowa to require its leaders to embrace
22 outside of marriage would be okay? 22 the mission of the organization?
23 A. Say that again, please. 23 A. Yes.
24 Q. A requirement for leaders -- a religious 24 Q. Okay. And can that requirement be written into
25 requirement for leaders to abstain from sexual activity 25 the constitution?
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 65 66
1 A. Yes. 1 Q. And that that religious philosophy included
2 Q. Okay. And can the leaders be required to sign a 2 beliefs that homosexual -- or that sexual conduct
3 statement affirming that provision of the constitution? 3 outside of marriage between a man and a woman is sinful,
4 A. Yes. 4 correct?
5 Q. Do you recall that -- that Jake and Brett, who 5 A. Correct.
6 were at the meeting, contested the investigators' 6 Q. And if they had been correct, if you were
7 Findings during the meeting? 7 reviewing -- let's say you had authority to review the
8 A. I don't recall if they did it or you did it. I 8 findings and you believed what they said, would you have
9 remember there being a contest. 9 issued sanctions against BLinC?
10 Q. Okay. And do you remember what the contest was? 10 A. I would not have as long as they didn't violate
11 A. I -- I think we've -- not specifically. But I 11 the University of Iowa's Human Rights Policy.
12 believe it was around what we've discussed earlier, the 12 Q. Okay. And if they were correct, they wouldn't
13 notion about the claim of -- the student being given a 13 have been violating it up to that point, correct?
14 leadership opportunity and then it being retracted 14 A. Correct.
15 because he admitted to being gay versus, I think, some 15 Q. Okay. And, in fact, at the meeting you asked if
16 of the substance that was in the communication he wrote 16 those beliefs were expressly written down somewhere; is
17 to Dr. Redington. 17 that correct?
18 Q. So basically BLinC argued, right, that they had 18 A. Correct.
19 denied Mr. Miller a leadership position because he 19 Q. And then you said it would be helpful to have
20 disagreed with religious philosophy, correct? 20 that in the group's constitution, right?
21 A. Correct. 21 A. Or in the governing documents, correct.
22 Q. And that they would have allowed anybody who was 22 Q. Okay. So you were asking them to detail their
23 gay to be a leader if they accepted their religious 23 religious beliefs in their constitution or in other
24 philosophy, correct? 24 governing documents, correct?
25 A. That's what they said. 25 A. Correct.

67 68
1 Q. And specifically you were referring to their 1 that?
2 beliefs about sexual activity outside of marriage 2 A. If there's a policy violation or a complaint, we
3 between a man and a woman, correct? 3 will.
4 A. Correct. And -- correct. 4 Q. So you only require that if there's been a
5 Q. Okay. And BLinC agreed that it would make clear 5 complaint?
6 that its leaders were expected to hold BLinC's religious 6 A. Correct.
7 beliefs, correct? 7 Q. And what exactly is the heightened requirement
8 A. Correct. 8 for groups that have received a complaint?
9 Q. Okay. And have you ever required any other 9 A. Excuse me -- here.
10 student groups to detail their religious beliefs in 10 Q. Well, you said that if there's a complaint
11 their constitution? 11 against a student group they'd have to -- you know, you
12 A. No. 12 took specific action or request -- requested specific
13 Q. Why did you ask BLinC to do that? 13 action from BLinC because they -- received a complaint.
14 A. Because they had committed a Human Rights 14 A. Um-hum.
15 Violation, and I wanted to -- moving forward, prevent 15 Q. Was that a "yes" or a "no"?
16 that so -- which was one of the reasons I issued my -- 16 A. Yes. Yes.
17 in my sanction about the clear qualifications for 17 Q. What were the -- what are the specific
18 leadership roles, as well as clear interview protocols 18 requirements that are imposed on a group that has
19 so that we wouldn't accidently, inadvertently, or 19 received a san -- a complaint?
20 perhaps on purpose ask inappropriate questions that 20 A. I -- I'm not certain I know what your --
21 could get the group -- in violation. 21 Q. So you --
22 Q. Okay. Are other -- are other groups expected to 22 A. -- question --
23 meet those same standards? 23 Q. At the meeting you asked BLinC to make changes to
24 A. Yes. 24 its constitution and you're saying now that that is
25 Q. And have you followed up with those groups to do 25 because a complaint was filed against them, correct?
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1 A. I don't think that's exactly correct. 1 from leaders and members.
2 Q. Okay. Explain what you meant to say. 2 Q. What do you say -- when you say all groups have
3 A. So, as I recall, the conversation was around the 3 that expectation, what do you -- how -- what are you
4 notion that the context -- as -- as I'm thinking about 4 basing that on?
5 it was -- I was thinking about the notion that 5 A. It's just -- I think it's just good practice that
6 students -- I'm sorry, I'm -- your question one more 6 if you're going to be a leader or a member of an
7 time. 7 organization that you be fully aware of what is expected
8 Q. Sure. At the meeting on September 1st, 2017, you 8 of you and what is expected among the leadership and
9 asked BLinC to detail its religious beliefs concerning 9 membership.
10 marriage and sexuality in its constitution, correct? 10 Q. So it's good practice, but does the University
11 A. Correct. 11 have any requirement that groups detail certain beliefs
12 Q. And you then stated that that was because they -- 12 in their constitutions?
13 a complaint had been filed against them, correct? 13 A. No.
14 MR. CARROLL: Well, that's a misstatement of 14 Q. Okay. Why did you ask BLinC to do that?
15 the record. His role was after the EOD found the 15 A. Because I thought it would be useful, moving
16 complaint to be valid. So it's not the complaint that 16 forward, to ensure ongoing compliance with policy moving
17 drove that meeting. It was the EOD Findings. 17 forward.
18 Q. Let me correct. You -- you -- you were 18 Q. BLinC had already told you, right, that they did
19 stating -- as I understand it, you were stating that you 19 not discriminate against anyone because of their sexual
20 required BLinC to detail its religious beliefs 20 orientation, correct?
21 concerning marriage and sexuality in its constitution 21 A. They had told me that, yes.
22 because of the EOD Findings against it, correct? 22 Q. And they told you that they intended to move
23 A. Not necessarily. I think it's because it's 23 forward with a standard that would require their leaders
24 really important that all student organizations have 24 to abide by their beliefs about sexual activity outside
25 very complete, thorough expectations of what they expect 25 of marriage, correct?

71 72
1 A. Correct. 1 you asked any other groups besides BLinC, including
2 Q. But that they would not categorically discrim -- 2 groups whose title indicate that they discriminate on
3 that someone who was gay could still be a leader if they 3 bases listed in the Human Rights Policy, to detail their
4 agreed with those beliefs, correct? 4 beliefs or their standards for leaders in their
5 A. Correct. 5 constitution to ensure ongoing compliance with the Human
6 Q. So was there any reason to require BLinC to put 6 Rights Policy?
7 that into its constitution? 7 A. No.
8 A. Again, to ensure ongoing compliance. 8 Q. And that time you agreed that if BLinC would add
9 Q. And have you ever required that of any other 9 that additional language into its constitution, that
10 group on campus? Just "yes" or "no." 10 that would resolve -- that would enable it to remain a
11 A. No. 11 registered group on campus, correct?
12 Q. Are you aware of groups that have in their names 12 A. I -- in my letter of sanction, I required them
13 words that would indicate that the group discriminates 13 to --
14 on the basis of sex or gender or sexual orientation? 14 Q. I'm just asking: At the meeting -- at the
15 A. Yes. 15 meeting you indicated that if BLinC would add that
16 Q. Have you asked any of those groups to detail 16 language into its constitution, that would resolve your
17 their beliefs in their constitution to ensure ongoing 17 concerns about any ongoing violation of the Human Rights
18 compliance? 18 Policy, correct?
19 A. We had -- 19 A. Correct.
20 Q. Just have you asked any of them to -- to add 20 Q. And BLinC agreed that it would do that, correct?
21 their detailed beliefs into their constitution to ensure 21 A. Correct.
22 ongoing compliance? 22 Q. And then BLinC asked if there was a way to
23 A. We've asked them to insert the University of 23 correct the adverse Finding that they had rejected
24 Iowa's Human Rights Policy in its entirety. 24 Marcus Miller solely because of his sexual orientation;
25 Q. Okay. I'm gonna ask the question again. Have 25 do you remember that?
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1 A. Yes. 1 A. That she would have access to their file and
2 Q. And Tom explained that there was an opportunity 2 their file could have that in there.
3 to appeal to correct the Finding, but that -- that if 3 Q. Okay.
4 BLinC elected not to appeal, it could submit a statement 4 A. Whether or not -- the merit she gave that, that
5 in the record -- that that didn't mean the University 5 would be Lyn's --
6 would correct the record, but that the statement would 6 Q. Why wouldn't you have considered the same thing?
7 be there; do you recall that? 7 A. Because I accepted the Findings from the EOD.
8 A. I recall that, correct. 8 Q. Okay. Why would you expect the appeal from your
9 Q. Okay. So at that time it was your understanding 9 sanctions to review the Finding of the EOD, but not your
10 that on the appeal BLinC could contest the factual 10 own sanctions decision?
11 findings of the investigation; is that correct? 11 A. Again, I think it's -- what Mr. Baker said, they
12 A. They could submit a letter countering that to be 12 had the opportunity to submit that. The merit that Lyn
13 part of their file. 13 Redington would give, that would be up to her.
14 Q. Okay. And so you would have expected Lyn 14 Q. Okay. In the policies that govern this
15 Redington to review their -- their allegations and the 15 procedure, is there anything written that would protect
16 factual record that was developed by Constance 16 the right to the student group to contest the factual
17 Cervantes; is that correct? 17 finding?
18 A. Would I have expected that? 18 A. Again, I think the context of the factual
19 Q. Yes. 19 findings happens at the EOD investigation. That's where
20 A. I think Lyn would have -- as my boss, I don't 20 the Findings are derived and issued, and so -- again,
21 know if I would have expected that of her. It seemed 21 I -- that's a really good question for Connie, but I --
22 like that's what she should do. 22 I believe that is an opportunity to appeal the Findings
23 Q. Okay. So you think there should be a -- you 23 of EOD.
24 didn't expect to review the factual findings, but you 24 Q. But when you receive findings, they come directly
25 expected that, on appeal, she would; is that correct? 25 from Connie to you, correct?

75 76
1 A. In the -- the three occasions over my 15 years. 1 Q. But in -- but in all three instances the findings
2 Q. So as far as you know, on those three occasions 2 came directly from the investigator to you, correct?
3 there was no one above Connie who was reviewing her work 3 A. Correct.
4 before it came to you? 4 Q. And would you agree that there's a problem if the
5 A. I can't speak to that. I don't know for certain. 5 findings go directly from the investigator to you, and
6 Q. But in your experience with the three you've 6 you impose a sanction without reviewing the underlying
7 received, you've never seen that in the process? 7 facts?
8 A. What in the process? 8 A. My assumption is that if the students are
9 Q. That there was a review at EOD of -- of the 9 disputing the facts, they will appeal the decision of
10 investigator's findings? 10 EOD.
11 A. Again, I'm not following that. 11 Q. And you think they have a decision within the
12 Q. Okay. In the -- you said that you had received 12 EOD -- they have an avenue within the EOD to appeal
13 three findings from EOD, correct? 13 that?
14 A. Correct. 14 A. I think so.
15 Q. Concerning student groups? 15 Q. And you think that they would have received
16 A. Correct. 16 notice of that opportunity?
17 Q. And you haven't received any other findings from 17 A. I believe so.
18 them? 18 Q. And if that opportunity did not exist, would you
19 A. Correct. 19 agree that that's problematic?
20 Q. And was Constance the investigator in all three 20 A. Yes.
21 of those? 21 Q. Because that would deny students of the right to
22 A. She was in BLinC. She was in 24:7. The UI 22 have their facts and circumstances reviewed, correct?
23 Feminist Union, I believe there that was -- I think 23 A. Correct.
24 perhaps Wanda -- I can't think of Wanda's last name -- 24 Q. Okay.
25 was the investigator. 25 MR. CARROLL: Why don't we take a break?
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1 MR. BAXTER: This is a great time. 1 when you were in the meeting you indicated that it would
2 (A recess was held from 10:27 a.m. until 2 be okay for BLinC to -- in fact, you asked BLinC to
3 10:35 a.m.) 3 include its beliefs about marriage in its constitution,
4 MR. BAXTER: Okay. Go on the record. 4 correct?
5 BY MR. BAXTER: 5 A. Correct.
6 Q. Okay. We were just talking about the meeting 6 Q. And a statement that all students had to abstain
7 that took place on September 1st, 2017, correct? 7 from marriage out -- abstain from sexual relationships
8 A. Correct. 8 outside of marriage between a man and a woman, you
9 Q. After that meeting did you have any discussion 9 indicated would be acceptable, correct?
10 with Tom about it? 10 A. I believe so.
11 A. Yes. 11 Q. Okay. And that's because as long as it applied
12 Q. And what was the nature of those discussions? 12 to everybody, that would not categorically exclude
13 A. Just talking about appropriate sanctions, asking 13 anybody from participating in BLinC because of their
14 opinion. 14 status -- their sexual orientation?
15 Q. What was Tom's opinion? 15 A. Correct.
16 A. I think com -- similar to mine; that again, based 16 Q. And asking students just to read that and sign
17 on the fact that there was a finding -- a violation that 17 that would allow BLinC to avoid asking them directly
18 seemed like there was some appropriate restorative kinds 18 about their sexual orientation, correct?
19 of sanctions related to ongoing compliance. 19 A. I suggested or I required in the --
20 Q. And by that you're referring to the additions to 20 Q. Well, let me -- let me just ask you that
21 the constitution that BLinC agreed to make? 21 question. Just -- just asking a student leader to sign
22 A. Referring to the -- what ended up being the three 22 a Statement of Faith, that would avoid the potential for
23 sanctions that were part of my September 13th 23 presuming something about someone's sexual orientation;
24 communication. 24 isn't that correct?
25 Q. Okay. And before I get to that, just to clarify, 25 A. No.

79 80
1 Q. And why not? 1 communicate -- face-to-face communication. There could
2 A. Because they could in an interview setting ask a 2 have been. I think there was -- sorry, an email draft
3 question that was not appropriate based on the Human 3 of the -- there wasn't an email draft. It was a hard
4 Rights Policy. They -- 4 copy draft, as I recall, of his -- a review of my
5 Q. So interviews would be problematic? 5 letter.
6 A. If -- if not structured with an appropriate 6 Q. Okay. Would you make sure that that's been
7 protocol and line of questioning that would be approved 7 produced?
8 by the leadership and by the advisor -- 8 A. Okay.
9 Q. Okay. 9 Q. And we'll make a note of that. Then would you --
10 A. -- to avoid asking questions that could get the 10 were there -- did you -- would you have emailed anybody
11 group in conflict with the policy. 11 else about the meeting?
12 Q. But if all the student group did was ask students 12 A. I may have emailed Lyn to let her know that it
13 to sign a statement, if they signed it, they were 13 occurred. I can't recall exactly.
14 eligible; if they didn't, they weren't eligible for the 14 Q. Okay. And would you make sure that any emails
15 leadership position; that would be okay? 15 that are relevant were produced?
16 A. Barring no other problem. 16 A. Correct.
17 Q. Okay. Let's -- so you -- was there any 17 Q. Well, you don't go forward -- you do that after
18 disagreement between you and Tom about how to proceed 18 this session?
19 after the meeting? 19 A. Yes.
20 A. Nothing of substance that I recall. 20 Q. Okay. Did you have any conversations with anyone
21 Q. Okay. Anything minor that you recall? 21 other than Tom about the meeting?
22 A. I -- I don't believe so. 22 A. Nate Levin.
23 Q. Okay. Did you exchange any emails about the 23 Q. And who's Nate Levin?
24 meeting with Tom afterwards? 24 A. In the Office of the General Counsel.
25 A. I don't -- there was definitely personal 25 Q. Okay. Anyone else besides Nate?
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1 A. I referenced Lyn in terms of how the meeting 1 Q. Okay. I'm gonna point your attention to the
2 went. 2 first sentence in the second paragraph. It says, "This
3 Q. What did you tell her about how the meeting went? 3 investigation was conducted under the Discipline of
4 A. I felt the meeting -- I felt the meeting was a 4 Registered Student Organization Procedures found at --"
5 good meeting. 5 and then there's a website?
6 Q. Okay. And why? 6 A. Yes.
7 A. Because I felt that the students had agreed to 7 Q. So the investigation was conducted under those
8 what we had talked about in that setting and that -- I 8 procedures; is that correct?
9 was -- that was the first time I had met those students. 9 A. Yes, because investigations of Human Rights
10 I was impressed with them. So -- 10 Policy violations go directly to the office of EOD.
11 Q. Okay. When you -- in fact, when you left the 11 Q. Okay. Would you expect to find procedures for
12 meeting you turned around and said something positive to 12 appealing from the EOD findings in this document?
13 them. Do you remember that? 13 A. No.
14 A. Yes, I do. 14 Q. Okay. It would be in a separate document?
15 Q. And do you remember what you said? 15 A. Yes.
16 A. Not exactly, but something to the effect, "You're 16 Q. Okay. And do you know what that document would
17 quality UI students." 17 be?
18 Q. Okay. 18 A. It would be an EOD-related document.
19 A. Something of that nature. 19 Q. Okay. And you don't know what it is?
20 Q. Great. Thank you. I'm gonna ask you to look at 20 A. I don't.
21 Document Number 114. Do you recognize this document? 21 Q. Okay. The second paragraph, you said in the
22 A. Yes. 22 second sentence, "I find there is a preponderance of
23 Q. Okay. And what is it? 23 evidence that BLinC violated the University of Iowa
24 A. This is my communication to Jacob -- at -- at the 24 Human Rights Policy." Is that correct?
25 conclusion of our meeting on September 1st. 25 A. Correct.
83 84
1 Q. But you made that decision without looking at the 1 are not categorically eliminated from consideration,"
2 evidence directly, correct? 2 correct?
3 A. I looked at the evidence that was provided by 3 A. Correct.
4 Constance. 4 Q. And that refers to the same decision that came
5 Q. Okay. But you did not look at the -- the -- the 5 out of the meeting, correct?
6 original evidence? 6 A. In essence, yes.
7 A. Correct. 7 Q. Okay. So if BLinC inserted its beliefs in a way
8 Q. Okay. It was just Constance's summary? 8 that did not categorically eliminate anyone from
9 A. In her insertion of direct quotations, et cetera. 9 consideration --
10 Q. Then the next paragraph you say, "After 10 A. Yes. And -- and I believe that it's important to
11 consideration of the investigative report and your 11 have all kinds of qualifications that are relevant for
12 remarks, I will permit your organization to function as 12 leaders in all student organizations to be very clear.
13 a Registered Student Organization in good standing 13 Q. Okay. And that's important for all student
14 provided you comply with the following." 14 groups?
15 A. Correct. 15 A. Correct.
16 Q. "Commit to ongoing compliance with the University 16 Q. Okay. And then the third requirement was,
17 of Iowa's Human Rights Policy at all times in the 17 "Submit an acceptable plan for ensuring that group
18 future." 18 officers who interview leaders will ask questions
19 A. Correct. 19 relevant to the vision statement that are not
20 Q. And BLinC had already agreed to do that, correct? 20 presumptive of candidates based upon their sexual
21 A. Correct. 21 orientation."
22 Q. Okay. "Two. Submit a list of qualifications for 22 A. Correct.
23 leaders of your organization designed to prevent future 23 Q. Okay. And then you state that they will return
24 disqualifications based on protected categories and to 24 to good standing if they comply with that.
25 ensure that persons who identify as non-heterosexuals 25 A. Correct.
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1 Q. Okay. I'm gonna turn your attention to the 1 section that -- there was a section that was included
2 document at Tab 115, and the top line email says -- is 2 that hadn't been there before.
3 basically an email from me attaching an updated 3 Q. And do you remember -- what was that about?
4 constitution; is that correct? 4 A. Was it Section 4 on membership?
5 A. Correct. 5 Q. Well, I'll -- I'll walk you through them. I'm
6 Q. And at Tab 116, do you recognize this document? 6 just wondering what you recall --
7 A. I do. 7 A. Yeah, I remember that -- I remember there were
8 Q. And what is it? 8 some --
9 A. It is the updated BLinC constitution. 9 MR. CARROLL: Slow down a little bit.
10 Q. Okay. And did you -- who -- were you the -- did 10 THE WITNESS: Oh. Can't read my hands? I
11 you review this constitution when it was submitted? 11 apologize again.
12 A. Yes. 12 A. Yes, there were -- minor changes, major changes,
13 Q. And did anyone else review it? 13 words that were -- so minor changes, major changes.
14 A. Did -- I'd assume that other people who received 14 Q. Okay. Do you remember what the substance --
15 the communication. 15 the -- the main gist of any of those changes were?
16 Q. So Tom Baker was the only other one at the 16 Without looking at the document. I'll let you look in a
17 University. Did you ever have a discussion with him 17 minute.
18 about who would review the constitution first or -- 18 A. Yeah, yeah.
19 A. I don't -- no, I don't believe so. 19 Q. I just want to know if you remember --
20 Q. Okay. Do you remember what the major changes 20 A. Yes, the -- part of the submission also involved
21 were in the constitution when you read it? Without 21 the Statement of Faith.
22 looking at it now, do you just recall off the top of 22 Q. Okay.
23 your head what the changes were? 23 A. That was -- that went from a -- it was like a
24 A. Yeah, there were -- there were the minor changes. 24 vision statement to an actual -- I believe the title
25 There were a couple -- major changes. There was a 25 said to a Statement of Faith in which the personal -- or

87 88
1 the Doctrine of Personal Integrity was included. That 1 Q. And then I'm gonna refer you next to the last
2 was a brand-new section, but everything else remained 2 page of this Exhibit, Exhibit A. Now, is this what
3 the same -- 3 you're referring to when you said there was previously a
4 Q. Okay. 4 vision statement and now there is a Statement of Faith?
5 A. -- in that document. 5 A. Correct.
6 Q. Okay. Any other changes that stood out to you? 6 Q. And the final paragraph was added?
7 A. Again, I remember there being a section that was 7 A. Correct.
8 included. I can't recall. 8 Q. And as far as you recall, that was the only thing
9 Q. Why don't you -- why don't you look at -- 9 that was changed in this, right?
10 A. Okay. 10 A. Correct. I know there was a section about
11 Q. -- Article III, paragraph 1, and read that to 11 signature section --
12 yourself? 12 Q. Okay.
13 A. (Pause.) Yes. 13 A. -- but -- that's not -- here. That was on the
14 Q. Okay. Is this the paragraph that you're 14 one that was submitted.
15 referring to? 15 Q. So let's look at Article VI.
16 A. Yes, if that -- if that is the Doctrine of -- 16 A. Excuse me. I believe that signature statement
17 Q. This is not the Doctrine of Personal 17 was a part of both.
18 Responsibility. That's later. I'm just asking if -- 18 Q. Okay.
19 you said there was another section you thought maybe was 19 A. Yeah.
20 in membership or something. I'm wondering if this is 20 Q. I'm gonna turn your attention to -- then go back
21 what you -- 21 a couple of pages to Article VI -- it says Article VI in
22 A. I believe -- I apologize, but I believe so. 22 the constitution. Okay. And it says, "All nominees
23 Q. Okay. What -- having read this now, is there 23 must be interviewed by the President or, at the
24 anything problematic in Article III, Section 1? 24 President's direction [sic], by another Executive
25 A. (Pause.) I don't believe so. 25 Officer. Nominees must affirm that they accept and seek
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 89 90
1 to live BLinC's religious beliefs as set forth in 1 problematic in including that statement in a student
2 Article III, paragraph 1 of this constitution. If 2 constitution?
3 elected, a nominee must sign a copy of BLinC's Statement 3 A. No.
4 of Faith." 4 Q. The next statement is, "We believe God's
5 A. Yes. 5 intention for a sexual relationship is to be between a
6 Q. Okay. Was there anything -- this was -- this was 6 husband and a wife in a lifelong covenant of marriage."
7 in the BLinC constitution before, correct? 7 Is there anything problematic about including that in a
8 A. Yes. 8 student constitution?
9 Q. Okay. That's your recollection? 9 A. Yes.
10 A. Yes. 10 Q. Okay. Why?
11 Q. Okay. Is there anything problematic about this 11 A. The -- the husband and wife piece is a -- a
12 provision? 12 violation of our Human Rights Policy as it relates to --
13 A. No. 13 we allow -- it's not universal for heterosexuals and
14 Q. Then I'm going to ask you to look at the 14 non-heterosexuals, and it infers a male and a female.
15 Statement of Faith again. The Doctrine of Personal 15 Q. Okay. When we spoke before the break, you stated
16 Integrity -- and in the first line says that, "All 16 that including a statement like that in a constitution
17 Christians are under obligation to seek to follow the 17 would not be a violation, correct?
18 example of Christ in their own lives and in human 18 A. Correct.
19 society," correct? Is there anything -- any problem 19 Q. Okay. And then during the break did you speak
20 with including that in the student constitution? 20 with anyone during the break?
21 A. No. 21 A. I did not.
22 Q. Okay. The next line says, "In the spirit of 22 Q. Did you speak to your counsel?
23 Christ, Christians should oppose racism, every form of 23 A. I did not.
24 greed, selfishness, and vice, and all forms of sexual 24 Q. Okay. And now you're saying that you think that
25 immorality, including pornography." Is there anything 25 statement is problematic?
91 92
1 A. Yes. 1 Human Rights Policy for students to express that belief
2 Q. Why? 2 on campus?
3 A. Because the husband and wife piece it's -- 3 A. No.
4 federal law that allows same sex marriage, State of 4 Q. Is it a violation for students to form groups
5 Iowa, same sex marriage. 5 with other students who share that belief?
6 Q. So it's your belief that it's now illegal to 6 A. No.
7 believe that God's intention for sexual relationship is 7 Q. Is it a violation for students in that group to
8 to be between a husband and wife? 8 express that belief on campus?
9 A. I'm saying it's a protected class in our Human 9 A. No.
10 Rights Policy. 10 Q. So why is it a violation of the Human Rights
11 Q. Okay. And does your Human Rights Policy prohibit 11 Policy?
12 certain religious beliefs? 12 A. Because the notion of -- of the status piece,
13 (The reporter requested a clarification.) 13 rather than belief piece.
14 MR. BAXTER: Religious beliefs. 14 Q. This says, "We believe God's intention for a
15 A. Well, religion is -- religion is one of the 15 sexual relationship is to be between a husband and a
16 protections. 16 wife in a lifelong covenant of marriage."
17 Q. Okay. So is it okay, under the Human Rights 17 A. Um-hum.
18 Policy, for students to believe that God's intention for 18 Q. And you think that violates the Human Rights
19 sexual relationship is to be between a husband and a 19 Policy?
20 wife in the lifelong covenant of marriage? 20 A. Again, the difference between belief and status.
21 A. There is a conflict. 21 Q. What's the status here?
22 Q. Well -- is it a violation of the Human Rights 22 A. The status related to protected class in the
23 Policy for students to believe that? 23 Human Rights Policy.
24 A. To believe it? No. 24 Q. But whose status is it --
25 Q. Okay. Is it unconsti -- is it a violation of the 25 A. Sexual orientation, meaning that this implies
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1 heterosexual and -- 1 violating the law?
2 Q. But you said -- you already indicated that it's 2 A. Correct.
3 okay to state your beliefs about homosexuality or 3 Q. And that they can even form a group, right?
4 marriage or any of those things on campus, correct? 4 A. Right.
5 A. Correct. 5 Q. And they can express that as a group?
6 Q. And so the -- yeah, students have freedom of 6 A. (Nodding.)
7 speech to do that. 7 Q. So if you were to suppress this statement from
8 A. Um-hum. 8 the -- the constitution of BLinC, that would violate
9 Q. And it would be a violation of the law for the 9 federal law, right?
10 University to suppress that speech? Just students on 10 A. Yes.
11 campus -- if students on campus, expressing their 11 Q. Okay. So your earlier statement that this was a
12 beliefs about homosexuality or God's intent for 12 problematic statement was false?
13 sexuality to be between a man and a woman, any of those 13 A. Again, I think it's -- problematic in
14 beliefs, if expressed on campus, and the University 14 relationship to the Human Rights Policy as it relates to
15 tried to suppress those speech -- that speech by a 15 sexual orientation.
16 student, that would violate federal law? 16 Q. So your Human Rights Policy is in violation of
17 A. Yes. 17 federal law; is that what you're saying?
18 Q. And it would violate state law? 18 A. No.
19 A. Yes. 19 Q. How do you -- how do you explain that students
20 Q. And it would probably violate Iowa City law, 20 can express all of those views on campus individually
21 right? 21 and in groups and they can form groups and have those
22 A. Yes. 22 views, but they can't express that in their
23 Q. Okay. And you indicated that if students get 23 constitution?
24 together on campus and express those beliefs as a group, 24 A. Say that again, please.
25 that the University cannot suppress that speech without 25 Q. How do you justify your statements that students
95 96
1 are free to express these views on campus, either alone 1 A. Say -- what is consistent?
2 or in groups, that they're free to form groups around 2 Q. What we've just said -- what you just said. You
3 these beliefs -- 3 said, "Correct" at the end because it was your -- the
4 A. Um-hum. 4 questions I was -- I'm just gonna stop right there.
5 Q. -- but that they can't express them in their 5 I'll leave it there.
6 constitution? 6 The next sentence says that, "Every other sexual
7 A. They should be able to express them in the 7 relationship beyond this is outside of God's design and
8 constitution. 8 is not in keeping with God's original plan for
9 Q. Okay. And if the Human Rights Policy says they 9 humanity." Is there any -- I'm sorry.
10 can't, then the Human Rights Policy is in violation of 10 A. No, correct. That's what that reads.
11 the law, correct? 11 Q. Okay. Is there any problem with including that
12 A. Correct. 12 provision in the student constitution?
13 MR. CARROLL: I'm gonna object. Just a 13 A. No.
14 minute. You're not an attorney, so don't answer legal 14 Q. Okay. The next sentence says, "We believe that
15 questions. 15 every person should embrace, not reject their God-given
16 THE WITNESS: Okay. 16 sex." Is there any problem with including that in the
17 MR. CARROLL: You're a fact witness and 17 student group constitution?
18 you're a corporate designee -- 18 A. Well, that statement is in conflict with the
19 THE WITNESS: Okay. 19 gender identity component of the University of Iowa
20 MR. CARROLL: -- but don't answer questions 20 Human --
21 about what counsel suggests the First Amendment or Title 21 (The reporter requested a clarification.)
22 VII for the equal protection clause, right. 22 THE WITNESS: Gender identity component of
23 BY MR. BAXTER: 23 the University of Iowa Human Rights Policy.
24 Q. But these are -- that's consistent with what you 24 BY MR. BAXTER:
25 believe, correct? 25 Q. Okay. Is that because the Human Rights Policy
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 97 98
1 prohibits certain beliefs about gender identity? 1 A. "We believe every person --"
2 A. Say that again. 2 Q. Correct. "Should embrace, not reject their
3 Q. Does the Human Rights Policy prohibit certain 3 God-given sex"?
4 beliefs about gender identity? 4 A. On the face it's a violation of our -- Human
5 A. Beliefs, no. 5 Rights Policy because of the gender identity component.
6 Q. Okay. What in the statement goes beyond belief? 6 Q. Okay. So is it your position that any reference
7 A. Nothing. 7 to gender identity in the student constitution violates
8 Q. Okay. So is this statement in violation of the 8 the Human Rights Policy?
9 Human Rights Policy? 9 A. Any reference?
10 A. I think it -- I think it is. 10 Q. Yeah.
11 Q. Okay. I'm going to -- okay. I'm gonna ask you 11 A. I'm sorry. I'm --
12 to look at document -- well, let me just ask you one 12 Q. Okay. And just to be clear, when we said, "The
13 more question about that document. You've indicated 13 first sentence," I was referring to the sentence that
14 that -- there's three sentences I want to focus on. The 14 says, "We believe God's intention for a sexual
15 first one starts out, "We believe God's intention." You 15 relationship is to be between a husband and a wife in
16 indicated that that sentence is not problematic. That's 16 the lifelong covenant of marriage."
17 what you previously said, correct? 17 A. Again, I'm -- I'm --
18 A. Right, right. 18 Q. I'm just -- I'm just gonna clarify for the
19 Q. Okay. And then you said that the second sentence 19 record. On the second sentence -- starts -- - says,
20 was not problematic, correct? 20 "Every other sexual relationship beyond this is outside
21 A. (No response.) 21 of God's design and is not in keeping with God's
22 Q. That's what you said, at least before, correct? 22 original plan for humanity." And the third sentence
23 A. Okay. Yes. 23 says, "We believe that every person should embrace, not
24 Q. Okay. And then -- but the third sentence you 24 reject, their God-given sex." I have a new question for
25 think is problematic? 25 you.
99 100
1 A. Yep. 1 A. A letter from me to Jacob.
2 Q. There are a number of groups on campus that are 2 Q. Okay. And what was the purpose of the --
3 essentially support groups for students in the LGBTQ 3 A. Sorry --
4 community, correct? 4 MR. BAXTER: Sorry. What was that?
5 A. Um-hum. 5 MR. CARROLL: He looked at me. I said, "I
6 Q. And those students' constitutions express certain 6 was just yawning."
7 views about homosexuality or gender identify; correct? 7 MR. BAXTER: Oh, oh, thank you.
8 A. Correct. 8 BY MR. BAXTER:
9 Q. And is their expression of those views in 9 Q. What's the purpose of this letter?
10 violation of the Human Rights Policy? 10 A. This was my communication -- to him stating that
11 A. No. 11 they had an additional ten days to respond to my --
12 Q. But BLinC's expression of those views -- of views 12 request in the September 13th communication.
13 is in violation of the Human Rights Policy? 13 Q. Okay. So this is -- this came after you'd
14 A. The expression of the belief, no. 14 received their revised constitution, correct?
15 Q. Okay. 15 A. Correct.
16 A. The acting on the -- the expression of the 16 Q. And you state that, "Their constitution does not
17 belief, no. 17 satisfy the requirements I delineated," correct?
18 Q. Okay. So all of those three statements that I 18 A. Correct.
19 read, none of those are -- there's no problem with 19 Q. "That the Statement of Faith on its face does not
20 including those in the student constitutions? 20 comply with the University's Human Rights Policy,"
21 A. As -- as beliefs. 21 correct?
22 Q. Okay. I'm gonna ask you to look at Document 118. 22 A. Correct.
23 Do you recognize this document? 23 Q. So we've already talked about several provisions
24 A. Yes. 24 in the constitution that you already said were all
25 Q. What is it? 25 acceptable. So what in the constitution, on its face,
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 101 102

1 violates the Human Rights Policy? 1 A. No.

2 A. The sections related to sexual orientation and 2 Q. What does it stem from then?

3 gender identity. 3 A. A violation of the University of Iowa's Human

4 Q. And which sections are those? Do you want to 4 Rights Policy.

5 flip back to -- 5 Q. Okay. You say -- let's see. You say, "You have

6 A. In the personal -- in the Document of Personal 6 opportunity to make additional revisions," correct?

7 Integrity. 7 A. Correct.

8 Q. Okay. This is doc -- the Document 116. Which -- 8 Q. You don't -- do you explain anywhere what those

9 which sentences on their face violate the Human Rights 9 revisions could be?

10 Policy? 10 A. I go -- I go back to my communication of the 13th

11 A. The -- the husband and wife and a lifelong 11 referencing back that the -- the acceptable plan for

12 covenant of marriage and the God-given sex. 12 ensuring that group officers must -- or who interview --

13 Q. Okay. And a minute ago you said that it was -- 13 will ask questions relevant to Statement of Faith, but

14 there was no problem including those in the 14 are not presumptive of candidates, so directing them to

15 constitution. This letter says that they are 15 provide that.

16 problematic on their face. 16 Q. If they deleted those three sentences that we

17 A. Um-hum. 17 spoke about earlier from their constitution, would they

18 Q. How do you -- how do you distinguish that? 18 no longer be in violation of the Human Rights Policy?

19 A. (No response.) 19 A. I'm --

20 Q. You can't -- you can't really distinguish those, 20 Q. Let me -- let me restate this. If they had -- if

21 right, there's no logic in those two positions, correct? 21 they had deleted -- after receiving this letter, if they

22 A. Right. I'm -- I am getting myself very confused 22 had deleted those three sentences --

23 and I -- 23 A. Could I take a break?

24 Q. I mean, doesn't this really stem from the fact 24 Q. After this question. After this question.

25 that the University disapproves of BLinC's views? 25 A. 'Cuz my head is so -- getting myself so confused

103 104

1 at this point. 1 MR. CARROLL: Do you still want a break?

2 Q. I'll get you -- I'll give you a break. I just 2 THE WITNESS: Yes.

3 want to hear your question [sic] right now. If they had 3 MR. CARROLL: Okay. Take a break.

4 responded to this letter by deleting those three 4 (A recess was held from 11:08 a.m. until

5 sentences, would you have approved their constitution? 5 11:16 a.m.)

6 A. At this point I -- I don't want to answer that 6 MR. BAXTER: Let's go back on the record.

7 without taking a break. 7 BY MR. BAXTER:

8 Q. Because the truth is you would have accepted 8 Q. Okay. Mr. Nelson, I'm going to ask you to take a

9 their constitution if they had deleted those three 9 look at Document Number 119. Do you recognize this

10 provisions, correct? 10 document?

11 A. Again, I'd like to take a break. I'm -- 11 A. Yes.

12 anxiety -- 12 Q. What is it?

13 Q. That's okay. Mr. Nelson, you're under oath, 13 A. This is Lyn Redington's communication to -- to

14 correct? 14 yourself and to Jacob, her response to the appeal.

15 A. Correct. 15 Q. Okay. Did you have any part in drafting this

16 Q. That means you have an obligation to tell the 16 letter?

17 truth, the whole truth, and nothing but the truth -- 17 A. No.

18 A. Correct. 18 Q. Do you talk to her about it at all?

19 Q. -- correct? 19 A. No. She may have asked me some -- some questions

20 A. Correct. 20 about -- I -- again, I can't recall.

21 Q. If they had deleted those three provisions from 21 Q. Did you have any discussions with Lyn Redington

22 their constitution and sent it back to you, would you 22 about the substance of the findings against BLinC?

23 have accepted their constitution? 23 A. Ah, Constance's Findings?

24 A. Yes. 24 Q. Yes.

25 Q. Okay. 25 A. Yes.

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 105 106
1 Q. When was that? 1 A. I don't recall.
2 A. Upon -- receipt of that. 2 Q. Okay. And then do you see at the end of the
3 Q. Okay. After -- go ahead. 3 first paragraph where she says, "My review is based upon
4 A. No. 4 the written record"?
5 Q. After you received the revised constitution, did 5 A. Correct.
6 you have any substantive conversations with Constance 6 Q. So that confirms your earlier suspicion -- or I
7 about the revised constitution? 7 guess, that indicates that she wouldn't have -- to
8 A. With Constance, no. 8 your -- well, I don't need to ask that question. The
9 Q. What about with Dr. Redington? 9 next sentence says, "Upon my review of the record I
10 A. Yes, I believe I shared that -- yes, we talked 10 affirm the decision of Dr. Nelson," correct?
11 about it. I -- but it did not -- as I recall, the 11 A. Correct.
12 conversation was about the fact that it did not -- what 12 Q. And then skipping a sentence, the next sentence
13 I had requested my position was, what I had received was 13 says, "The Statement of Faith on its face does not
14 not sufficient. 14 comply with the University's Human Rights Policy,"
15 Q. Okay. And what was her response? 15 correct?
16 A. I -- "Thank you." 16 A. Correct.
17 Q. Do you remember anything else about the 17 Q. That "on its face," language is the same language
18 conversation? 18 you used in your letter, correct?
19 A. I don't. 19 A. Correct.
20 Q. Okay. Then looking at this letter, did you 20 Q. Did you have any discussion with Lyn about that?
21 review it before it went out? 21 A. No.
22 A. I can't recall for sure. She may have checked 22 Q. Okay.
23 for factual accuracy, but I -- I don't recall. 23 A. I -- I don't recall.
24 Q. Do you remember providing any edits to the 24 Q. Okay.
25 letter? 25 A. I don't believe so. You know, that was language

107 108
1 I used and she'd received my letter. 1 Q. Okay. And you were cc'd on that document,
2 Q. And I'm gonna ask you to go ahead and look at 2 correct?
3 Document Number 120. 3 A. Correct.
4 A. 120? 4 Q. Okay. I assume that you had no involvement in
5 Q. Yes. Do you have that? Does not have -- 5 the EOD investigation portion of this; is that correct?
6 A. I don't believe so. 6 A. Correct.
7 Q. Okay. Okay. We'll pass -- we'll pass on this 7 Q. Had you heard about the investigation before you
8 next point. Right before we went back on the record, we 8 received this complaint?
9 took a ten or 15-minute break, correct? 9 A. Yes.
10 A. Correct. 10 Q. And what had you heard?
11 Q. Did you talk with anyone during that -- 11 A. That it -- again, that the -- there had been a
12 A. I -- I did not. I may have mumbled. No. 12 complaint, and again, as I referenced earlier on that
13 Q. You mumbled to someone or to yourself? 13 May 26th meeting when Kristi Finger and I met with
14 A. Mumbling, myself. 14 Connie, I believe we talked about both cases.
15 Q. Okay. 15 Q. Okay. And was there any other time when you
16 A. Anxiety and sweating and -- 16 would have discussed the 24:7 situation with anyone?
17 Q. Okay. Sorry to make this a difficult experience. 17 A. Yeah. I -- I'm certain I would have talked with
18 Let's see. (Pause.) I'm gonna ask you to take a 18 my supervisor about it. Again, just in normal course
19 look -- well, let's -- do you have Document Number 81? 19 of -- supervisor/supervisee communication. Tom Baker,
20 A. Yes, I do. 20 probably given Tom's -- having historical involvement in
21 Q. Okay. And do you recognize what that is? 21 cases and -- yeah.
22 A. Yes. 22 Q. Okay. Was -- do you recall the substance of any
23 Q. What is it? 23 of those conversations?
24 A. This was Constance Schriver Cervantes' finding on 24 A. No.
25 the investigation of 24:7. 25 Q. In the normal course of dealings, what would they
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1 have been? 1 Q. -- didn't surprise you?
2 A. Update on -- part of my style in communicating 2 A. That she -- there was just insufficient
3 with my supervisor is just letting them know any issues 3 information to -- to determine whether or not -- again,
4 of importance, and so I would have definitely 4 I think we've already, I think, discussed this -- the
5 communicated that this is something that would have come 5 student's name, right?
6 to me. The depth of our discussion, I simply can't 6 Q. Marcus Miller?
7 recall. But I absolutely would have notified because 7 A. Yes, yes.
8 that's how I do my work. 8 Q. Um-hum.
9 Q. Okay. And what's your understanding of what the 9 A. The reason for his -- not being given that
10 result was of the investigation? 10 leadership opportunity, there was not a preponderance of
11 A. This investigation resulted in a finding of -- 11 evidence for her to determine if it was a policy
12 there was not a preponderance of evidence that there was 12 violation or not.
13 a violation. I -- 13 Q. Okay. So I want you to look at the second page
14 Q. Okay. Did -- did you review the -- the Findings? 14 of the -- of the Findings. And I guess it's the
15 A. Yes, I've reviewed this, yes. 15 paragraph after allegations. It says -- the fourth
16 Q. You would have read the -- at the time, had -- 16 paragraph down, it says, "Complainant was then contacted
17 did you -- when you first received it, did you read 17 by Gaskill." Do you see that?
18 the -- read it in its entirety? 18 A. Um-hum.
19 A. Yes. 19 Q. And then the second sentence says, "Complainant
20 Q. Okay. And were you surprised about the Finding? 20 met with Gaskill and advised Gaskill that he was
21 A. I was not, based on the facts that Constance 21 struggling with being gay and Christian. Gaskill told
22 presented. 22 Complainant if Complainant was openly gay, he would not
23 Q. Okay. And do you remember what the facts were 23 be acceptable as a leader in 24:7."
24 that -- 24 A. Um-hum.
25 A. Yes. 25 Q. If that were true, would that be a violation of

111 112
1 the Human Rights Policy? 1 Q. And then it says, "Complainant's answer provided,
2 A. (Pause.) Yes. 2 in part, 'I am gay and continue to wrestle with the
3 Q. That would be a violation? Okay. And then look 3 Bible actually -- with what the Bible actually teaches
4 at the next page, page three. Do you see down where it 4 on the subject of homosexuality.'" Correct?
5 says, "Complainant understood he could still be a member 5 A. Yes.
6 of 24:7, but he chose not to be"? 6 Q. Does having an application that asks those kind
7 A. Correct. 7 of questions violate the Human Rights Policy?
8 Q. And then do you see that it says that, "The 8 A. (Pause.) Could you repeat that, please?
9 application completed by Complainant indicated his 9 Q. Do you see the application question?
10 desire to be a Verve leader"? 10 A. Um-hum.
11 A. Correct. 11 Q. It's number 2.
12 Q. And then it says, "One of the questions in the 12 A. Yes.
13 application provides as follows," correct? 13 Q. Correct? Is having that question as part of the
14 A. Correct. 14 application for becoming a leader of a student -- of a
15 Q. And then it says, "The Bible's definition of 15 registered student group -- does that violate the Human
16 sexual immorality is rooted in the Greek word pornea, 16 Rights Policy?
17 which includes a wide variety of sins such as 17 A. Yes.
18 masturbation, viewing/addiction to pornography, 18 Q. But Constance found no -- no probable cause to
19 fornication, sex outside of marriage, lust, 19 find a violation, correct?
20 inappropriate relations with the opposite sex, 20 A. Because there was additional context in terms of
21 homosexuality, et cetera, 1 Corinthians 6:12-20. Where 21 student -- one of the students -- I believe a --
22 do you see those sins in your life? Have you done 22 respondent not following up with the Complainant -- the
23 anything to see God transform your life in those areas?" 23 specifics of this -- really, I think, are -- need to be
24 You see that, right? 24 Constance.
25 A. Correct. 25 Q. Okay. But you didn't do anything -- the fact
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 113 114
1 that a student organization had a provision that 1 are you asking at the time of the letter?
2 violated the Human Rights Policy, you took no action to 2 BY MR. BAXTER:
3 correct that, correct? 3 Q. I'm just asking right now, do you remember what
4 A. Correct. 4 the gist of the letter is?
5 Q. And you just let it go? 5 A. Yeah. There was an issue about whether or not
6 A. Correct. 6 the -- potential violation of Human Rights Policy -- and
7 Q. Okay. Do you have Exhibit 46? 7 failure to include part of it in the -- in the
8 A. Yes. 8 documents, as I recall.
9 Q. Do you recognize this document? 9 Q. Okay. Does it sound correct to remember that
10 A. Yes. 10 BLinC -- or that -- I'm sorry -- that CLS was concerned
11 Q. What is it? 11 about including the Human Rights Policy in its
12 A. Communication from Tom Baker to -- regarding the 12 constitution?
13 Christian Legal Society. 13 A. Correct.
14 (The reporter requested a clarification.) 14 Q. And do you remember why it was concerned about
15 THE WITNESS: Christian Legal Society. 15 that?
16 BY MR. BAXTER: 16 A. I'll have to read it and --
17 Q. And do you -- this -- this is dated February 17 Q. Do you want to just take a minute and read the
18 20th, 2004, right? 18 letter?
19 A. (Nodding.) 19 A. Please. Thank you. (Pause.)
20 Q. And you've said that you've been at the -- is 20 Q. Have you read the letter?
21 that correct? 21 A. I've skimmed the -- the last section. The last
22 A. Yeah. I arrived -- October of 2003. 22 part.
23 Q. Okay. Do you remember what was the gist of this 23 Q. Where -- where did you start skimming?
24 letter? 24 A. The middle of the second page. Page two.
25 MR. CARROLL: Excuse me. Just so I'm clear, 25 Q. Okay. After --

115 116
1 A. Would you like me to continue to -- 1 Q. And the first one says, "The University of Iowa's
2 Q. Why don't you just read the letter? 2 policies and/or procedures regarding Registered Student
3 A. Thank you. (Pause.) Okay. 3 Organizations."
4 Q. At the time the -- you've had a chance to read 4 A. Correct.
5 the entire letter, correct? 5 Q. And you are authorized to speak on that topic
6 A. Yes. 6 today on behalf of the University?
7 Q. And at the time that you received this letter, it 7 A. Correct.
8 would have been your normal practice to read it 8 Q. And then topic number 11 -- well, I won't -- I
9 carefully? 9 don't need to ask for that one. Why are you the person
10 A. Yes. 10 that can speak for the University? I mean, what -- what
11 Q. Okay. And do you remember doing that in this 11 are your day-to-day responsibilities that qualify you to
12 instance? 12 speak on this topic?
13 A. I -- I'm certain I did. 13 MR. CARROLL: Well, I'm gonna object. That
14 Q. And is there anything in this letter that you 14 isn't the requirement of the rule. You can certainly
15 disagree with from -- or as -- let me just -- let me ask 15 ask him what his day-to-day responsibilities are. We
16 you this question. Turn to Exhibit 2 quickly. And 16 can designate anybody we want, as long as they're here
17 the -- is that the Exhibit A to the -- Notice of 17 properly.
18 Deposition -- Notice of 30(B)(6) Deposition? 18 MR. BAXTER: Thank you.
19 A. Yes. Yes. 19 MR. CARROLL: So you can --
20 Q. And so you're looking at Exhibit A, correct? 20 MR. BAXTER: Let me --
21 This is the list of topics that were noticed for the 21 MR. CARROLL: -- respond.
22 deposition. 22 MR. BAXTER: Well, let me rephrase the
23 A. Correct. 23 question.
24 Q. Correct? 24 BY MR. BAXTER:
25 A. Correct. 25 Q. Do you have responsibilities in your job that
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 117 118
1 qualify you to speak on these topics? 1 Q. Okay. But as far as the Center, you have the
2 A. Yes. 2 final authority at the Center for construing the Human
3 Q. Okay. And did you have any -- did you -- what 3 Rights Policy; is that correct?
4 are those -- what are those responsibilities? 4 A. Correct.
5 A. The registration of student organizations 5 Q. Okay. And you're authorized to speak for the
6 function as a part of the Center for Student Involvement 6 University on that topic today?
7 and Leadership. The Center for Student Involvement and 7 A. Correct.
8 Leadership works up through the Iowa Memorial Union. 8 Q. Okay. Is there anything in this letter that is
9 Q. And how does that -- what -- what impact does 9 inconsistent with the Human Rights Policy?
10 that have with respect to student organizations in the 10 A. (No response.)
11 Human Rights Policy? Do they submit their constitutions 11 Q. Let me re-ask that question. As you read the
12 to you? 12 letter, was there anything that jumped out to you that
13 A. They submit the constitutions to the staff who 13 violates the Human Rights Policy?
14 administer that program. 14 A. The -- the -- the case, as I recall -- and,
15 Q. Okay. And -- and so the staff has responsibility 15 again, in reading, was that they had not inserted
16 to make sure that the Human Rights Policy is complied 16 their -- the Human Rights Policy, and then the
17 with? 17 University directed them to insert it, correct, and then
18 A. Correct. 18 in doing so --
19 Q. And if they have questions, do they go to you 19 Q. Do you remember why they were concerned about
20 or -- 20 inserting the Human Rights Policy?
21 A. They can, yes. 21 A. I'm sorry. Do I -- why --
22 Q. Okay. 22 Q. Do you remember why they were concerned?
23 A. They can, or to General Counsel's Office, or 23 A. Why Christian Legal Society?
24 historically Tom Baker has answered some of those 24 Q. Correct. Why Christian Legal Society was
25 questions. 25 concerned about putting the Human Rights Policy in their

119 120
1 constitution? 1 have any knowledge of the history of CLS and its
2 A. (No response.) 2 compliance and concerns about its compliance with the
3 Q. If you don't remember, that's fine. I just 3 Human Rights Policy?
4 wanted to know if -- 4 A. Yes, there have -- there had been.
5 A. Yes. 5 Q. And what have those concerns been?
6 Q. -- you remember why? 6 A. Related to whether or not they are operating
7 A. I don't. 7 consistent or not consistent with the University of
8 Q. All right. But at the time you would have read 8 Iowa's Human Rights Policy.
9 the letter? 9 Q. Can you remember any specific incidents that
10 A. Yes. 10 arose?
11 Q. And understood it? 11 A. Again, the -- the one related to -- again
12 A. I believe so. 12 student -- University of Iowa student government denied
13 Q. And if you disagreed with anything in it, would 13 them recognition, and then they were to include their
14 you have said something? 14 Human Rights Policy, and then they would be eligible to
15 A. I would not have attempted to overturn the 15 receive the -- benefits of Registered Student
16 decision of the -- the Vice President, and I think Tom 16 Organizations.
17 Baker was writing on behalf of the Vice President. 17 Q. Okay. And that's the ones referred to in the
18 Q. Okay. Are you aware of -- after that of any 18 letter you just read --
19 other situation involving CLS and concerns about whether 19 A. Correct.
20 it was in compliance with the Human Rights Policy? 20 Q. -- which is Document 47? Were there any
21 A. I -- one point of clarification, is at -- at that 21 incidents after that, that you're aware of?
22 point in time my role in terms of student organization 22 A. I believe so.
23 discipline was different than it is today. 23 Q. Do you remember what they were?
24 Q. Okay. But do you have any recollection -- during 24 A. There may have been another incident later on
25 all of your time at the University of Iowa -- do you 25 in -- I don't know if it was 2008, 2009, related to,
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 121 122
1 again, student government, I believe, wanting to deny 1 Q. That's okay. Okay. I'm going to move now to
2 funding. 2 Document Number 121. Or no, wait.
3 Q. Okay. And do you remember how that was resolved? 3 A. I don't have Document --
4 A. The decision was made at the student government 4 Q. Document 14. (Pause.) Is 220 in your binder?
5 level to allow funding. 5 A. Yes, it is.
6 Q. Okay. And did you review any of the docu -- in 6 (A discussion was held off the record between
7 preparation for your deposition today, did you review 7 Mr. Baxter and Mr. Blomberg.)
8 any of the documents about that? 8 BY MR. BAXTER:
9 A. Yes. 9 Q. Okay. Are you familiar with this document?
10 Q. Okay. Why -- do you remember why anybody wanted 10 A. Yes.
11 to deny CLS either registered student status, registered 11 Q. And what is this?
12 group status, or funding? 12 A. Communication from then-Vice President Rocklin to
13 A. There -- the -- the student government leadership 13 OutLaws student Organization.
14 was suggesting that they were being discriminatory in 14 Q. And what was the nature of the letter?
15 their practices. 15 A. Again, related to the challenges around student
16 Q. Well, what was the belief that they were 16 organization registration and possible disconnect with
17 discriminating on? 17 the University of Iowa Human Rights Policy.
18 A. I believe on sexual -- orientation. 18 Q. Okay. And what -- do you remember what the
19 Q. Okay. So there was -- and that incident -- I am 19 conclusion of this letter was?
20 gonna ask you to look at Document Number 53. Are you 20 A. (No response.)
21 familiar with this document? 21 Q. I mean, do you have any independent -- without
22 A. Yes, now. I don't remember it back from 2008. 22 having to look back at the document, do you have any
23 Q. Okay. I'm gonna ask you to look at Document 23 independent recollection of what these were about?
24 Number 54. Should be next in the -- 24 A. Not without reviewing this because there's --
25 A. I have 53. I don't have -- 25 Q. I understand.

123 124
1 A. -- a massive amount of documents. Incredible to 1 A. Um-hum. Yes.
2 retain all that -- 2 Q. Had a -- I have that.
3 Q. I'm just -- 3 A. SABAC is S-A-B-A-C. It's an acronym.
4 A. -- without getting confused in my own mind, and I 4 THE REPORTER: Thank you.
5 apologize for that. 5 Q. And it stands for?
6 Q. That's okay. I understand. I just want to make 6 A. The Student Allocation Budgeting Committee.
7 sure we end up both understanding where we are in this 7 Q. And do you recall an incident where SABAC had a
8 so -- but you were aware that there was a group called 8 provision where they were wanting to deny funding to CLS
9 OutLaw on campus, and what was that group's mission? 9 and groups like it?
10 A. They were -- they were affiliated with the 10 A. Correct.
11 College of Law -- gay, lesbian, bisexual, and allied 11 Q. Okay. So you're aware that there's been a
12 students affiliated with the College of Law. 12 history on campus of groups protesting CLS, correct?
13 Q. And is it fair to say that they were protesting 13 A. Yes.
14 funding going to Christian Legal Society? 14 Q. Because of its religious beliefs?
15 A. Yes. 15 A. Yes.
16 Q. And the University basically wrote a letter 16 Q. And those beliefs concerning marriage and
17 saying that it was -- the funding was constitutional and 17 sexuality?
18 appropriate? 18 A. Correct.
19 A. Correct. 19 Q. Okay. And did you ever do anything to try to
20 Q. Okay. And you're -- there was another issue -- 20 fight that kind of discrimination against CLS?
21 is it correct that -- do you recall another issue where 21 A. I remember being a part of the -- the discussion
22 one of the student -- the student -- I think it's SABACK 22 with the students at the -- at the student government --
23 [pronouncing]; is that correct? 23 student government meeting, talking about the fact that
24 A. SABAC, yes. 24 denying funding would be -- not consistent with
25 Q. SABAC? 25 University policy, and if they chose to do so the
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1 University would, as I recall, as I reflect, reverse 1 there been any change to this document in recent times?
2 that decision. 2 A. Yes, there was clarification to the document
3 Q. Okay. So you knew back in 2009 that conditioning 3 regarding fraternities and sororities. There have
4 funding based on a group's religious beliefs would be a 4 been -- that's the substantial -- and inclusion into
5 violation of the law, correct? 5 this document -- there's three sections. One is
6 A. Correct. 6 registration, one is administration, so they're in the
7 Q. And would also violate the Human Rights Policy, 7 registration section or administration section. The
8 correct? 8 inclusion of the -- the --
9 A. Correct. 9 Q. I'm gonna ask you to slow down a little bit.
10 Q. Okay. Now, I'm going to ask you to look at 10 A. Okay. The adapted -- Human Rights Policy that
11 Document 14. 11 has in -- in it the exemption related to social
12 (A discussion was held off the record between 12 fraternities and sororities.
13 Mr. Baxter and Mr. Blomberg.) 13 Q. Okay. I want you to explain that to me. When
14 BY MR. BAXTER: 14 was this amendment made?
15 Q. Okay. Do you recognize this document? 15 A. Within the last month, two.
16 A. Yes. 16 Q. Okay. So in the last month or two there's been a
17 Q. Okay. And what is this? 17 change to this policy?
18 A. It is one of the three sections of the Code of 18 A. Correct. And it's -- again, an insertion related
19 Student Life that references student organizations. 19 to the Human Rights Policy. There's no, like -- when
20 Q. Okay. And what's the purpose of this document? 20 this was printed -- yes, yes, it's a registration
21 A. To talk about the registration of student 21 section so --
22 organizations. 22 Q. What page are you on?
23 Q. Okay. And has this document -- was -- you know, 23 A. Page -- it would be the second page.
24 print -- this copy was printed some time ago, you know, 24 Q. Okay. Then the one labeled 000273 at the bottom?
25 since the start of the BLinC litigation. Is -- has 25 A. Correct. There's an additional section that has

127 128
1 been added related to fraternities and sororities, and, 1 A. I don't -- I don't know that for sure, why it
2 again, it has the -- the only difference is the 2 wasn't provided. Is it my obligation to provide the
3 exemption language related to social fraternities and 3 question? My obligation to provide it or --
4 sororities. 4 Q. You didn't -- you didn't go look for anything to
5 Q. Okay. And what is -- what is that? What is -- 5 provide them in this litigation?
6 what kind of exemption is there? 6 A. Well, again, there's been ongoing communication.
7 A. The -- Title IX exemption that's given to the 7 As I understand it, there's been supplemental
8 University allows the University to exempt -- allows 8 communication sent from the University to -- to you
9 them to have the single sex status. 9 related to updates, updates related to this, updates in
10 Q. Okay. And you've applied that to fraternities -- 10 terms of some of our enforcement practices that are
11 so is this an exemption from the Human Rights Policy for 11 different now than they were then.
12 fraternities or sororities? 12 MR. BAXTER: Okay. Counsel, will you make
13 A. This is -- this is -- the Title IX, as I 13 sure that gets produced to us?
14 understand it, is an exemption that's given to the 14 MR. CARROLL: Yeah, I'm not sure that I've
15 institution to comply with social fraternities and 15 seen it. If I have it, you have it.
16 sororities to allow them to retain their single sex 16 MR. BAXTER: Okay. I haven't seen the
17 status. 17 original old policy or the new policy from you so -- we
18 Q. Okay. So it allows fraternities and sororities 18 just --
19 to discriminate on the basis of sex? 19 MR. CARROLL: This is the old policy
20 A. Protected under Title IX. 20 (indicating).
21 Q. Okay. And we will talk about that, but what -- 21 MR. BAXTER: Well, we printed that and
22 is there any reason why this policy was not in the 22 produced it.
23 documents that were -- the updated policy? Is there any 23 MR. CARROLL: Oh, okay.
24 reason why the updated policy was not produced to us in 24 MR. BAXTER: That's our document.
25 response to the document requests? 25 BY MR. BAXTER:
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 129 130
1 Q. I'm gonna ask you to look at Document Number 11. 1 Q. Okay. And these correlate on the Document Number
2 Do you have it? 2 11 to the policies affecting student organizations,
3 A. I believe so. 3 correct?
4 Q. Go to the document that's been -- will be in the 4 A. These are the three sections within the policies
5 binder as Number 11. Do you recognize that document? 5 affecting student --
6 It's a screen shot? 6 Q. Okay.
7 A. Um-hum. 7 A. Well, policies and regulations affecting
8 Q. Do you recognize what it's a screen shot of? 8 students.
9 A. Yeah, it's related to our OrgSync platform, I 9 Q. Okay. So if I told you that I clicked on the
10 believe. 10 6/22/2018 date on Document 11, and it brought down this,
11 Q. Okay. And do you see the column on the right? 11 that would --
12 It says something about 6/22/2018 -- can you read that? 12 A. Yes.
13 A. 6/22/18, um-hum. 13 Q. That would make sense, right?
14 Q. What do those two entries say that have that 14 A. Yes. Some of our -- yes, there has been
15 date? 15 substantial work in the last several months about making
16 A. Registered Student Organization Constitutional 16 certain that our policies/procedures are -- are clear,
17 Standards and Guidelines. 17 and so that we can be consistent in our enforcement of
18 Q. Okay. And what does the second one say? 18 policies and procedures.
19 A. That was the second one. The first one says 19 Q. Okay. And which one of those three is the one
20 Policies Affecting Student Organizations. 20 that has the fraternity -- the exception for
21 Q. Okay. And turn to Document 12. 21 fraternities and sororities?
22 A. I don't have 12. 22 A. Now? The A.
23 Q. Okay. Do you see this breakdown where it says A, 23 Q. A? Okay.
24 B, and C? 24 A. Registration.
25 A. Those are the three sections I referred to. 25 Q. And then what's this second one down here that

131 132
1 says "Registered Student Organization Constitution 1 Q. I'm sorry -- on Document 12?
2 Standards and Guidelines"? 2 A. Yes, yes, yes. Corresponds with B.
3 A. That's -- that's -- we provide student 3 Q. Okay. And is this document then revised any time
4 organizations with a template to use to develop the -- 4 in the recent future?
5 the model constitution. 5 A. It would have -- by recent future --
6 Q. Okay. I'm gonna ask you just to hold onto 6 Q. I mean -- in recent -- in the recent past?
7 Document Number 11, which is labeled P000270. No, I'm 7 A. Okay. Yes, if there were -- if -- again, if
8 sorry. That is Document Number 12. Document 12 is 8 there were components of this document that needed
9 labeled P270. 9 clarification related to policies and -- and
10 (The reporter requested a clarification.) 10 enforcement, there would have been adjustments made to
11 MR. BAXTER: Correct. 11 this?
12 THE WITNESS: 2-7-0. 12 Q. Okay. And would you have a redlined version of
13 BY MR. BAXTER: 13 these policies with the recent changes?
14 Q. Okay. And then turn in the binder to 14. So 14 14 A. The staff would.
15 corresponds with -- what's A on 11, correct? 15 Q. Okay. Would you produce those to us?
16 A. Correct. 16 A. Yes.
17 Q. And you're gonna provide me an updated copy of 17 Q. Okay. And --
18 that? 18 THE WITNESS: Do I need to write this --
19 A. Yes. 19 MR. CARROLL: No, I've -- I've got notes.
20 Q. Okay. And then turn to 15. You're familiar with 20 THE WITNESS: Okay.
21 that document? 21 BY MR. BAXTER:
22 A. Yes. 22 Q. Okay. And then I'm asking you to look at
23 Q. And is that what corresponds with B on Document 23 Document 16.
24 11? 24 A. Okay.
25 A. Correct. 25 Q. Does that correspond with Exhibit C on Document
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1 12? 1 MR. BAXTER: Let's do anything before the
2 A. Yes, it does. 2 invest -- before the situation on BLinC arose, so
3 Q. Okay. And do you know if this one's been updated 3 whatever the date is of the complaint. February 20th.
4 any time recently? 4 Well, no, because -- I would say back to -- well, we'll
5 A. I'm just reviewing it to make sure some of the 5 talk about a time.
6 sections -- I don't believe there's been any changes to 6 MR. CARROLL: Yeah. Yeah.
7 this. 7 MR. BAXTER: Okay. We don't have to put
8 Q. Okay. And then also for 17 -- on Document 17, do 8 this on the record.
9 you have a 17? 9 (A discussion was held off the record.)
10 A. Um-hum. 10 MR. BAXTER: In fact, I'm gonna make that
11 Q. Okay. Is that the document that corresponds with 11 same request because we didn't receive any of the
12 this second entry on Document 12? 12 docu -- we didn't receive any of the policies except one
13 A. Correct. And there would be changes to this. 13 copy of the Human Rights Policy. So for documents
14 Q. Okay. For all of those documents, will you 14 labeled 18, 19, 20, 21, 22, will the University produce
15 produce updated copies including redlined with any 15 updated versions of those documents?
16 changes that have been made since 2008? 16 MR. CARROLL: Yeah. Why don't you put it in
17 A. 2008 would be challenging. 17 writing --
18 Q. Okay. Since -- since -- 18 MR. BAXTER: Okay.
19 A. Commencement of the -- 19 MR. CARROLL: -- what you truly want because
20 MR. CARROLL: Well, you don't have to answer 20 some of these policies -- it depends on how far back
21 discovery requests. 21 you're going. When you say "redlined versions," they
22 THE WITNESS: I'm sorry. 22 may not exist. Changes exist.
23 MR. CARROLL: I do. 23 MR. BAXTER: Sure, but any -- any -- okay.
24 MR. BAXTER: He'll provide those. 24 We'll put them in writing.
25 MR. CARROLL: I'll provide -- 25 MR. CARROLL: Yeah.

135 136
1 MR. BLOMBERG: Can you give me the numbers 1 what applies to the University in its own operation --
2 again? 2 A. Correct.
3 MR. BAXTER: Yeah, it's basically -- or 14 3 Q. -- as far as you know?
4 through 22. 4 MR. BAXTER: And then -- why don't we take a
5 MR. CARROLL: Do you want to break for 5 break? We'll do lunch. Meet here again at one.
6 lunch? 6 MR. CARROLL: Okay.
7 MR. BAXTER: Let me just look. I think 7 (A discussion was held off the record.)
8 we're done. I want to just check and make sure there's 8 (A recess was held from 12:04 p.m. until 1:03
9 nothing about those documents that I want to ask him 9 p.m.)
10 when we all break, if that's okay. Then we'll have a 10 (Mr. Blomberg is not present.)
11 nice clean break. 11 MR. BAXTER: Okay. We're back on the
12 BY MR. BAXTER: 12 record?
13 Q. I do have one question. On 21 there is a 13 THE REPORTER: Yes.
14 document entitled Nondiscrimination Statement. 14 BY MR. BAXTER:
15 A. Um-hum. 15 Q. Okay. Mr. Nelson, we've just returned from our
16 Q. Is there a difference between the 16 lunch break. Did you speak to anyone about this case
17 Nondiscrimination Statement and the Human Rights Policy? 17 while you were at lunch?
18 A. This -- this document is in the University of 18 A. I did not.
19 Iowa Operations Manual. I'm not -- I'm not responsible 19 Q. Okay. After -- after Lyn Redington sent her
20 for the University of Iowa's Operations Manual. I 20 letter affirming the sanctions, did you have any other
21 believe there are -- there are -- there are differences. 21 involvement specifically with regard to BLinC?
22 The Human Rights Policy has some additional language as 22 A. After Lyn sent her letter to the -- in terms of
23 related to student organizations than what is written 23 communication with you, communication with students?
24 here. 24 Could you clarify, please?
25 Q. Is it fair to say, though, then the -- this is 25 Q. Yeah, did you have any -- well, you didn't have
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1 any -- did you have any communication with me after the 1 lingo.
2 Lyn Redington letter? 2 A. No, no, no. That's fine.
3 A. No, I received the -- after -- after Lyn's 3 Q. Okay. So you -- IMU -- you or the -- someone at
4 nine-day appeal, I know that there was no communication 4 the IMU reached out to BLinC to invite them back to the
5 with you and I, and then I think our next communication 5 student --
6 with the students occurred after -- after the judge's 6 A. Correct. Andy Kutcher, exactly.
7 decision and it allowed -- getting ahold of them to 7 Q. Okay. And what exactly is Andy Kutcher's role at
8 participate in the student organizations there. 8 the IMU?
9 Q. Okay. So you -- and by "you," I assume you mean 9 A. Andy Kutcher replaced Kristi Finger, Student
10 the center. What do you call the place where you work? 10 Organization Development Coordinator.
11 A. I work in the Iowa Memorial Union. 11 Q. Okay. And Kristi, you said, went into more of an
12 Q. The Memorial Union. 12 administrative side?
13 A. And in the Center for Student Involvement and 13 A. Correct. She's still in the Iowa Memorial Union,
14 Leadership. It is a -- kind of a programatic area that 14 works in Event Services, and does scheduling, meeting
15 works with -- 15 rooms, events, space, campus -- outdoor campus space.
16 Q. Okay. So when you referred to -- 16 Q. So do you remember approximately when Andy would
17 (The reporter requested a clarification as 17 have been --
18 the witness's answer was not audible.) 18 A. When he joined our team?
19 THE WITNESS: Registered Student 19 Q. When he would have joined your team?
20 Organizations. 20 A. Yes, it would have been, I believe, the first
21 BY MR. BAXTER: 21 part of December of 2017.
22 Q. So when you refer to where you work, what do you 22 Q. Okay. And before that, was he at another
23 call it? The Memorial Union? 23 position at the University, or was he an outsider?
24 A. The IMU. 24 A. He was in a clerical role in our University
25 Q. The IMU? Okay. I'll just be in -- up with the 25 residence halls, but he trailed his partner and -- but

139 140
1 prior to Iowa, he was in a professional role at another 1 ruling -- is it called an injunction; is that correct?
2 institution. 2 Q. Correct. Entered an injunction --
3 Q. Okay. And does Andy have a male partner? 3 A. Yep. Then there was --
4 A. No. 4 (The reporter requested a clarification.)
5 Q. Okay. 5 MR. BAXTER: Entered an injunction is what I
6 A. A -- I believe a wife, woman. 6 said.
7 Q. Okay. And when did Andy first become aware of 7 A. Then there was a communication to us immediately
8 the BLinC matter? 8 to reinstate BLinC, and I believe that was -- could have
9 A. I would imagine shortly after his hire. 9 been the very same day or the day -- I think the day of
10 Q. Okay. And was there anything that happened after 10 because then we immediately -- when I say "we," Andy
11 the Lyn Redington letter that caused the University to 11 Kutcher authored the email inviting the students to
12 reconsider policy or to start conducting a review of the 12 participate in the student organization fair, which they
13 constitutions? 13 did that day. I think perhaps January 20 something.
14 A. Yes, my understanding was that after the -- 14 Q. Okay. So you reinstated BLinC. At some point,
15 again, we received direction from the Office of the 15 though, the University started reviewing student
16 General Counsel. 16 constitutions, correct?
17 Q. Okay. 17 A. Correct.
18 A. I don't know -- 18 Q. And what triggered that?
19 MR. CARROLL: You -- you can -- you can 19 A. The concern that was -- communicated to me from
20 answer that component without getting into what -- 20 General Counsel. I don't know. And, again, tell me if
21 BY MR. BAXTER: 21 I can't say this.
22 Q. Yeah, you don't have to tell me what your lawyer 22 Q. I'll let your counsel stop you.
23 told you, but if you want to tell me, like -- 23 A. Sure. Because the -- one of the concerns from
24 A. Correct. Yeah, we -- yeah, we were in 24 the judge was -- again, I don't want to quote this --
25 communications with the -- after the judge made the 25 but in -- inconsistent enforcement, and so beginning --
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1 January, February, there would have been a process of -- 1 Director for -- in the Center for Student Involvement
2 yeah. 2 and Leadership, and she had administrative oversight
3 Q. So the -- one of the judge's concerns was 3 over student organization development. So -- just a
4 inconsistent enforcement. So without telling me what 4 visual, if you will, Andy Kutcher reporting to Anita
5 your attorney said, though -- 5 Cory, Anita Cory reporting to Bill Nelson. And I said
6 A. Um-hum. 6 that she is no longer in that role, however, she's still
7 Q. -- what decisions were made to respond to that? 7 with the University.
8 A. The -- we -- needed to review our student 8 Q. And what's her new role?
9 organization -- Registered Student Organization 9 A. She is -- she is doing student organization
10 constitutions, to determine, of those constitutions, 10 conduct.
11 which of them had the current accurate and complete 11 Q. What does that mean?
12 University of Iowa Human Rights Policy. That review 12 A. She works in the Office of Dean of Students, and
13 happened late January, early February. 13 her primary area of focus is student conduct.
14 Q. Okay. And the -- who -- who headed up that 14 Specifically, student organization conduct.
15 review? 15 Q. So this is if they have a drunken party and cause
16 A. The -- review -- the -- coordinating the effort 16 problems, she would deal with that?
17 was led by -- Anita Cory, which we referenced earlier, 17 A. Correct.
18 Paul Mintner, which I believe we referenced earlier, and 18 Q. Okay. Those types of things?
19 they assembled the staff of the Center for -- because of 19 A. And University policy violations.
20 the volume of constitutions involved, they assembled the 20 Q. Okay. Would that also -- but if it were a Human
21 staff of the Center for Student Involvement and 21 Rights Policy violation, it would go back to the EOD?
22 Leadership to review those constitutions. 22 A. EOD. Correct.
23 Q. And just remind me, Anita Cory works where and 23 Q. Okay. And then remind me, Paul Mintner's role?
24 for whom? 24 A. Yes, Paul is -- currently Andy's interim
25 A. Okay. Dr. Cory at the time was the Associate 25 supervisor.

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1 Q. So he is between Anita and Andy? 1 guidance was to review the constitutions to see if the
2 A. Nope. 2 University Human Rights Clause -- the updated Human
3 Q. Because Anita left? 3 Rights Clause, which was, I think, 2014, was included
4 A. Anita left. Anita works in the Office of the 4 and was complete and accurate there. They were also to
5 Dean of Students. 5 see if there were other perhaps contradictory language
6 Q. What was he at the time that this -- back in 6 that was also to be noted.
7 January? 7 Q. Was there something about a financial clause?
8 A. Paul was -- there were three Associate Directors. 8 A. There's a financial clause that's required as
9 Anita was one, and Paul was two of the three. The 9 well, and I -- I -- that was part of the review that had
10 second of the third. 10 been going on over time as well. That wasn't a central
11 Q. So both Anita and Paul reported directly to you? 11 piece, but it was -- a Human Rights Clause -- or excuse
12 A. Correct. 12 me -- the Human Rights Policy was.
13 Q. Okay. And they pulled in more of your staff from 13 Q. The Human Rights Policy was? I thought you --
14 CSIL to help review? 14 A. Oh.
15 A. Correct. 15 Q. -- ended in the middle of -- sorry.
16 Q. And how many people were pulled in? 16 A. No, yeah, I -- yeah. The Human Rights --
17 A. The majority of the team, which would be -- I 17 checking to see if the Human Rights Policy, the updated
18 could do a count but probably -- I know there were some 18 version, complete and full, was included in the student
19 that were not available, and, again, it happened over 19 organization's constitution.
20 more than one occasion. But -- ten, ten to 12 -- 20 Q. Okay. And -- when you said they were looking for
21 Q. Okay. 21 language that was conflicting --
22 A. -- staff members. 22 A. Um-hum.
23 Q. And were they given guidance on what to do? What 23 Q. -- were they given any guidance on what to look
24 were they told to do? 24 for?
25 A. They were -- they were given guidance. The 25 A. Yes. Any language that might be in conflict with
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1 protected classes in the Human Rights Policy. 1 Q. She's writing everything -- oh, she's writing
2 Q. Okay. Was it just that general? They weren't 2 everything down and we will --
3 given any examples or -- 3 A. Right.
4 A. I think they were -- I wasn't in the setting 4 Q. -- and we're writing everything down.
5 where they did that. 5 A. We'll come back eventually because we need to
6 Q. Okay. 6 follow up.
7 A. I would imagine they did give examples and were 7 Q. Yeah.
8 asked questions and provided illustrations. 8 A. Thank you.
9 Q. Do you know if they were given any written 9 Q. I want to go back. Well, I'll just have you look
10 guidance, or was this just oral communication? 10 at a document. That was one of the documents pertaining
11 A. I think it was oral. 11 to the Christian Legal Society. And it was the letter
12 Q. Could you double-check that? 12 that Tom Baker wrote on February 20th, 2004. It's
13 A. Okay. 13 Document Number 46. Do you see in the second or the
14 MR. CARROLL: (Nodding.) 14 third paragraph -- actually, the last sentence, it says,
15 A. I have a procedural question; may I ask? 15 "Creed and sexual orientation are specifically listed as
16 Q. Sure. 16 examples of categories that deprive a person from
17 A. Why -- there's been many times that you have 17 consideration as an individual. Religion and religious
18 referenced followup, and I certainly want to -- 18 affiliation are not specifically identified in the
19 Q. Well, your counsel will keep track of that. 19 policy, although in some instances discrimination on the
20 We'll keep track of that. 20 basis of religion would violate the policy, such as a
21 MR. CARROLL: Yeah, you don't have to worry 21 practice of not permitting Christians to join a student
22 about it. 22 political group."
23 A. Okay. I want to make sure that -- 23 Do you have -- I mean, was there ever an earlier
24 Q. Yeah, we -- 24 policy that didn't include religion? Does that sound
25 A. -- don't do anything wrong. 25 right?
147 148
1 A. Yes, yes. 1 BY MR. BAXTER:
2 Q. Okay. What was -- tell me about that. 2 Q. And what -- what is this document, as best you
3 A. I'm not certain I can. That was when I was 3 know?
4 arriving. I can't speak to previous -- 4 A. This explains the revisions to the University of
5 Q. Okay. 5 Iowa's Human -- Human Rights Policy.
6 A. -- versions of the Human Rights Policy. I 6 Q. Okay. And it indicates that this is -- the date
7 apologize. 7 at the top says fall of 2014, correct?
8 Q. Okay. Was there a time when the Human Rights 8 A. Correct.
9 Policy was revised to add religion? 9 Q. And that this is when policy changes were
10 A. Again, I think that issue -- 10 expected that summer. Do you see that in the heading?
11 Q. You don't have any independent knowledge of that? 11 A. Yes.
12 A. No. I know that there was an update in 2014. 12 Q. Okay. And it -- it -- does it sound right that
13 Q. Okay. Do you have Document Number -- 33 and 34? 13 in December 2012, there was an internal audit that made
14 A. I have 33. 14 a recommendation to review the policy on human rights?
15 Q. Okay. 15 Do you see that at the very top sentence?
16 A. I do not have 34. 16 A. I do, I see that.
17 Q. Okay. Do you recognize this document 17 Q. And then it says their goal is to promote a more
18 (indicating)? 18 complete understanding of the nondiscrimination policy
19 A. As an -- as an original document, no. As a -- 19 and encourage consistent practices and so forth?
20 no. 20 A. Correct.
21 Q. But you read it to prepare for this deposition? 21 Q. Okay. And then down under number 1 it says,
22 A. I had access to it, yes, as the part of the -- 22 "Combine the Human Rights Policy with the EOD's
23 (The reporter requested a clarification.) 23 discrimination complaint procedures."
24 THE WITNESS: As part of a very large amount 24 A. Correct.
25 of documents. 25 Q. So was it your understanding that the EOD
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1 discrimination process and the H -- Human Rights Policy 1 Q. Okay. Do you think this came out of EOD more
2 process are the same process? 2 than --
3 A. I think you'll need to speak to Connie about 3 A. I'm not certain of its origin.
4 that. 4 Q. Okay. That's fair. Do you know, as the person
5 Q. Okay. 5 who's authorized to speak for -- the person at the
6 A. Constance. 6 deposition about the Human Rights Policy -- do you know
7 Q. Yep. And then under 2 it says, "Added several 7 why the categories that are included were included, and
8 new protected categories: Religion, status of the U.S. 8 why other categories aren't included?
9 veteran, pregnancy, service in the U.S. Military, and 9 A. I do not have that information.
10 genetic information." 10 Q. For example, there's nothing in the Human Rights
11 A. Correct. 11 Policy that would protect someone based of their
12 Q. Okay. Were you part of the discussion on how to 12 immigration status, correct?
13 change the policy? 13 A. Correct.
14 A. No. 14 Q. And there's nothing in the Human Rights Policy
15 Q. No? And have you talked to anybody who was? 15 that would protect someone based on their status as a
16 A. No. 16 crime victim?
17 Q. Do you have any insight into why these were 17 A. Correct.
18 protected categories? 18 Q. Or as an ex-spouse?
19 A. No, not why they were added. 19 A. Correct.
20 Q. Who would have that knowledge? 20 Q. Okay. So I want to ask you just a series of
21 A. I believe Constance -- Constance would. 21 hypotheticals.
22 Jennifer -- these were people who would work in the 22 A. Okay.
23 Office of Equal Opportunity and Diversity. Jennifer 23 Q. And ultimately -- let me ask: Ultimately, you
24 Modestou who is the director there, Constance who is one 24 were the person who was responsible -- or were you the
25 of the team members there, perhaps Mr. Baker. 25 person who was responsible for carrying out the review

151 152
1 of the student constitutions? 1 Q. And so as the process of the reviews began, you
2 A. At -- at my level or the Vice President's 2 were starting to shift over your reporting to Vice
3 level -- I'm not certain. So, again, I -- or the office 3 President Shivers as well?
4 of the President. Again, it was -- it was a 4 A. Correct.
5 directive -- 5 Q. And were there any issues that arose that you
6 Q. Okay. 6 passed up to her?
7 A. -- based on advice to -- that needed to happen. 7 A. Yes. In our -- in our review of -- or when I say
8 Q. Okay. But Anita and Paul would have -- 8 "our," the collective "our," our CSIL team in the
9 A. Report to me. 9 review. I'm sorry. In the review, I believe they
10 Q. Report to you? 10 reviewed over 500 student constitutions, and among those
11 A. Excuse me. Interrupted. 11 500 constitutions, approximately 160, 150 -- I think it
12 Q. If you had questions, you would have then 12 was 157 have the full and complete information. Human
13 reported to who? 13 Rights Policy Clause.
14 A. At -- at the time when the review started, it 14 Q. Okay.
15 was -- Lyn Redington was in the process of leaving, and 15 A. The remaining did not. That was passed along.
16 so I, for a period of time, was in the process of 16 Q. And so what did you do -- that was passed along
17 reporting to Dr. Shivers, shall we say? 17 to Vice President Shivers?
18 Q. And Dr. Shivers is? 18 A. Correct.
19 A. The Vice President for Student Life. 19 Q. And do you know what she did with that
20 Q. So before Lyn Redington left, did she report 20 information?
21 directly to Ms. Shivers -- 21 A. I believe she passed that along to the Office of
22 A. Correct. 22 the President and the Office of General Counsel.
23 Q. -- Dr. Shivers? 23 Q. And what did you do? Beyond -- you've got the
24 A. Yes. Lyn reported directly to Vice President 24 first wave of information.
25 Shivers. 25 A. Um-hum.
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1 Q. Then what did -- what happened? 1 Q. But do you know how it came to your attention
2 A. Um-hum. Then we realized that one of our 2 that they were being uploaded without getting --
3 challenges was that student organizations could upload 3 A. That was just the way the system was. That was
4 governing documents into the OrgSync portal -- OrgSync 4 our practice.
5 being our student organization data -- database 5 Q. It wasn't -- okay. And so what -- what did you
6 management platform, and that students could go in and 6 do -- anything besides that? You changed it so they
7 do that, and there was no trigger for staff to know that 7 would reroute to staff?
8 the ABC group went in and made a change. 8 A. Yes. And so -- timing-wise, then the -- that
9 So in the first part of February we disabled 9 disabling occurred the first part of February, and
10 that, so that all con -- all governing documents -- 10 then -- there were -- in -- April there was a
11 uploads or -- would have to go through staff. So that 11 communication that was sent out to the -- Registered
12 way staff had to review the updated uploaded document -- 12 Student Organization leadership, the primary
13 prior to upload. 13 representatives, asking that they submit -- or -- new
14 Q. So how did that -- how did that problem come to 14 constitution, new governing documents that included the
15 your attention? 15 updated full and complete University of Iowa Human
16 A. When we realized -- how the problem? 16 Rights Policy.
17 Q. Well, you said that it was a problem -- or it 17 Q. And did that -- that was April something?
18 sounded like you were saying it was a problem that 18 A. Something. Yes.
19 student groups were uploading their revised 19 Q. Did that go to every single student -- Registered
20 constitutions, presumably without it going through 20 Student Organization on campus?
21 staff? 21 A. That went to the groups who -- well, we knew from
22 A. Correct. Correct. And this was -- as we 22 our initial review that there were 160 that were
23 realized, we needed to do something different related to 23 complete. That communication went out to the remaining.
24 enforcement. That seemed to be a natural -- point of 24 We started the review, I believe I said -- 500 and --
25 where we could connect a potential problem. 25 513, I think, was the initial starting number; 157

155 156
1 was the -- those that were full and complete, accurate, 1 and I believe they received 200 and -- 201 responses.
2 current. So that remaining number, that 300 and some -- 2 Q. And why was March 3rd chosen as the date?
3 they were reached out to, to say that, "You need to 3 A. I think there was a two-week period. I think,
4 include the full, complete, updated Human Rights -- 4 ballpark of two weeks from April 20th to --
5 Policy." 5 Q. Okay. And then there were two more letters that
6 Q. Do you have a list of the 157 that were complete 6 went out later. Do you recall that?
7 from the beginning? 7 A. There was a letter that then went out on -- June
8 A. We should have that, absolutely. 8 1st.
9 Q. And we'll ask that that be provided. Were those 9 Q. Okay. What was the purpose of that letter?
10 157 also reviewed for conflicting language? Do you know 10 A. That letter was a communication to the groups who
11 what I am talking about? 11 had not complied or -- complied or responded, saying,
12 A. Yes, yes, yes. Part of -- yeah, part of -- part 12 "You have until June 15th to submit the revised con --
13 of that review that happened initially with that 513 -- 13 governing documents, constitution in the bylaws," and it
14 that was -- you know, the other thing they were looking 14 said that if they did not, they would be deregistered,
15 at, was -- potential conflicts in language, yes. 15 but as soon as they did, they would be reregistered,
16 Q. Okay. Then -- 16 assuming it was full and complete.
17 A. I don't know how many of that 157 may -- may or 17 Q. And were you -- did you help draft those emails
18 may not have had conflicting language off the top of my 18 or who would have drafted those emails?
19 head. 19 A. They would have come from, I believe, Andy
20 Q. Would there be a record of that? 20 Kutcher. I reviewed -- I have reviewed some of his
21 A. I -- I believe so. 21 communications, and I don't know -- I know I reviewed
22 Q. Okay. And then after the April 14th letter went 22 the communication that went out on -- that -- that first
23 out to the remaining 300 and some groups, what happened? 23 communication, was the day April --
24 A. So that communication, I believe, was sent on 24 Q. 20th?
25 April 20th. They had until March [sic] 3rd to respond, 25 A. Yes.
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1 Q. Okay. I'm gonna show you a document that's been 1 to the -- all of the student groups that weren't already
2 labeled as Document 75. Do you recognize that document? 2 in compliance by April 20th, correct?
3 A. Yes. 3 A. Correct.
4 Q. And what are those? 4 Q. Okay. Was there any other communication that
5 A. This is communication from Andy Kutcher to a 5 went to all of those groups with everything else in it?
6 student organization leader, and -- referencing the 6 A. So -- again, the -- then the June 1st
7 Human Rights Clause. 7 communication.
8 Q. Is that the April 20th letter you were referring 8 Q. Okay. So it's -- did everybody who got the April
9 to, or one copy of it? 9 20th -- email also receive the June 1st email?
10 A. Correct, it was a batch. 10 A. No.
11 Q. Okay. And if you flip through that, is that what 11 Q. Okay. Why not?
12 that -- those are all batches of the same letter? 12 A. Because some of the groups complied in the
13 A. Yeah. Yeah, this -- yes. 13 interim.
14 Q. Okay. And does that language -- does that email 14 Q. Okay. So some of those groups that complied
15 have language in there asking the students to make sure 15 might have failed to remove conflicting language because
16 the Human Rights Policy is stated correctly in their 16 they didn't know about it?
17 constitution? 17 A. Sorry. I'm just -- I'm collecting in my head
18 A. Correct. 18 then the letters. I -- I can't recall for sure exactly
19 Q. Does it have language in there about removing 19 when we addressed the conflicting language piece with
20 conflicting language? 20 them. But we were -- we continued to look at that in --
21 A. Not in this communication. 21 in submissions.
22 Q. Okay. And does it have information about making 22 Q. Okay. And the only -- and this -- and the people
23 sure the financial's policy is stated correctly? 23 who were looking at that, the reviewers --
24 A. Not in this communication. 24 A. Um-hum.
25 Q. Okay. So this is the communication that went out 25 Q. -- are full-time employees of the CSIL?

159 160
1 A. Correct. 1 Q. Okay. That's fine. I think I have that
2 Q. And are they student employees? 2 document, but I'll wait to show it to you later and you
3 A. No. 3 can verify if it's what you're thinking of.
4 Q. Okay. And they were just given oral guidance on 4 A. Okay.
5 how to do that, not written guidance? 5 Q. Okay.
6 A. There were -- no, there was -- there were 6 A. Which -- which document?
7 written -- yes, because there was -- again, in that -- 7 Q. Well, there are some documents that may -- maybe
8 in those -- the dates -- the -- the time frame between 8 have the script that you referred to or something, and I
9 those dates we've identified, there was follow-up 9 will show those to you.
10 communication, and so there was, for lack of a better 10 A. Yeah. I -- I can see the sample email, I can see
11 description, a script that people could use in those 11 the -- some scripts, et cetera, but I can't tell you in
12 follow-up communications -- 12 which communication, plural, we addressed the
13 Q. Okay. 13 conflicting language piece.
14 A. -- to guide the conversation. 14 Q. Okay. Now, just for clarity of the record, I'm
15 Q. Okay. And did that script have examples of types 15 going to state that the document that I showed you that
16 of problems and how to resolve them? 16 was the samples of the April 20th, 2018, email is
17 A. I don't believe it was that specific. 17 Document 175. I'm now going to show you what's Document
18 Q. Okay. I'm trying to understand what -- 18 173. This is a set of emails dated June 1st, 2018.
19 A. Sure. 19 They appear to be a form email. And can you verify
20 Q. -- "conflicting language" means. Was there 20 whether this is the email you referred to earlier that
21 anything in writing that would have explained what was 21 was sent on June 1st?
22 meant by conflicting language? 22 A. Yes.
23 A. I'm trying to -- I -- I'm un -- I'm unclear right 23 Q. Okay. Does that email contain instructions
24 now as to the guidance that we provided the groups about 24 regarding the full -- inclusion of the full Human Rights
25 the unclear language piece. 25 Policy?
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1 A. Yes. 1 A. Correct.
2 Q. Does it have language in there about removing 2 Q. And then I'm going to show you what's labeled as
3 conflicting language? 3 Document 174, which is an email -- a batch of emails
4 A. Yes. 4 dated June 8, 2018. And what -- would you look at that
5 Q. Could you read that? 5 and tell me if that's --
6 A. Yes. "Additionally, RSO governing documents --" 6 A. Um-hum.
7 (The reporter requested that the witness read 7 Q. -- what that is?
8 more slowly.) 8 A. Yeah, it's an additional communication going out
9 MR. CARROLL: Slow down. 9 about having the -- Human Rights Clause in there as well
10 THE WITNESS: I apologize. 10 as removal of contradictory --
11 THE REPORTER: Additionally -- 11 Q. And what was the impetus for this email just one
12 A. Thank you. This is -- yeah. "Additionally, RSO 12 week later?
13 governing documents may not include language that is 13 A. I believe in the previous communication you sent
14 considered contradictory to the Human Rights Clause. 14 me, they -- we had given them till June 15th --
15 Any language considered contradictory must be removed." 15 Q. Correct.
16 I knew this was in a communication. I just didn't know 16 A. -- to respond. I think it was a little bit of a
17 which one. 17 courtesy, a reminder to -- to do so.
18 Q. Okay. And -- but this one would not have gone to 18 Q. Okay. And are you confident that there are no
19 all the students. This email at Document 173 would only 19 student groups who received the first notice on either
20 have gone to students who already hadn't been approved? 20 June 1st or June 8th?
21 A. This would have gone -- this would not have gone 21 A. Am I confident --
22 to the ones that we had identified as being -- having no 22 Q. That all student groups received the April 20th
23 problems. 23 email, and that there are no student groups who heard
24 Q. So that's the 157 from before April, plus any who 24 about this for the first time on June 1st or June 8th?
25 came into compliance between April and June 1st? 25 A. I believe -- to the best of our ability, we

163 164
1 communicated with everybody initially. 1 that, look at the document that's labeled 174 and --
2 MR. BAXTER: Okay. I would share with 2 is -- do you see there's additional language added?
3 counsel the documents we received, there are gaps that 3 A. Yes.
4 suggest that some student organizations received the 4 Q. And this kind of language is in bold and
5 first notice on June 1st -- June 1st or June 8th. So if 5 underlined, right? And what's the additional language?
6 that's correct, I'd like the rest of the production of 6 A. The part about the -- more clarifications related
7 those documents. 7 to, "Requirements for membership and leadership that are
8 BY MR. BAXTER: 8 based on one or more protected classifications that are
9 Q. Do you notice that -- well, I'm gonna show you 9 listed above in the Human Rights Clause."
10 again Document 173, which was the June 1st email. 10 Q. So this tried to explain what contradictory
11 A. Um-hum. 11 language might be, right?
12 Q. In this document the language -- the 12 A. Correct.
13 contradictory language is just in plain type, no 13 Q. And it states that the contradictory language
14 underlining or emphasis, correct? 14 would be anything that has to do with selecting the
15 A. Correct. 15 years [sic] based on things that might contradict the --
16 Q. And could you read that again? 16 or might be implicated by the Human Rights Clause?
17 A. The entire paragraph or just the -- 17 A. Correct.
18 Q. Just the -- the (inaudible) language. 18 Q. So only the -- only the groups that received this
19 (The reporter requested a clarification.) 19 email on June 8th would have received that instruction,
20 MR. BAXTER: I'm sorry. Just the 20 correct?
21 contradictory language. 21 A. Correct.
22 A. "Additionally, RSO governing documents may not 22 Q. And, again, there's no -- there were no more
23 include the language that is considered contradictory to 23 specific guidance on what it meant to have language
24 the Human Rights Clause." 24 contradictory to the Human Rights Policy?
25 Q. Okay. And I'd like you, while you're looking at 25 A. Please say again.
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1 Q. And was there -- is there anywhere where I could 1 Q. So they had the first call whether something was
2 find more clear guidance on what you meant by language 2 a violation or not?
3 that is -- by contradictory language, that would include 3 A. Correct.
4 requirements for membership or leadership that are based 4 Q. And you were just trusting their judgment to
5 on one or more protected classifications? 5 decide if something should be passed up?
6 A. So is there -- you're asking for -- is there 6 A. Or, again, based on instruction, direction that
7 another document that explains that? 7 was given to the team assembling. I -- again, I
8 Q. Right. 8 wasn't -- I wasn't in the space at the time with them,
9 A. I can't recall. There may be. 9 but I -- there had to have been a layer of discussion --
10 Q. So did the CSIL employees who were redoing the 10 or discussion and direction, guidance given. There was
11 constitution pretty much act on their own discretion to 11 a -- there was a form. They had a form that -- that had
12 determine what was a violation of the Human Rights 12 at -- that had protected classes on the form, and
13 Policy? 13 protected classes, those included in the Human Rights
14 A. They -- 14 Policy.
15 Q. What was -- excuse me. Let me ask that question 15 Q. Okay. Well, let me -- I'm just gonna ask you a
16 again. Did the CSIL employees pretty much act on 16 series of questions to see what you -- what your
17 their -- have final decision making authority on what 17 understanding was of how they would have applied the
18 type of language for selecting leaders would violate the 18 requirement to remove any contradictory language. Let's
19 Human Rights Policy? 19 say someone started a group to -- for students who are
20 A. No, that -- if there were questions, those were 20 participants in the DACA Program?
21 to be addressed to -- to Andy and, again, Anita at some 21 A. Um-hum.
22 point, and then Paul more recently. 22 Q. Do you know what the DACA Program is?
23 Q. But questions would never get to them if the 23 A. Um-hum.
24 reviewers didn't raise them, right? 24 MR. CARROLL: "Yes"? "Yes"?
25 A. Correct. 25 THE WITNESS: Yes, I apologize.

167 168
1 BY MR. BAXTER: 1 you had a group that formed around, you know, protecting
2 Q. Thank you. If in their constitution they had a 2 victims of sexual assault, and they wanted to exclude
3 provision that excluded nonimmigrants, would that 3 anybody who had a criminal record, there's nothing that
4 have -- should that have been flagged by the reviewers? 4 would trigger the Human Rights Policy or that it would
5 A. The -- whenever there was a conflict of -- of 5 be considered a violation of the Human Rights Policy for
6 contradictory language, and it couldn't be discerned by 6 that?
7 Paul, again -- excuse me -- Andy -- and then Anita or 7 A. Could you repeat that?
8 Paul, depending on the timeline, then those were sent to 8 (Mr. Blomberg left the room.)
9 the Office of the General Counsel for clar -- or for an 9 BY MR. BAXTER:
10 interpretation and advice. 10 Q. Let's say a group formed around -- a group of
11 Q. So let's say that a group formed around 11 students wanted to form a club to -- a support group for
12 immigration status, is there anything in the Human 12 victims of crime --
13 Rights Policy that would be triggered by that? 13 A. Um-hum.
14 A. No. 14 Q. -- say, victims of sexual assault.
15 Q. Okay. So if someone, though -- you know, started 15 A. Um-hum.
16 a -- you know, build-a-wall club -- 16 Q. And in their constitution they excluded any
17 A. Um-hum. 17 members who had a criminal record --
18 Q. -- and they wanted to exclude immigrants -- 18 A. Um-hum.
19 A. Um-hum. 19 Q. -- there's nothing in the Human Rights Policy --
20 Q. -- they could do that without violating the Human 20 A. My apologies. Yes.
21 Rights Policy; is that correct? 21 Q. Please say that.
22 A. We allow the groups to assemble around an 22 A. Yes, yes.
23 agreed-upon mission. 23 Q. That would --
24 (Mr. Blomberg entered.) 24 A. That's earlier -- yes. Felonies, not --
25 Q. Okay. And the same with categories like -- if 25 Q. Okay. What about political parties? If a group
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1 of students wanted to form a group supporting Bernie 1 that -- leaders to sign Statements of Faith.
2 Stand -- Stander -- Sanders, they could do that, right? 2 Q. Okay. So creed is included as a protected
3 A. Correct. 3 category, correct?
4 Q. And they could limit their leadership to 4 A. Correct.
5 individuals who supported Bernie Sanders' platform? 5 Q. And what's your understanding of what creed
6 A. Correct. 6 means?
7 Q. Okay. And could students form a Republican club 7 A. Context of religion.
8 and require their leaders to be registered Republicans? 8 Q. In the context of religion or other -- what does
9 A. Correct. 9 it mean to you?
10 Q. They could require them to support the Republican 10 A. Umm --
11 party platform? 11 Q. Let me ask you another question?
12 A. Correct. 12 A. Yes, please.
13 Q. What if the Republican Party platform has a 13 Q. Will you turn to Document 37? Okay. Do you
14 statement that marriage should be between a man and a 14 recognize that document?
15 woman -- 15 A. And it's authored, yes. Works at EOD --
16 A. Um-hum. 16 Tiffini -- (inaudible).
17 Q. -- could they still have that club and exclude 17 (The reporter requested a clarification.)
18 people who didn't -- who didn't support that platform? 18 A. Yes. And the person listed on the first page is
19 A. They can have that statement, but they can't -- 19 a staff member in Equal Opportunity and Diversity.
20 that statement can't categorically unilaterally violate 20 Tiffini Stevenson Earl.
21 the University of Iowa's Human Rights Policy. 21 Q. Earl. And do you recognize what -- or do you
22 Q. Could that club make people sign a statement 22 have -- do you recognize what that document is?
23 saying that they support everything in the Republican 23 A. It's a review, yes.
24 Party platform in order to be eligible to be a leader? 24 (Mr. Blomberg returned.)
25 A. Yes, we -- we allow groups to sign a statement 25 Q. A review of what?
171 172
1 A. Policy and human rights. 1 A. Um-hum.
2 Q. What's Tiffini Stevenson Earl's job? 2 Q. -- does that mean that political groups can't
3 A. She's one of the compliance officers in EOD. 3 exclude people who don't share their political creed?
4 Q. Okay. And do you know what her job 4 A. Again, it's -- student organizations can have
5 responsibilities are? 5 those statements.
6 A. She's involved in training; I know that. I 6 Q. Okay. So the political -- the Republican Party
7 think, again, Constance can speak specifically to her 7 can exclude Democrats?
8 exact duties. 8 A. They cannot violate the University of Iowa's
9 Q. Okay. This looks like a training document, 9 Human Rights Policy.
10 right, on how to comply with the policy on human rights? 10 Q. Okay. Can they exclude Democrats as their
11 A. Correct. 11 leaders?
12 Q. Okay. On the -- on the page within this document 12 A. (Pause.) As long as their exclusion is not based
13 that's numbered 935 -- do you see that? 13 on a violation of the Human Rights Policy.
14 A. Um-hum. 14 Q. Well, how do you -- how would Republicans exclude
15 Q. It defines creed as a formal statement of 15 Democrats without violating the prohibition against
16 religious belief, confession of faith, or a system of 16 discrimination based on creed?
17 beliefs, principles, or opinions, and it can be any 17 A. I'm -- I'm sorry?
18 strongly held philosophical beliefs, even if not a 18 Q. If the Republican Party excluded a Democratic
19 recognized religion; is that correct? 19 leader --
20 A. Correct. 20 A. Um-hum.
21 Q. So -- and is this an accurate statement of how 21 Q. -- isn't that discrimination on the basis of
22 the University would interpret creed? 22 creed?
23 A. Yes. 23 A. Yes.
24 Q. So when the Human Rights Policy says that you 24 Q. So it violates the Human Rights Policy?
25 cannot discriminate on the basis of creed -- 25 A. Yes.
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1 Q. But you said you make an exception, apparently, 1 complaint from a student that acknowledged that they
2 because you allow political parties to exclude, as 2 were -- "I was not given an opportunity because of a
3 leaders, people who don't share their -- their beliefs 3 protected class," we would investigate -- or EOD would
4 or their creed? 4 investigate.
5 A. Yeah. 5 Q. And what would EOD's conclusion be?
6 Q. That's correct? 6 A. It depends on the specifics of the -- of the
7 A. What we -- again, we -- allow the groups to have 7 complaint and --
8 these -- their -- their Statements of Beliefs, their 8 Q. Well, let me give you a very specific fact
9 credos, their -- what they believe strongly in. And as 9 pattern.
10 long as someone is -- not denied an opportunity, because 10 A. Okay.
11 of our protected classes, we haven't -- we have not 11 Q. Okay. Assume that there's a par -- a group on
12 acted on that as a violation. 12 campus that supports Bernie Sanders, and a -- individual
13 Q. Okay. So creed is a protected class, and do you 13 shows up and asks -- has been attending the group for
14 know that on campus there's lots of groups that exclude 14 months, and asks if he can be a leader of the party.
15 leaders who don't share their creed, right? 15 And he says, "I'm a huge Trump supporter, and -- I want
16 A. Um-hum. Um-hum. 16 to become a leader so that I can insert Trump's beliefs
17 Q. Is that a "yes" or "no"? 17 into the group," and the group denies him a leadership
18 A. Yes. 18 position for that reason because his political creed is
19 Q. And have you ever done anything to stop that? 19 different than the group's political creed.
20 A. We've received no violations, no complaints on 20 A. Um-hum.
21 that. Had we, we would have investigated. 21 Q. Does that violate the Human Rights Policy?
22 Q. But you said earlier that you would allow that to 22 A. I got a little bit lost in the analogy there.
23 happen, that if that -- you would allow groups to 23 But -- does it violate -- is a result of an
24 exclude leaders who didn't share their creed. 24 investigation that would look at the whole situation to
25 A. As a Statement of Faith, but if we received a 25 see what all of the variables were.

175 176
1 Q. Well, I've given you the entire situation. 1 group philosophy could conflict with the Human Rights --
2 You're authorized to interpret the Human Rights Policy, 2 with a -- could touch on a topic in the Human Rights
3 correct? 3 Policy, correct?
4 A. For Registered Student Organizations with 4 A. Correct.
5 guidance from administration, yes. 5 Q. Could a sorority, for example, require its
6 Q. But for purposes of this deposition, you're 6 members to be single?
7 entitled to speak on behalf of the University on that 7 A. No.
8 issue, correct? 8 Q. Why not?
9 A. For student organizations. 9 A. There may be actually sororities that do not
10 Q. That's a "yes" -- 10 allow membership to women to be married.
11 A. Yes. 11 Q. And why do you think that might be?
12 Q. -- for student organization? 12 A. Because that's a part of their credo, their
13 A. Excuse me. Yes, yes. 13 belief, their strongly-held system of values.
14 Q. If the pro-Bernie party excludes, as a leader, a 14 Q. Right. Possibly, the sorority's purpose, right,
15 pro-Trump individual, that's discrimination on the basis 15 is to generate social interaction between men and women,
16 of creed, correct? 16 correct?
17 A. Correct. 17 A. Or students, in general, um-hum.
18 Q. Technically, that violates the Human Rights 18 Q. And they might feel like that feels improper if
19 Policy, correct? 19 they have married members, right?
20 A. Correct. 20 A. I'm not certain I know -- how they feel.
21 Q. But you've stated that you let student groups do 21 Q. But it's a possibility?
22 that because you want student groups to form around 22 A. Certainly.
23 common beliefs, correct? 23 Q. And would you allow them to follow that credo,
24 A. Right. 24 that creed, if that's what they wanted to do?
25 Q. And there's many ways that someone's creed or 25 A. Again, I think we would allow the group to
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 177 178
1 function until we were made aware of there being a 1 facts, then, if they were found to be in violation of
2 problem, and then we would look at the entirety of the 2 the University of Iowa's Human Rights Policy, there
3 problem to determine what had happened. 3 could be sanctions issued against them. If they're --
4 Q. Well, I'm giving you very basic scenarios. Let 4 if the investigation yielded no violation of the
5 me give you another very simple one, okay? Let's say 5 University of Iowa's Human Rights Policy --
6 there's a group organized on campus to support veterans 6 Q. Okay. You're dodging the question.
7 who have served in the United States Military -- 7 A. I --
8 A. Um-hum. 8 Q. There's no -- there's no complicating factor
9 Q. -- and they exclude anyone who hasn't served in 9 here. There's -- there's one set of facts. A group
10 the military. That would be discrimination on the basis 10 excludes leaders who don't meet their mission. A U.S.
11 of service in the U.S. Military, correct? 11 Military group excludes people who haven't served in the
12 A. Correct. 12 U.S. Military. That is a violation of your Human Rights
13 Q. And service in the U.S. Military is a protected 13 Policy, correct?
14 status? 14 A. Yes.
15 A. Correct. 15 Q. So you should disband that group, correct?
16 Q. So would you allow that group to exist or not, if 16 A. Yes.
17 someone complained? 17 Q. Okay. Have you made any effort to go to the
18 A. If they complained and they were found in 18 groups on campus that form around affiliations of the
19 violation, they would not be allowed to exist. If 19 U.S. Military and ask them to disband?
20 they -- if the complaint -- if the finding was there was 20 A. No.
21 no violation, they would be allowed to exist. 21 MR. CARROLL: Well, just a minute. I'm
22 Q. Say that last part again. 22 gonna object as a misstatement of the record. We
23 A. If there was a -- if the investigation -- you 23 deregister groups. We don't disband them.
24 said there was a complaint. If the complaint was 24 BY MR. BAXTER:
25 investigated, and given all of the variables, all the 25 Q. When I say "disband," do you understand what I
179 180
1 mean? 1 Q. -- is that correct?
2 A. I under -- I think you were talking about 2 A. Well, no, I'm saying -- I'm following your line
3 disassociating them from the institution. 3 of questioning, and that no, we have not done that.
4 Q. Deregistering them, correct. 4 That's why we are changing our enforcement patterns.
5 A. Correct. 5 Q. Okay. So --
6 Q. Okay. Have you made any effort to deregister -- 6 A. Because we operate from a complaint-driven
7 are there groups on campus that form around -- 7 system.
8 A. Yes. 8 Q. But all you -- you've upgraded from a
9 Q. -- affiliation with the military or service in 9 complaint-driven system?
10 the military? 10 A. Correct.
11 A. Yes. 11 Q. What's the system now?
12 Q. Okay. Do they require their leaders to have 12 A. Well, I think we're waiting on guidance from the
13 served in the U.S. Military, or to meet the purposes of 13 General Counsel's Office to determine exactly how we
14 the group? 14 should be proceeding. That's why I referenced these
15 A. The latter. 15 cases where there's conflict and the staff can't seem to
16 Q. Okay. They require them to meet the purposes of 16 quite work through the conflict, are -- in the General
17 the group? 17 Counsel's Office or interpretation for us to then
18 A. Correct. 18 receive direction.
19 Q. And even -- have you made sure that that -- so 19 MR. BAXTER: Okay. We're gonna -- I'm gonna
20 some of those groups would exclude members who, for 20 stop and go off the record for a minute.
21 example, have never served in the military or have no 21 (A discussion was held off the record.)
22 affiliations with the military? 22 (A recess was held from 2:03 p.m. until 2:11
23 A. (Nodding.) 23 p.m.)
24 Q. So you're nodding your head "yes" -- 24 MR. BAXTER: Let's go on the record.
25 A. Meaning -- 25 BY MR. BAXTER:
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1 Q. And we'll start with Document 121, which will be 1 Q. Okay. And it's an email from you to Melissa
2 handed to you by Mr. Blomberg. 2 Shivers and Pam Krogmeier, correct?
3 (A discussion was held off the record.) 3 A. Correct.
4 MR. BAXTER: Here, why don't you give me the 4 Q. Who is Pam Krogmeier?
5 folder. We'll give one to the reporter and one to you. 5 A. Pam is Vice President Shivers' Administrative
6 That's 121, and 121 to the reporter. 6 Assistant.
7 MR. CARROLL: Just so I'm clear, how do we 7 Q. Okay. And Dinette Myers is your Administrative
8 know this is 121? 8 Assistant; is that correct?
9 MR. BAXTER: Because you're gonna put it in 9 A. Correct.
10 your folder behind Tab 121, and we're going to put it in 10 Q. And do you know what this email is about?
11 her folder -- 11 A. Yes, I believe she had asked me for some just
12 MR. CARROLL: Okay. 12 general information surrounding student organizations,
13 MR. BAXTER: -- behind 121. 13 privileges that are afforded to the student
14 MR. CARROLL: Are these exhibits marked as 14 organizations. She may have been -- she must have
15 exhibits (addressing the reporter)? 15 required specifically or -- to include discipline cases,
16 MR. BAXTER: They're marked by the tabs. 16 perhaps.
17 MR. CARROLL: But -- 17 Q. Okay. Do you know -- she says, "I just want to
18 (A discussion was held off the record.) 18 make certain you had something in your hands to start
19 BY MR. BAXTER: 19 with and to use that something as a gauge for whatever
20 Q. Okay. The exhibit was marked as -- or was 20 else you need -- you may need." What were you referring
21 Document 121, correct? If you'd like, you can write on 21 to?
22 the bottom, "121." 22 A. I believe she was going to have a conversation
23 A. (Writing.) 23 with either or -- -- the President's office and/or
24 Q. And do you recognize this document? 24 General Counsel.
25 A. Yes. 25 Q. About what?

183 184
1 A. Well, in relation to the context we're 1 Q. Okay. On the page that's marked at the bottom as
2 discussing, all of our -- like, how do we manage student 2 3888 --
3 organizations. I can't remember the exact context, but 3 A. Excuse me.
4 I believe I prepared a one or two-page -- brief related 4 Q. -- where it says, "Several fraternities have been
5 to -- this is what student organization review 5 deregistered since I've been here, approximately 15
6 committee, benefits that you are given should you be 6 years." Is that something that you submitted?
7 registered as a student organization. 7 A. It would have had to have been.
8 Q. Okay. I'm gonna ask you to look at Document 122. 8 Q. Okay. I'm gonna ask you to take a look at then
9 They're marked here as 122. We'll add a sticker. 9 Document 125.
10 (Marking.) You're not on this document. Do you 10 A. Excuse me.
11 recognize what it is? Have you seen it before? 11 Q. Would you mark that on the bottom as 125?
12 A. I -- it could be in -- well, again, in the -- I 12 A. (Marking.)
13 assume it was in the production of documents, yes. 13 Q. Do you recognize that document?
14 Q. And you see the documents immediately behind it. 14 A. Yes.
15 Did you prepare this document or have you seen it before 15 Q. What is it?
16 preparing for this deposition? 16 A. A document that I provided directly to Vice
17 A. I believe I provided some of the contents for 17 President Shivers.
18 this. 18 Q. And what was the purpose of this document?
19 Q. Did you provide it in writing or -- 19 A. It was based on a request that she had made to
20 A. I think it goes back to some of the 20 provide information about how we managed an
21 information -- (pause) -- could have been -- I'm 21 organization, what the benefits of student organizations
22 speculating -- could have been information also shared 22 are. Just -- basic information for -- for her. Again,
23 with strategic communications surrounding -- surrounding 23 Dr. Shivers, I think at this point in time, would have
24 the case, as well as general information about 24 been in her -- fifth or sixth month of employment.
25 Registered Student Organizations. 25 Q. Was this in preparation for a decla -- or
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1 declaration sheet signed and submitted to the Court; do 1 Q. Okay. Let me hand you what's been marked as

2 you know? 2 Document Number 127. Do you recognize this document?

3 A. I don't know that. 3 A. Yes.

4 Q. I'm gonna ask you to look at -- what will be 4 Q. What is it?

5 marked as Exhibit 126. (Marking.) Are you familiar 5 A. Some of the -- the guidance that was given to the

6 with this document? 6 team of people -- during review.

7 A. Yeah, this was -- this was information that was 7 Q. And do you know who drafted this?

8 provided in terms of a -- a plan as we -- as I 8 A. I believe it was Paul Mintner and Dr. Cory.

9 referenced earlier, when we were -- began the effort to 9 Q. Okay. And did you review and approve this

10 work with student organizations about their documents. 10 document?

11 Q. Okay. And do you know when this document would 11 A. I did not.

12 have been printed or created? 12 Q. And why not?

13 A. Probably in advance of that first review, which 13 A. I -- it was -- I didn't ask to approve it.

14 happened again late January. 14 Q. Okay.

15 Q. Okay. And -- 15 A. I -- I can't honestly recall -- I believe it was

16 A. Early February, that's when we -- as I -- 16 at that time managed with -- again, Andy and Dr. Cory.

17 possibly, you and I discussed earlier, in terms of when 17 Perhaps some involvement from Paul Mintner.

18 we began the -- the review. 18 Q. Okay. And you see down at the bottom where it

19 Q. And do you know who this went to? 19 says 1, a, b, c?

20 A. I think there were -- I think there were multiple 20 A. Correct.

21 recipients of this. 21 Q. Are these the written instructions that the

22 Q. Do you remember who the author was? 22 reviewers received for reviewing constitutions?

23 A. A -- Paul -- again, I believe, Andy Kutcher and 23 A. Yes.

24 Dr. Cory would have, with some assistance from Paul 24 Q. You referred to a document they might have

25 Mintner. 25 received earlier; is this that document?

187 188

1 A. I believe so. 1 documents on behalf of everyone. I'm not sure --

2 Q. Do you think there were any other documents like 2 individual people didn't submit anything to the General

3 it? 3 Counsel's Office. It was funneled through Paul and -- I

4 A. There may have been followup that some of the 4 continue to say Paul -- I meant Andy. And Paul and

5 staff asked of Paul -- of Andy, and he may have provided 5 Dr. Cory, but again Dr. Cory and Paul -- Dr. Cory

6 some additional followup in writing. 6 transitioned out, and Paul transitioned in.

7 Q. And would you have received copies of that 7 Q. Okay. And so is it possible that there were

8 follow-up writing? 8 communications between the people reviewing the

9 A. Probably not. Would have been directly between 9 contract -- constitutions that have not been produced?

10 the staff members and Paul. 10 A. Perhaps. I did -- I -- oral communication or

11 Q. And were you -- 11 written communication? They were assembled in the room.

12 A. Excuse me. Andy. 12 The majority of the -- of review happened with people in

13 Q. Were you at some point asked to produce documents 13 the same room at the same time. So there -- maybe I

14 for this litigation? 14 referenced this earlier, as there were questions, they

15 A. Yes. 15 could be addressed as a team. So all of the

16 Q. And was Andy asked to as well? 16 communications in that setting probably were mostly

17 A. I -- yes. 17 oral.

18 Q. And was everybody on your staff who participated 18 Q. Okay. But when you were asked to provide

19 in this review process asked to produce documents? 19 documents for this deposition, did you ask your entire

20 A. No. 20 team to collect documents and send them to someone?

21 Q. No? 21 A. Yes.

22 A. I don't believe so. 22 Q. Including all the reviewers?

23 Q. Okay. Is there any reason why -- 23 A. Yes. And that process was a process that was

24 A. Well, I think -- well, I think Paul was -- again, 24 done by -- by me and by Andy and -- yeah, that team of

25 I think Andy Kutcher and Paul were collecting all the 25 us worked together on this because of the magnitude of

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1 the effort. 1 Human Rights Clause"?
2 Q. But everybody that was on the review team was 2 A. Um-hum.
3 asked to somehow get you any documents they might have? 3 (The reporter requested a clarification.)
4 A. I believe Paul asked everybody to do that. That 4 MR. BAXTER: The Human Rights Clause.
5 would be part of the -- what we needed to do. 5 BY MR. BAXTER:
6 Q. On the next page over you see -- and then there's 6 Q. And then it says, "The Human Rights Clause is
7 Number 2 a, it says, "Once approved please delete the 7 encompassing of all RSO activities, including the
8 organization from the Student Organization Governance 8 selection of membership and/or leadership"; is that
9 Follow-up --" 9 correct?
10 A. Correct. 10 A. Um-hum.
11 Q. Okay. And it says -- and that's a shared Excel 11 Q. And then it says, "RSOs can still have
12 spreadsheet, correct? 12 purposes/mission statements related to specific classes
13 A. Correct. 13 or characteristics of the HR Clause, but attaining --
14 Q. Was that document gathered for production in this 14 attainment of membership or leadership cannot be
15 litigation? 15 contingent on the agreement, disagreement, subscription
16 A. I -- I can't tell you if it was. 16 to, et cetera, of stated beliefs/purposes which are
17 MR. BAXTER: Well, I'm gonna ask counsel to 17 covered in the HR Clause."
18 make sure I have that. I don't believe it was in the 18 A. Um-hum.
19 production. 19 Q. So I want to tease out your understanding of this
20 BY MR. BAXTER: 20 sentence, and I want to propose: One way of looking at
21 Q. Okay. On the next page at the top of the page -- 21 a Human Rights Policy is that it prohibits status-based
22 A. Okay. 22 discrimination.
23 Q. Do you see where it says "Registered Student 23 A. Correct.
24 Organizations RSOs are considered University programs 24 Q. And you can't discriminate against someone
25 and thus must comply with all policies including the 25 because of their status. There's another way to look at

191 192
1 that. You can say, "Well, we're prohibiting conduct 1 because of their status?
2 that might fall within one of the categories or we're 2 A. Their status.
3 protecting conduct." And then this seems to be saying 3 Q. So it's okay to discriminate on the basis of
4 that the HR Clause prohibits beliefs -- stated beliefs 4 beliefs?
5 or purposes which are covered by the HR Clause. That is 5 A. (No response.)
6 the position of the University? 6 Q. Can the -- student group for transgender students
7 A. I believe this was the guidance that we received, 7 discriminate against people who believe that
8 that Paul -- Andy received specifically from General 8 transgenderism is a figment of the imagination?
9 Counsel. 9 A. Discriminate by not allowing them --
10 Q. Okay. So when it says, "Obtainment of membership 10 Q. To join the group.
11 or leadership cannot be contingent on agreement with 11 A. Can they? We don't allow -- we don't allow
12 beliefs or purposes that are covered in the HR Clause," 12 violations of our Human Rights Policy, and so the -- so
13 is it the University's position that it can prohibit 13 excuse me.
14 groups from selecting leaders who share their beliefs? 14 Q. If -- if -- if a transgender -- a transgender
15 A. No. 15 support group excludes people who believe that
16 Q. So how do you read that then? 16 transgenderism is a figment of the imagination -- is
17 A. Again, I -- I read this as -- as I've stated 17 that status-based discrimination or is it belief-based
18 before, that Registered Student Organizations can have 18 discrimination?
19 Statements of Belief, but the -- and members can be 19 A. Belief.
20 asked to sign them, but to deny someone a -- an 20 Q. Okay. Can you give me an example of what
21 opportunity for membership or leadership cannot be in 21 status-based discrimination would be?
22 violation of the Human Rights Clause. 22 A. Yes, it's a suit -- if -- if -- in this case if
23 Q. But what does it mean to violate the Human Rights 23 Marcus Miller saying he was gay and then being denied a
24 Clause? Do you violate the Human Rights Clause when you 24 leadership opportunity.
25 discriminate against someone because of their beliefs or 25 Q. Just because he was gay?
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1 A. If he -- correct. If the group had categorically 1 A. Yes.
2 denied him of that opportunity because he had -- he had 2 Q. And did everybody else in the University that you
3 said he was gay, and so as a result, they denied him 3 know of know that?
4 that leadership opportunity. So gay would be a status 4 A. I can't attest to that.
5 in that case. 5 Q. Okay. Did your staff know that?
6 Q. Okay. So -- is belief-based discrimination okay 6 A. Yes.
7 under the Human Rights Policy? 7 Q. Okay. And is it your understanding the new
8 A. Yes. 8 policy is going to prohibit belief-based discrimination?
9 Q. So the Human Rights Policy only prohibits 9 A. I'm not -- we are waiting for direction from the
10 status-based discrimination? 10 Office of the General Counsel about how we will
11 A. At the time, yes. 11 interpret the Human Rights Policy moving forward.
12 Q. At what time? Right now? 12 (The reporter requested a clarification due
13 A. No. I -- again, we are waiting for guidance. 13 to lawn maintenance occurring outside of the
14 Q. Okay. But at the time that -- up till -- at this 14 deposition room.)
15 moment the Human Rights Policy is the same Human Rights 15 BY MR. BAXTER:
16 Policy that was in existence at the time of the BLinC 16 Q. So this statement in this memo, you think, is
17 investigation? 17 wrong?
18 A. Correct. 18 A. The opening paragraph, that first paragraph?
19 Q. There's been no changes? 19 Q. Well, the last sentence in that opening paragraph
20 A. Correct. 20 says that, "RSOs can have mission statements related to
21 Q. And the human policy [sic] in place right now 21 specific classes or characteristics of the HR Clause,
22 only prohibits status-based discrimination? 22 but obtainment of membership or leadership cannot be
23 A. Correct. 23 contingent on the agreement, description -- agreement,
24 Q. And did you know that at the time of the BLinC 24 disagreement, subscription to, et cetera, of stated
25 investigation? 25 beliefs/purposes which are covered in the HR clause."

195 196
1 A. I think that's the belief status thing. That -- 1 Q. You never tried to make sure that the guidance
2 Q. This says that you can't -- you can't require 2 they were giving their reviewers was accurate?
3 people to subscribe to a belief, though, right? 3 A. I made the assumption of what they were getting
4 A. (Pause.) This is -- this is, at the time, an 4 from the General Counsel's Office -- is what we needed
5 accurate interpretation of how we were instructed to 5 to do.
6 move forward. 6 Q. Okay. But you don't know if they asked counsel
7 Q. And this came from counsel? 7 to review this?
8 A. We received our direction about how to move 8 A. We've been asking counsel every step of the way.
9 forward in consultation with the Office of the General 9 It would be logical to assume that they were asking --
10 Counsel. 10 as well in this situation. We've been asking every step
11 Q. Did anybody that you know of above you approve 11 of the way.
12 this statement? 12 Q. But you agree that this is wrong compared to what
13 A. I can't -- I can't speak to that. I'm -- I 13 you understand the policy to be?
14 believe we received direction from the General Counsel's 14 A. I state at -- at the --
15 Office on that. 15 Q. At this time, right now, which is the same policy
16 Q. And who did you say you think drafted this? 16 that existed during the BLinC investigation, is this a
17 A. The document itself was put together by Andy 17 false statement?
18 Kutcher and Dr. Cory -- 18 A. I don't think it's false.
19 Q. Okay. 19 Q. But you stated, correct --
20 A. -- I recall, but they were informed along the way 20 A. I'm sorry. I --
21 by direction from the Office of the General Counsel. 21 Q. You stated the Human Rights Policy only prohibits
22 Q. But this is just Andy and Anita's -- own writing? 22 status-based discrimination?
23 A. Correct. 23 A. Correct.
24 Q. And you never -- you never reviewed it? 24 Q. Can the University tell students what they have
25 A. I did not. 25 to believe?
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1 A. No. 1 A. They are allowed to share similar beliefs and
2 Q. Can they tell the student groups what they have 2 purposes.
3 to believe? 3 Q. And that's true for leaders, correct?
4 A. No. 4 A. Correct.
5 Q. So this statement says that you cannot condition 5 Q. And that's true for members?
6 leadership on agreement to a stated belief or purpose. 6 A. Correct.
7 Isn't that trying to tell people what they -- 7 Q. Okay. And that's the official interpretation of
8 A. Correct. 8 the policy by the University?
9 Q. -- can't believe? 9 A. Currently.
10 A. Correct. 10 Q. Okay. So the entire review of all of these 500
11 Q. Okay. So this statement, you're -- according to 11 plus constitutions was done based on a false statement;
12 your own views of the Human Rights Policy, this 12 is that correct?
13 statement is a false statement? 13 A. No. They were reviewing constitutions, and part
14 A. We can't -- (pause). I -- I -- wonder if that 14 of what was being flagged to be set aside for review by
15 should say "status." 15 General Counsel was any of -- if they had statements,
16 Q. You wonder or you agree that it should say 16 beliefs in there that were counter to the Human Rights
17 "status"? 17 Policy, that would be reviewed by General Counsel.
18 A. It should. 18 Q. But -- but the -- but did -- everyone who was
19 Q. Okay. So the statement that you can't condition 19 reviewing the constitutions. Was looking for the wrong
20 membership or leadership on shared beliefs or purposes 20 kind of language, correct?
21 is false? 21 A. They were responsible for collecting the data,
22 A. Correct. 22 and then the data would be given to Paul -- Paul --
23 Q. The Human Rights Policy does allow you to share 23 Andy, and then Andy and Paul, and then that information
24 or to -- require leaders and members to share beliefs or 24 was in direct communication with -- General Counsel's
25 purposes? 25 Office in term of whether there may or may not be

199 200
1 conflicts. 1 as far as who relates to student groups at that school?
2 Q. Okay. But they would have been flagging language 2 A. Roughly, yes.
3 based on a false understanding, right? 3 Q. Okay. And do you know who Jacob Gordon is?
4 A. Perhaps. 4 A. Jacob Gordon. I'm not recalling off the top of
5 Q. Because this -- this was the official document 5 my head who Jacob Gordon is.
6 they were looking at for guidance? 6 Q. Okay. Do you know who Tevin --
7 A. Yes. 7 A. Yes, Tevin Robbins is a staff member there as
8 Q. And there's nothing in here about status-based 8 well.
9 discrimination, correct? 9 Q. At the --
10 A. Correct. 10 A. In the Tippie College of Business.
11 Q. It only flagged belief-based selection of members 11 Q. Okay. And if you flip over to the second page,
12 and leaders -- 12 the very first line it says -- notes that Court issued
13 A. Correct. 13 an injunction that BLinC is reinstated as a student
14 Q. -- which this says is -- is a violation of the 14 organization?
15 Human Rights Policy? 15 A. Correct.
16 A. Correct. 16 Q. And then the second paragraph says, "I know that
17 Q. So you were just relying on legal counsel to 17 some members of the organization engaged in
18 correct that? 18 discrimination and that that act was not only wrong but
19 A. Correct. 19 hurtful." Do you see that?
20 Q. Okay. Let me ask you to look at Document 128. 20 A. Correct.
21 Do you know who Ken Brown is? 21 Q. And then you see down at the next to the last
22 A. Yes. Ken Brown is the Associate Dean of the 22 line in the middle, it says, "We understand how BLinC's
23 Tippie College of Business and has oversight of their 23 activities are not consistent with our beliefs and
24 student -- Student Services functions. 24 principles of human rights"?
25 Q. So is he your equivalent at the Tippie school -- 25 A. Um-hum.
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 201 202
1 Q. Did you hear anyone else in the -- in the 1 University of Iowa's Human Rights Policy.
2 University administration express these kinds of 2 Q. Did you hear anyone express a concern or express
3 sentiments? 3 a belief that -- that BLinC's actions were evidence of
4 A. (Nodding.) 4 that religious believers are sometimes bigoted?
5 Q. You're nodding your head; is that a "yes"? 5 A. Repeat that again.
6 A. No, I'm just familiarizing myself with the 6 Q. Did any -- did you ever hear any University
7 contents of the communication. And then your question 7 employees or officials --
8 again, please? 8 A. Refer to BLinC's actions as bigoted? No, I
9 Q. Did you hear anyone else in the University 9 wouldn't use -- no, I don't think that was ever --
10 express this kind of sentiment? 10 Q. Did you ever hear them talk about religious
11 A. What -- could you ask your question again? 11 groups -- rights in connection with this whole affair;
12 Q. That BLinC had engaged in discrimination. That 12 speak about religious groups that opposed homosexuality?
13 BLinC's conduct was wrong, that BLinC's activities were 13 I'm sorry. That opposed homosexual activity.
14 inconsistent with the University's beliefs and 14 A. Staff members stating that they -- do not support
15 principles of human rights? 15 homosexuality?
16 A. Yes, that was the Findings from the EOD. 16 Q. Did you -- were you aware of any conversations or
17 Q. But did you have -- did you ever hear other 17 University officials -- officials -- among the
18 University officials express these kinds of feelings 18 University officials --
19 either in person or in email? 19 A. That the group had engaged in discrimination?
20 A. Yes, I -- yes, those that understood the case. 20 Yes.
21 Yes. Like Tom Baker, yes. 21 Q. Okay. Did anybody in the University that you
22 Q. Tom Baker was disappointed in BLinC's actions? 22 worked with that you know of speak up in defense of
23 A. Tom Baker -- I wouldn't -- I don't know if it's 23 BLinC?
24 disappointment or not disappointment. I just know that 24 A. Not that I'm aware of.
25 Tom recognized also that it was a violation of the 25 Q. Okay. You never heard anybody express concern

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1 about whether the whole event was just based on a 1 A. To defend BLinC?
2 misunderstanding of religious beliefs? 2 Q. To defend BLinC or the right for religious
3 A. I don't believe any of my supervisors or 3 organizations to have beliefs that are controversial?
4 supervisees thought it was a misunderstanding. 4 A. Oh, yes, I think -- yeah, the -- there were -- if
5 Q. Okay. And Kristi Finger had no concerns about -- 5 it's -- now I understand your question, yes. There
6 what was her concern? She never talked to you about any 6 were -- there may have been a faculty member or two or
7 concern about the impact that the BLinC Findings would 7 committee member or two that disagreed with the
8 have on other religious organizations? 8 University's position, yes.
9 A. Yeah, I think -- I think she had concerns about 9 Q. Okay. But nobody within the decision making
10 the Finding. I don't think that meant she disagreed 10 group --
11 with them. 11 A. Meaning?
12 Q. Okay. And it never occurred to you that what 12 Q. -- discussed that. You, Lyn Redington, Melissa
13 happened -- what BLinC was doing was just requiring 13 Shivers, your immediate supervisors or supervisees?
14 members to support its religious beliefs? 14 A. I think, there was -- yeah, there was discussion
15 A. BLinC wanted -- students to support their 15 about whether or not this was the right -- you know,
16 religious beliefs. Yes. 16 course of -- course of action because I think there had
17 Q. And you said that's okay? 17 been some historical pieces where -- this was
18 A. Yes. 18 philosophically a -- a different approach than the past.
19 Q. We've established that, right? 19 Q. Was that because they were going more after
20 A. Yes. 20 beliefs than just protecting status?
21 Q. Even if those beliefs concerned homosexuality or 21 A. That was because -- it was more of a shift from
22 other sexual conduct? 22 leadership and membership, would be the differentiation.
23 A. Correct. 23 Q. But really, the policy hasn't changed, correct?
24 Q. Correct? And was there anybody in the University 24 A. Correct.
25 who spoke up to defend that in this entire process? 25 Q. So there was -- the way it was enforced against
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1 BLinC was different; is that what you're saying? 1 please.
2 A. Policy had changed. We've established that, 2 Q. Okay.
3 but -- 3 A. (Pause.) This was a -- a brief prepared to
4 Q. When had the policy -- 4 update the administrative reporting line for Dr. Cory
5 A. But interpretation of the policy in this case, I 5 about where we were at in our review process and kind of
6 believe, had been somewhat different than -- that was 6 an outcome -- general outcome of what we -- the team --
7 part of the discussion. Again, I -- I hadn't been here 7 discovered/learned during the review.
8 as long as some of those staff members that were talking 8 Q. So this would have been passed up the chain?
9 about some of the historical -- allowing groups to -- 9 A. Correct.
10 the membership versus leadership piece. 10 Q. Okay. Do you know who -- do you know who it went
11 Q. Okay. That was a new thing that arose just with 11 to?
12 the BLinC situation? 12 A. Me -- again, I'm trying to -- Lyn Redington was
13 A. That was our first opportunity to have the 13 on an extended leave from the office between when her --
14 conversation after a long time. 14 when -- it became her last day in the office versus her
15 Q. I'm gonna ask you to look at what's labeled 15 retirement and day of leaving the institution -- was
16 Document 131. (Marking.) Do you recognize this 16 extended. Like, she was only in the office a couple of
17 document? 17 days. So I'm not certain whether or not Lyn had access
18 A. Yes. Dr. Cory, I believe, produced this. 18 to this, but Dr. Shivers would have -- and I believe it
19 Q. Okay. 19 would have been shared with the President's Office and
20 A. Yes. 20 the Office of General Counsel.
21 Q. And did you review this document? 21 Q. Okay. And would there have been an email
22 A. I believe so. 22 circulating this?
23 Q. Okay. And who did this -- who was this document 23 A. I believe so.
24 written for? 24 Q. Okay.
25 A. I'm gonna have to take a look at it again, 25 A. I -- I'd have to -- I would have to review,

207 208
1 again, other documents to verify that was the case, but 1 Q. Isn't that true of other groups as well?
2 I know this is Dr. Cory's work. I know the next page is 2 A. I believe there's some, yes.
3 something that I put together, also for -- I believe at 3 Q. In fact --
4 the request of the Vice President. 4 A. The other -- excuse me. Go ahead.
5 Q. Okay. Do you see in the review process where it 5 Q. The Federalist Society, for example, is a
6 says, "The Center for Student Involvement and Leadership 6 national organization. They have a chapter on campus.
7 Staff conducted a review of approximately 500 of the 7 A. Um-hum.
8 more than 550 student organizations"? Do you see that? 8 Q. Were they given extra time or not reviewed?
9 A. Yes. 9 A. I don't believe they were given extra time.
10 Q. Why is -- why was only review done of 500 of the 10 Q. And -- but they were part of the 500?
11 550? 11 A. Correct.
12 A. Fraternities and sororities were not a part of 12 Q. They were not in the --
13 the initial review. 13 A. Correct. Yes.
14 Q. Why not? 14 Q. And do you have any reason -- any explanation for
15 A. Because we were told -- let's -- we were told to 15 why that would be?
16 hold off on them at this point in time because of the -- 16 A. No.
17 kind of the complexities of their -- international-based 17 Q. Okay.
18 constitutions and bylaws. That's the origin of our 18 A. I just know that we -- the decision was made to
19 social fraternities and sororities there -- their 19 set aside fraternities and sororities. That was a
20 constitution and bylaws would be national and 20 decision that was confirmed by the Office of General
21 internationally kind of connected, so the notion of 21 Counsel, and then -- but we did eventually move to
22 calling the -- the chapter president of a sorority and 22 working with them in the very same way, starting in
23 saying, "We need you to do this," would involve several 23 June.
24 layers of consultation with their international 24 Q. Okay. So in June they got emailed, or what did
25 organization representatives. 25 they get?
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1 A. Correct. They got -- they got an email 1 Q. Okay. So -- and that said -- in this document
2 communication. 2 right here it says in the middle of paragraph three, do
3 MR. BAXTER: Okay. I'm gonna note for the 3 you see where it says -- I'm on page that's marked 3981
4 record that I don't believe that email's been produced. 4 on the bottom?
5 BY MR. BAXTER: 5 (The reporter requested a clarification.)
6 Q. Has there just been one communication? 6 MR. BAXTER: Correct.
7 A. There was, I believe, a -- a followup. That 7 BY MR. BAXTER:
8 communication was from Erin McHale. 8 Q. In the middle of that paragraph it says,
9 Q. Okay. 9 "Regardless of category, all organizations are expected
10 A. Erin McHale was our Assistant Director for 10 to adhere to the Human Rights Policy except social
11 Fraternity and Sorority Life Programs, and so Erin 11 fraternities and sororities."
12 communicated on, I believe, June 1 or June 15th -- I 12 A. Sir, where are you at on that page?
13 apologize -- in June -- that they would need to adjust 13 Q. I'm in the middle of the third paragraph.
14 their governing documents to include the modified Human 14 A. Thank you. (Pause.) Was there a question? I'm
15 Rights Policy that we referenced earlier, that had the 15 sorry.
16 exemption related to Fraternity and Sorority Life. I 16 Q. You've -- you've read that?
17 believe that was also part of the delay -- my 17 A. Yes.
18 understanding, from the Office of the General Counsel, 18 Q. Okay. Is there -- why were the fraternities and
19 was that particular piece, in terms of what the exact 19 sororities given a -- that exception?
20 language would be used in the Human Rights Policy that 20 A. The -- a couple of -- a couple of issues. The
21 would apply to fraternities and sororities because of 21 fraternity and sorority constitutions and bylaws were
22 Title IX. 22 not in the OrgSync portal because fraternities and
23 Q. And were there any other exceptions made for 23 sororities are -- receive their recognition -- their
24 fraternities and sororities? 24 registration, their recognition to their respective
25 A. I don't believe so. 25 counsels.

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1 Secondly, there was a question posed to General 1 Q. Okay. So you're just acting on instruction, you
2 Counsel about how to manage the Title IX exemption. 2 don't have any reason or any personal --
3 Q. What's your understanding of what the Title IX 3 A. Well, it -- it --
4 exemption is? 4 Q. -- stake in it?
5 A. As I shared earlier, that is an exemption that 5 A. Absolutely, I have a personal stake and I have a
6 the institutions have, as relates -- my contact with 6 professional stake in it, and it's the notion that, as
7 fraternities and sororities is much broader than that, I 7 it currently reads, fraternities and sororities, because
8 understand. But that there's an exemption that the 8 the exemption piece wasn't in there, it was the opinion
9 institution can enact to -- so that fraternities and 9 that it could give the appearance of not being accurate
10 sororities can operate as single sex organizations. 10 because we need the -- we thought it was important to
11 Q. Okay. So your understanding is that the law 11 draw out the exemption language.
12 allows Universities to let fraternities do that? 12 Q. Okay. Do you know that Title IX has a religious
13 A. Well, I -- well, the point I'm trying to make is 13 exemption in it?
14 the exemption is for the institution to make that. 14 A. I'm not familiar with that part.
15 Fraternities and sororities themselves aren't 15 Q. Okay. But if there were, would it make sense to
16 quote/unquote exempt from Title IX. 16 you to also give religious organizations a religious
17 Q. Okay. So is there any reason why you had to 17 exemption?
18 exempt fraternities and sororities from the sex -- 18 A. That would make sense.
19 nondiscrimination requirement? 19 Q. And -- what about sports teams? Does the
20 A. I -- 20 University of Iowa's official team -- official teams,
21 Q. It sounds like you're saying that you could, 21 are they segregated on the basis of sex?
22 under Title IX, but is there any reason why you have to? 22 A. Yes. We have -- yes, sports, yes. Division --
23 A. Again, I -- that's a General Counsel Office 23 NCAA groups, are you talking about?
24 direction that we were wanting to receive. I'm not 24 Q. Yes.
25 certain. 25 A. NCAA groups. Yes.
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1 Q. And that technically violates the Human Rights 1 sports-centered?
2 Policy, correct? 2 A. No.
3 A. There's a long -- perhaps. A long established 3 Q. So if you have a women's football team at the
4 NCAA -- that that's been allowed to happen. 4 University, is it your understanding that they have to
5 Q. Regardless of what the NCAA does, the University 5 admit men to play on their team?
6 could have its own policy, right? It could say, "We're 6 A. Are you referencing sports clubs at this point?
7 gonna dis -- we're gonna forbid discrimination"? 7 Q. Correct.
8 A. It could. 8 A. Yeah, we've long -- long allowed sports clubs to
9 Q. Okay. And is there any written exception in the 9 be single sex. The men's volleyball team, the --
10 Human Rights Policy or the University's 10 Q. So I'm talking about student organizations --
11 nondiscrimination policy that allows University sports 11 A. Um-hum.
12 teams to discriminate on the basis of sex? 12 Q. -- Registered Student Organizations.
13 A. No. 13 A. (Nodding.)
14 Q. Okay. So technically they're in violation of 14 Q. If there were a women's football club that had
15 their own policies? 15 registered status, would it be okay for them to exclude
16 A. Yes. 16 men from membership?
17 Q. Okay. 17 A. No.
18 (A discussion was held off the record during 18 Q. So they have to admit men?
19 which time the reporter requested that the 19 A. Umm --
20 parties speak more slowly.) 20 Q. If a man wants to join a women's club that's sole
21 MR. BAXTER: I will slow down. 21 purpose is to get together to pay football, they have to
22 BY MR. BAXTER: 22 let him come and play?
23 Q. Is there any reason then -- so was this exemption 23 A. I -- I don't know if we've had that kind of a
24 for fraternities and sororities extended to student 24 case come before us to see how -- what we -- how we
25 organizations that have sports -- that are 25 would respond to that.
215 216
1 Q. Well, just -- just tell me how you would 1 Q. Not even with the spirit?
2 interpret the Human Rights Policy right now if that 2 A. No.
3 question came to you. 3 Q. Because the University's goal is to stop any kind
4 A. It would be. 4 of status-based discrimination, no matter how much sense
5 Q. That's status-based discrimination, right? 5 it makes?
6 A. Correct. Correct. 6 A. No.
7 Q. And so the women -- 7 Q. So what's the real purpose of the Human Rights
8 A. It would be. 8 Policy?
9 Q. -- cannot do that? 9 A. It is to protect classes that have been decided
10 A. Correct. 10 by law to be protected. Federal law, state law.
11 Q. Okay. And would you -- do you think the 11 Q. Okay. What about --
12 University would make an exception? 12 A. Equal opportunity and access, et cetera.
13 A. Perhaps. 13 Q. What about a women's a cappella group? If a man
14 Q. Okay. And why might they make an exception? 14 wanted to join, and he couldn't -- and he was a bass,
15 A. Historical reasons. 15 would they be required to join -- let him join?
16 Q. Okay. 16 A. Right. We haven't had that situation so, again,
17 A. Long standing traditions that have been 17 I think it would go back to if we would have looked
18 acceptable for extended periods of time. 18 at -- we would have looked at the situation like that,
19 Q. And would that all be consistent with the spirit 19 if a man tried to join, he was denied that opportunity,
20 of the Human Rights Policy? 20 and we received a complaint, we would look into that.
21 A. Would all what be? 21 Q. And if he was denied just because he was a man,
22 Q. With those types of -- making exceptions for 22 you would have to find -- that there was a violation?
23 those reasons, would that still be consistent with the 23 A. Correct.
24 spirit of the Human Rights Policy? 24 Q. And you would sanction that organization?
25 A. No. 25 A. Correct.
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1 Q. And basically force them to admit him? 1 correct?
2 A. We would have ruled that you cannot violate the 2 A. Correct.
3 University of Iowa's Human Rights Policy. 3 Q. Okay. So is there any reason why you would give
4 Q. And the only way to do that would be to admit 4 fraternities an exception to sex nondiscrimination
5 him, right? The only way to not violate the policy is 5 policy, but not sports teams -- or sports clubs?
6 to admit him? 6 A. We allow sports clubs. We do have single gender
7 A. Correct. 7 sports clubs.
8 Q. Is it fair to say that there are lots of 8 Q. But you've admitted that that's in violation of
9 complexities with the Human Rights Policy that you have 9 the Human Rights Policy, correct?
10 not thought through? 10 A. If that's what was found to be the case -- the
11 A. Yes. Yes. 11 outcome of a hearing.
12 Q. And -- 12 Q. So you'd -- even though there's a club on campus
13 A. Me personally, or the University of Iowa? 13 called the men's football team?
14 Q. Well, you personally. 14 A. We've allowed them to be registered.
15 A. Yeah. There's -- there's -- I thought through -- 15 Q. And you turn a blind eye to that potential
16 never thinking through these would not be accurate. I 16 violation of the Human Rights Policy?
17 thought through a lot of this. And there are 17 A. We have.
18 complexities and there -- to say I've not thought 18 Q. And that's a -- why have you done that?
19 through them is not accurate. 19 A. We have not received a complaint.
20 Q. Okay. Is -- would you say that there is a fair 20 Q. You only enforce based on complaints?
21 bit of discussion, just generally, you know, across the 21 A. Correct.
22 nation about the value of fraternities and sororities? 22 Q. But now you're going to require all men's sports
23 A. Yes. 23 teams to fully integrate? That's --
24 Q. And there are some people who think that 24 MR. CARROLL: Just a minute now, you're
25 fraternities contribute to misogyny/homophobia; is that 25 mixing two things here. Are you talking about
219 220
1 Division I teams? 1 change their name or anything like that?
2 MR. BAXTER: I'm talking about sports -- I'm 2 A. Correct.
3 talking about the -- 3 Q. Okay. I'm gonna ask you to look at Document
4 MR. CARROLL: Clubs? 4 Number 132. Do you recognize that document?
5 MR. BAXTER: -- the clubs. 5 A. That is the spreadsheet that I referenced
6 MR. CARROLL: Registered clubs, because, 6 earlier.
7 obviously, the football team is not a registered group. 7 Q. What spreadsheet is that?
8 MR. BAXTER: Right. It is subject to the 8 A. This was -- this was the compilation of the
9 University Civil Rights Policy. 9 review that happened. So after the -- after the review
10 MR. CARROLL: Right. But -- but -- 10 of -- I believe this was in the category Registered
11 MR. BAXTER: But it's not a Registered 11 Student Organization, then -- it's self-explanatory in
12 Student Organization. 12 terms of whether or not --
13 MR. CARROLL: Yeah. 13 Q. So -- continue.
14 A. Back to your question now. 14 A. Yeah. No. Whether or not the violations --
15 Q. So you turned a blind eye to this for all of 15 Q. So you --
16 these years, but now you're going to start requiring 16 A. -- are a potential conflict.
17 student clubs -- student sports clubs that are sex-based 17 Q. Is it your understanding that this is the
18 to integrate? 18 spreadsheet that should have all 500 student
19 A. We are not, that I am aware of at this point in 19 organizations on them?
20 time. Sports clubs are administered through 20 A. The initial effort involved registered --
21 Recreational Services. 21 religious student groups.
22 Q. Okay. So you -- as far as you know, they're 22 Q. Okay. Why did you review religious groups first?
23 going to continue to be allowed to be single sex clubs? 23 A. That was what we were directed to do by the
24 A. Correct. 24 General Counsel's office, to look at them first.
25 Q. Okay. And you're not going to require them to 25 Q. So before you sent the April 20th emails --
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1 A. Correct. 1 Q. Okay. And is there a spreadsheet like this one
2 Q. -- you conducted an internal review? 2 for all of the other groups?
3 A. That was what happened in late -- that's what 3 A. We tracked the information. I don't know if we
4 happened late -- yes, late January and February, and 4 tracked it in a spreadsheet form or not.
5 then the review happened for all the groups, but we were 5 Q. Okay. I think I mentioned to you an Excel
6 asked about this specifically. 6 spreadsheet earlier that was a missing document, and
7 Q. Okay. So was this the first group you reviewed, 7 that document has now been produced to us. I'm entering
8 these -- groups on this spreadsheet? 8 a request for it to be reproduced.
9 A. They did them -- yes, this was done first. 9 I'm going to ask you to flip back to Document 131
10 Q. Okay. And was there any other category that you 10 in front of you.
11 specifically looked at besides religious groups? 11 A. Yes.
12 A. This -- these were done first. 12 Q. In the back of that there's another copy of a
13 Q. Okay. 13 similar spreadsheet; do you see that?
14 A. And then shortly thereafter everybody. All of 14 A. Correct.
15 the -- all of the groups. 15 Q. Okay. And there's actually two copies of it. Do
16 Q. When you say "all of the groups --" 16 you see that? If you -- if you flip through the
17 A. All of the Registered Student Organizations. 17 Document 131, there's two copies of this -- of a similar
18 Q. Okay. So were all of the constitutions reviewed 18 looking spreadsheet.
19 before the April 20th email? 19 A. Um-hum.
20 A. Yes. That -- the review occurred late January 20 Q. I think the first of those --
21 and February, and then there was the subsequent dates 21 MR. BAXTER: Do you have that copy that I
22 that we talked about, the -- April 20 -- April 20th and 22 had?
23 May 3rd, and then the June 1, June 5th -- or 15th. So 23 MR. BLOMBERG: Oh, isn't that in your
24 there was -- the -- reason it occurred before we 24 notebook?
25 communicated with all of those groups. 25 BY MR. BAXTER:

223 224
1 Q. Okay. I'm gonna ask you to look at the first 1 Q. Okay. Now, I want you to look at the same column
2 attachment -- the first attachment to Document 131. 2 on Document 132.
3 A. Okay. 3 A. Okay.
4 Q. And I want you to look at the -- on the far right 4 Q. This is even tinier, but can you see where the
5 column. It says "Applicable language from the org's 5 last one ended with the -- with the word -- the words
6 constitution." 6 "communicated with integrity," there's more after. Can
7 (The reporter requested a clarification.) 7 you read what's after that?
8 MR. BAXTER: From The org's -- 8 A. Yes. "Corinthians, Chapter 6, verses 9-12,
9 o-r-g-apostrophe-s constitution. 9 explicit statement about homosexuality. Several other
10 BY MR. BAXTER: 10 bias verses that related to sexual immorality."
11 Q. And then the third column down, can you read what 11 Q. And I believe that says "Several other Bible
12 that says? 12 verses --"
13 A. "The -- all voting members"? 13 A. Oh, excuse me.
14 Q. No, "The selection process." 14 Q. "-- that related to sexual immorality."
15 A. Okay. Excuse me. "Athletes in Action"? 15 A. I apologize. I --
16 Q. Yes. 16 Q. Okay. So do you know why there's two different
17 A. "Selection process: Only those applicants who 17 versions of this spreadsheet?
18 can communicate the chapter's message accurately, can 18 A. Yes, I believe this was an initial review.
19 provide spiritual leaders for the chapter, and can model 19 Q. When you say "this," what do you mean?
20 the chapter's message in their behavior shall be 20 A. Excuse me. The -- I don't remember the numbers.
21 eligible for a leadership position. Applicants -- 21 Q. The document's are on the bottom, on the -- on
22 excuse me -- applicant may be asked about their 22 the front page, at the bottom.
23 willingness to model the chapter's core messages through 23 A. Yeah. This here (indicating) being an initial
24 their behaviors so that the messages are communicated 24 review.
25 with integrity." 25 Q. Before you go, just, will you flip to the front
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1 page and tell me what number it is? 1 A. Numbers --
2 A. 131. 2 Q. When you say that --
3 Q. Okay. 3 A. Excuse me.
4 A. This being an initial review (indicating), and 4 Q. -- Number 131 --
5 this being a subsequent review (indicating). 5 MR. CARROLL: She's gonna wear out, and
6 Q. And when you say "the subsequent review," that 6 she's gonna kick us out, so you -- you both have to
7 would be Document -- 7 really pay attention to -- let him finish his question
8 A. 132. 8 and then you can answer. Okay. Because you are talking
9 Q. -- 132? Why were there two different reviews? 9 over each other.
10 A. This was an -- I believe -- 10 THE WITNESS: I apologize.
11 Q. 130 -- when you say "this," you're referring to 11 MR. CARROLL: Well, that's fine but --
12 Document -- 12 THE WITNESS: I'll try to do it differently.
13 A. 131 -- 13 BY MR. BAXTER:
14 Q. -- 131? 14 Q. So just to -- the document in your --
15 A. -- was an initial review. 15 A. 131.
16 (The reporter requested that one person speak 16 Q. -- left hand is 131?
17 at a time.) 17 A. Correct. Correct.
18 MR. BAXTER: Sorry. I'm sorry. We'll slow 18 Q. Okay. So that one was -- was 131 the initial
19 down. 19 review or the subsequent review?
20 (A discussion was held off the record.) 20 A. The initial review.
21 THE WITNESS: I apologize. 21 Q. Okay. And then -- 132 was the subsequent review?
22 MR. BAXTER: As do I. As do I. 22 A. Correct.
23 A. This was an initial review. This was a 23 Q. And why --
24 subsequent review. 24 A. As I recall.
25 Q. I'm sorry. I'm gonna stop you. 25 Q. And why was there a subsequent review?

227 228
1 A. For -- to gather, like, a double-check and to 1 A. I was providing her an update of our -- of our
2 make certain another set of eyes, et cetera, and I 2 effort related to religious student organizations, and I
3 believe this latter one was done -- Andy Kutcher was -- 3 was clarifying the 31 versus 32, being that we were
4 again, with help from Paul or Anita, depending on the 4 asked to not look at BLinC.
5 timing. 5 Q. As far as you're aware, was the President of the
6 Q. So it's your -- 6 University Bruce Herrald ever consulted or informed
7 A. It was Anita at this point in time, I believe. 7 about the review of the constitutions?
8 Q. So it's your understanding that the second 8 A. Yes.
9 document was done by Anita and Andy themselves? 9 Q. Okay. And do you know -- did you ever have a
10 A. Correct. I -- I believe so. 10 direct communication with him?
11 Q. And the first document would have been done by 11 A. I'm trying to remember if we were in the same
12 whom? 12 room together for any conversations. Melissa and I
13 A. The compilation of -- of information from the 13 certainly were. I may have been. I apologize for not
14 reviewers and Paul, and this being a second in-depth 14 recalling.
15 look. More in-depth look. 15 Q. Do you know anybody at Iowa State University
16 Q. I am gonna hand you what is Document 133. 16 name -- whose last name is Braun, B-r-a-u-n?
17 (Marking.) What is this document? 17 MR. CARROLL: You said Iowa State.
18 A. A communication to Melissa about the groups that 18 MR. BAXTER: Yes.
19 were -- Dr. -- Vice President Shivers about the 19 MR. CARROLL: Did you mean that?
20 Registered Student Organizations that were reviewed. 20 MR. BAXTER: Yes.
21 Q. Okay. And this was just the religious 21 BY MR. BAXTER:
22 organizations; is this correct? 22 Q. Iowa State University, not University of Iowa.
23 A. Correct. 23 A. Mark -- I don't -- I don't --
24 Q. And do you know why she wanted a specific list of 24 Q. Please, I'm just asking if you know someone
25 religious organizations? 25 named -- whose last name is Braun at the University --
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 229 230
1 at Iowa State University? 1 Board of Regents was regularly informed about the status
2 A. I know someone named Braun, but their affiliation 2 of the BLinC lawsuit?
3 is broader than Iowa State University. 3 A. I believe they were informed.
4 Q. Oh, okay. Would they have an Iowa State address? 4 Q. And why do you believe that?
5 A. Yes. 5 A. Because that's the normal course of action for
6 Q. Okay. Who is that? 6 the Vice President to communicate with the President
7 A. I believe -- depending on what you have in front 7 who, in turn, communicates with the Board, or the Vice
8 of you -- 8 President can communicate with the Board when directed.
9 Q. Well, I'm just asking the person you know. 9 Q. Okay.
10 A. Mark. 10 A. I, personally, in my capacity, don't communicate
11 Q. I'm not asking you what -- 11 directly with the Board.
12 A. Mark Braun. 12 Q. Are you aware of any statements or -- of concern
13 Q. Don't talk over me. 13 or interest that the Board has communicated -- or
14 A. I apologize. 14 members of the Board have communicated to --
15 MR. CARROLL: If I may just interject, just 15 A. I --
16 it's a little complicated. It's just Mark Braun is the 16 Q. -- someone at the University?
17 Executive Director of the Board of Regents. They just 17 A. I know that one Board -- what I know -- there
18 by -- historically use Iowa State's email address. So 18 could be multiple because, again, I'm not privy to all
19 he's not an Iowa State employee. He's an employee of 19 of those communications, but I know one regent did reach
20 the Board of Regents. 20 out to -- and have concerns to Melissa. Melissa told
21 MR. BAXTER: Okay. 21 me.
22 MR. CARROLL: So it's -- it's just 22 Q. And which regent was that?
23 sufficiency whose email server they use. 23 A. I believe Boddicker.
24 BY MR. BAXTER: 24 Q. And did Melissa tell you what the regent's
25 Q. Okay. And do you know -- do you know if the 25 concerns were?

231 232
1 A. Yes. But that was quite some time ago, and I 1 Q. Do you recognize --
2 would not want to portray that inaccurately. 2 A. Yes.
3 Q. Well, what do you remember about it? 3 Q. -- this document?
4 A. That she was concerned about the University's 4 A. Yes. Professor I referenced.
5 positions, in general, I recall. 5 (The reporter requested a clarification.)
6 Q. That she thought the University's position was 6 THE WITNESS: Yes. The professor --
7 correct or incorrect? 7 professor I referenced earlier.
8 A. Incorrect. 8 BY MR. BAXTER:
9 Q. Okay. And do you remember anything specifically 9 Q. Remind me what professor you're referring to.
10 why she thought it was incorrect? 10 A. Michelene Pesantubbee. It's -- it's the --
11 A. So many conversations. I believe religious -- 11 that's -- I referenced -- you'd asked a question earlier
12 religious freedom. Related -- violating the group's 12 about concerns. One of the concerns that came in was
13 religious freedoms. 13 from a professor, Dr. Michelene Pesantubbee.
14 Q. Okay. I'm gonna ask you to look at Document 140. 14 Q. Okay. What was the -- have you had a chance to
15 MR. CARROLL: Can we take a break at this 15 look at this email and refresh your recollection?
16 time? 16 A. Yes.
17 MR. BAXTER: This would be a great time. 17 Q. What --
18 (A discussion was held off the record.) 18 A. She was -- she was concerned about another
19 (A recess was held from 3:18 p.m. until 3:25 19 situation that was similar, and I -- I was really
20 p.m.) 20 nebulous in my response because, again, as the
21 MR. BAXTER: Back on the record. 21 litigation was pending, I didn't feel that I could -- I
22 BY MR. BAXTER: 22 should be talking much.
23 Q. I'm going to hand you what's been marked as 23 Q. What was her specific concern?
24 Exhibit 140. (Marking.) 24 A. A group and a book -- a booklet had been used as
25 A. Um-hum. 25 a proselytizing tool, I recall, to lead a group --
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1 Q. Well -- 1 send through the email?
2 A. -- and the connection. Oh, please. 2 A. There's issues related to -- length. There are
3 Q. Do you see the bottom of the first page where it 3 issues -- it's a little convoluted, and there's layers
4 says "Original Message"? It's under Michelene's name. 4 of the mass email system. Some go to just students.
5 A. Yes, yes. 5 Some go to students and faculty. Some go to just
6 Q. And then that original message was from Imam 6 faculty. There's several layers, and depending on the
7 Mahdi Org, and that's spelled I-m-a-m, M-a-h-d-i, Org. 7 layers, drives a little bit on how long they can be, who
8 Is Imam Mahdi a student group on campus? 8 has to approve them, but they're not censored for
9 A. Yes, it is. 9 content.
10 Q. Okay. And in the subject line it says, 10 Q. Okay. So is there any problem with Imam Mahdi
11 "NonAcadStudorg." 11 having expressed the views that they do in this email?
12 A. Correct. 12 A. No.
13 Q. Do you know what that refers to? 13 Q. So at the top of that document you say, "At some
14 A. Yes, this would be a mass email that was sent by 14 point this nuance needs to be brought into the
15 the sender through the University's mass email process 15 discussion." What did you mean by that?
16 for Registered Student Organizations. 16 A. Um-hum. That I didn't think it was appropriate
17 Q. And so Professor Pesantubbee was complaining 17 at that point in time, but I think what is appropriate
18 about the content of the email, correct? 18 is that we perhaps need to have a broader communication
19 A. Correct. 19 to the University campus about what is acceptable and
20 Q. Because she thought it was proselytizing? 20 not acceptable mass emails because we often hear
21 A. Correct. 21 concerns from faculty and staff about, "Why are you
22 Q. Do all student organizations have access to this 22 letting that out? Why are you allowing that statement
23 email? 23 as such?" And so nuance, being she was complaining
24 A. Correct. 24 about it, and response would be we allow all of our
25 Q. And are there any rules that govern what they can 25 groups to do that.

235 236
1 Q. Okay. I'm going to show you what's been marked 1 Q. Okay. And you have supervisory authority over
2 as Document 141. Are you familiar with this document? 2 that office?
3 A. Yes. 3 A. Correct. One of the areas that reports to me.
4 Q. What is it? 4 One of the departments.
5 A. A communication about some of the -- an update, 5 Q. Ask you to look at Document 143. (Marking.) Are
6 if you will, about our compliance efforts, our outreach 6 you familiar with this document?
7 student orgs, our review of constitutions, peppered with 7 A. Yes, I am.
8 specifics related to fraternities and sororities. 8 Q. And the bottom email in this chain, is that the
9 Q. And do you know who drafted it? 9 June 1st email that we've previously discussed?
10 A. From the outer page, I believe Andy Kutcher. And 10 A. Correct.
11 this, again, is in reference to how we were going to -- 11 Q. And at the top, what were you -- what was
12 as we discussed earlier, our subsequent outreach to 12 Melissa -- or what were you saying to Melissa?
13 fraternities and sororities. 13 A. This was the communication that again went out, a
14 Q. Okay. And do you know who drafted this second 14 reference that I had worked with Andy on the first
15 half? If you turn to the next page it says -- 15 communication, and -- that went on June 15th at -- and
16 A. Paul and -- Paul -- Andy Kutcher and Erin McHale 16 was related to due date on June 15th. I shared with her
17 had a -- I'm sure, had a level of -- of edit -- writing 17 what we had worked on together, and then I was
18 and editing. 18 forwarding that to her, and the -- the little joke in
19 Q. Do you see at the next -- bottom of the next 19 here is that I am -- I am the advisor to the University
20 page, number 3713, it says, "Sincerely, Center for 20 of Iowa Student Government, UISG. So they weren't
21 Student Involvement and Leadership"? 21 compliant. Our goal was to get groups compliant. I'm,
22 A. Um-hum. Um-hum. 22 obviously, very, very involved, and one of the groups I
23 Q. This was drafted by your office; is that correct? 23 advised directly wasn't compliant. So I referenced
24 A. It was constructed by the Center for Student 24 myself as being a terrible advisor.
25 Involvement and Leadership. 25 Q. Got it. (Marking.) Ask you to look at Document
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1 Number 150. Do you recognize this document? 1 Q. Okay.
2 A. Yes. 2 A. I would imagine they got it from Strategic
3 Q. And what is it? 3 Communications, which is the connection between the
4 A. It's a doc -- it's an update about compliance, 4 University --
5 sent by Erika Christiansen in Andy Kutcher's absence. I 5 (The reporter requested a clarification.)
6 believe he was on vacation for a period of time, and 6 THE WITNESS: Between the University --
7 Erika became a point person. 7 Strategic Communication is the -- kind of portal
8 Q. Okay. And these -- what's on this document? 8 through --
9 What are these groups? 9 (The reporter requested that the witness only
10 A. The groups that weren't compliant in terms of 10 finish his sentence.)
11 having the current accurate full Human Rights Policy 11 MR. CARROLL: Yeah.
12 included in this -- in their document. 12 THE WITNESS: Media. And media. Yeah,
13 Q. So is it possible that this list is no longer 13 Media.
14 accurate; that some students, for example, have 14 BY MR. BAXTER:
15 submitted corrected constitutions? 15 Q. Do you know which nine have been reinstated from
16 A. Correct. 16 the 39?
17 Q. Okay. Did you see the article in the newspaper. 17 A. Off the top of my head, no. I have -- I
18 In the Gazette a week or so ago, talking about the 18 have -- a binder full of that information, but I don't
19 University of Iowa had deregistered 39 student groups? 19 have that off the top of my head.
20 A. Correct. 20 Q. Okay. And that's information you could provide
21 Q. And did that list come off of this? 21 to us?
22 A. I'm not certain where they got that number. I 22 A. The nine? Absolutely.
23 know that number has now changed. It was 39 originally. 23 MR. BAXTER: Okay. And I understand the
24 It's now 30. The origins, how they got that 24 request that we get updates --
25 information, I'm not quite certain. 25 MR. CARROLL: Um-hum.

239 240
1 MR. BAXTER: -- and the discovery requests 1 Q. And you --
2 are still ongoing. 2 A. Twenty-five; 24, 25.
3 BY MR. BAXTER: 3 Q. And do you have a list of which groups those are?
4 Q. Going back to that document, are those the 4 A. Yes.
5 only groups left that could be deregistered based on 5 Q. Okay. Can you provide that list to us?
6 this review? 6 A. Yes.
7 A. No. The Fraternity and Sorority Life, the -- the 7 Q. All right. Do you know why they're being held
8 chapters are given until September 4th or 5th, the first 8 up?
9 part of September, to be compliant. There's a meeting 9 A. They -- yes. They were the ones where we had --
10 that's occurring on August 13th to discuss all this. 10 that they resubmitted, and based on the resubmission,
11 Q. Okay. Other than the fraternities and 11 caused staff not to -- it wasn't clear whether or not it
12 sororities, if a -- if a student group is not on this 12 was acceptable, and we wanted General Counsel to give us
13 list, and they have a constitution on OrgSync, they have 13 directions to whether it was acceptable.
14 been officially approved; is that correct? 14 Q. And they just haven't gotten back to you yet?
15 A. Yes, with the exception of those that are with 15 A. Correct.
16 the Office of General Counsel for their review. 16 Q. So there are 24 or 25 groups out there that don't
17 Q. So there still are some documents that are 17 know yet what their status is?
18 subject to review? 18 A. Of the 24 and 20 -- of that -- of that number --
19 A. Correct, in the Office of the General Counsel. 19 they know that -- if they're registered or deregistered.
20 We have forwarded them for their -- to provide counsel 20 Q. But they don't know yet --
21 for us, what to do. 21 A. But they --
22 Q. And how many of those documents -- how many 22 Q. -- if they will be deregistered as a result of
23 groups are still looking for review of the General 23 your review or General Counsel's review?
24 Counsel's Office; do you know? 24 A. Correct. As I -- as I'm remembering, there's
25 A. Twenty -- 24. 25 about 17 -- of that 20 -- I can't remember if it's 24 or
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1 25 -- there's 17 that are -- registered. Roughly, 1 Exhibit 154. (Marking.) Do you recognize these
2 seven -- seven or eight that are deregistered. 2 documents?
3 Q. And they were deregistered because they were 3 A. Yes.
4 already not in compliance? 4 Q. And what are they?
5 A. Correct. They missed the submission -- they 5 A. A further capturing of -- of -- of potential
6 missed the submission date, and they became 6 problems with alignment of language and the University
7 deregistered, and then if everything would have been -- 7 of Iowa's Human Rights Policy.
8 acceptable based on staff review they worked on 8 Q. Are these documents that would have been created
9 automatically to reregister, but because there was 9 during the review last January and February?
10 questions, they went back to the General Counsel's 10 A. And -- and beyond, with subsequent -- because of
11 Office for review. 11 the followup.
12 Q. Okay. So there are 24 or 25 student groups that 12 Q. Should there have been a review sheet for every
13 still could hear word that they've been deregistered for 13 student group on campus?
14 failure to comply with the Human Rights Policy? 14 A. I believe there was a review sheet for every
15 A. Correct. 15 group that was being reviewed.
16 Q. And will they get -- does every student group get 16 Q. And every group, except the fraternities and
17 a written notification once they've been approved? 17 sororities, got reviewed last January or February,
18 A. Yes. 18 correct?
19 Q. Okay. So if someone has received no 19 A. Yes.
20 notification, that means their renewed constitution is 20 Q. Okay. So there should be about 500 of these?
21 still in General Counsel's Office? 21 A. Correct.
22 A. Yes. I want to -- I will need to double-check 22 Q. And I only counted 109. I could be wrong, but
23 with Andy to understand exactly what's been 23 your understanding there should be another 400 pages or
24 communicated. 24 so out there?
25 Q. Okay. I'm gonna show you what's marked as 25 A. They reviewed over 500.

243 244
1 Q. Okay. And you could -- 1 you know what the outcome should be?
2 A. Whether or not -- 2 A. In terms of invitations?
3 Q. Please go ahead. 3 Q. In terms of whether the requirement that one must
4 A. Whether or not they completed this actual form 4 be invited to be a part of the student group, whether
5 for all of them, I will need to have to check on that. 5 that violates the Human Rights Policy or is somehow
6 Q. Okay. And you can check that for us? 6 inconsistent with that policy?
7 A. Yes. 7 A. One does not have be invited to join.
8 Q. Flip through the one that's numbered, at the 8 Q. Well, this suggests, doesn't it, that the U.I.
9 bottom, 1828. 9 Men's Club Soccer student organization has a requirement
10 A. Okay. 10 that one must be invited? Isn't that a fair conclusion
11 Q. This is the U.I. Men's Soccer -- Club Soccer? 11 because someone flagged that as language that was
12 A. Oh, 28. Excuse me. Yes. 12 inconsistent with the Human Rights Policy?
13 Q. Okay. And then it says, "Please summarize in 13 A. I would imagine what that means is everybody has
14 consistent language," and then someone has handwritten 14 the opportunity to try out, and then they select
15 "One must be invited." Close quote. 15 their -- the team base, but everybody -- but it's open
16 A. Um-hum. 16 for tryouts for all.
17 Q. Is a requirement that someone has to be invited 17 Q. But as far as you know, should that be -- you
18 to join a student organization -- is that a problem from 18 know, what if it were an invitation-only student
19 the University's perspective? 19 organization, do you think that would be a problem?
20 A. I think it was a notation from the reviewer to 20 A. For -- membership?
21 quote/unquote flag it for further review by Andy. 21 Q. Correct.
22 Q. And do you know what the outcome of that review 22 A. We have student organizations that have -- you
23 was? 23 have to be invited to join.
24 A. I do not. 24 Q. And that's okay under the Human Rights Policy?
25 Q. And based on your understanding of the policy, do 25 A. Correct.
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1 Q. Okay. And that's to be invited to be a member? 1 Q. Now, InterVarsity Graduate Christian Fellowship
2 A. Correct. 2 is on the list of 39 that the -- well, they've received
3 Q. Okay. Will you turn to the -- the document 3 an email, actually, that they were deregistered.
4 that's tabbed as -- I mean, labeled 2107 at the bottom? 4 A. Yes. And as I said earlier. Of the 24 that are
5 And then it says "General Members," where it -- where it 5 in the General Counsel's Office, 17 are deregistered.
6 asks the reviewer to flag inconsistent language, it 6 MR. BLOMBERG: I believe it's the other way
7 says, "General members have no requirement. Executive 7 around.
8 board members must subscribe to Basis of Faith as 8 A. Excuse me, I apologize, yes. Seventeen
9 outlined in the constitution." 9 registered, and to my -- to the best of my knowledge, 17
10 A. Correct. 10 registered, seven deregistered.
11 Q. Okay. And are you aware that InterVarsity 11 Q. So is it your understanding that no decision has
12 Graduate Christian Fellowship was one of the 12 been made about InterVarsity's religious requirements
13 organizations that was kicked off campus? 13 for leaders?
14 A. They were de -- they are deregistered, yes. 14 A. I don't believe there's been a final decision.
15 Q. Okay. And do you know why they were 15 Q. And what are you basing that on?
16 deregistered? 16 A. The fact that my understanding is it's still
17 A. They didn't complete their -- by the -- I believe 17 pending with the General Counsel's Office.
18 they were one of the groups that didn't meet the 18 Q. And are you aware that InterVarsity has filed a
19 deadline. 19 lawsuit against the University?
20 Q. So theirs was just a deadline issue? 20 A. Yes.
21 A. No. I think there were issues also that were 21 Q. But you think that's premature?
22 flagged based on the executive board members having to 22 A. Depending on the outcome of the review from
23 subscribe, which again was something that was flagged. 23 General Counsel and guidance they provide us, it could
24 This group was one of the groups that is pending with 24 be.
25 the Office of the General Counsel. 25 Q. Okay. I'm gonna show you what's been marked as

247 248
1 Document 167. (Marking.) Why don't you take a minute 1 the bottom of the page marked 7993 --
2 and familiarize yourself with that email? 2 A. Um-hum --
3 A. Thank you. (Pause.) 3 Q. -- there's an email from Katrina, correct?
4 Q. Have you had a chance to review that email? 4 A. Correct.
5 A. Yes. 5 Q. And it states, "I was under the impression that
6 Q. Okay. Let's start at the back, the bottom of the 6 the InterVarsity Graduate Christian Fellowship's
7 email chain, and walk through this. Do you see on the 7 constitution had been updated and submitted June 1st or
8 bottom of the page marked 7994, the next to last page -- 8 2nd." Do you see that?
9 A. Yes. 9 A. Correct.
10 Q. -- at the very bottom it says "Original message 10 Q. And then above that, Andy jumped in and asked
11 from Laurynn King"? 11 Katrina if she used the OrgSync form.
12 A. Correct. 12 A. Correct.
13 Q. And who is Laurynn King? 13 Q. And then Katrina says that she's done that now.
14 A. Laurynn King is an Administrative Assistant for 14 "Let me know you if you need anything else" --
15 the Center for Student Involvement and Leadership. 15 A. Correct.
16 Q. Okay. And do you see on the next page where she 16 Q. -- or something to that effect. And then on 7992
17 sent an email to Tiffany and Lyubov, L-y-u-b-o-v, 17 Andy says to Katrina, "On my initial review I see
18 indicating that she's following up on several emails and 18 several issues."
19 voice mails that she's left? 19 A. Um-hum.
20 A. Correct. 20 Q. "As part of compliance with the Human Rights
21 Q. Okay. And then moving up the next email, 21 Clause, organizations cannot have any language deemed
22 Tiffany responds and says, "Hi Laurynn," she's 22 contradictory to that clause." And then he cites
23 forwarding it to the new leadership team? 23 specific provisions, correct?
24 A. Correct. 24 A. Correct.
25 Q. And then Laurynn says, "Thank you." And then on 25 Q. And he says that that language is directly
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1 related to the ability to become a member or hold a 1 Policy?
2 leadership position, correct? 2 A. (Pause.) Having -- again, having a belief is
3 A. Correct. 3 not.
4 Q. And then above that Katrina answers -- and 4 Q. Is religious organizations selecting leaders who
5 explains why she doesn't think it's a conflict. She 5 select -- if a religious organization rejects leaders --
6 says, in the second paragraph, halfway through, "It is 6 let me start over. If a religious organization rejects
7 also important to have Christian leadership in a 7 as leaders students who reject that organization's
8 Christian organization." 8 religious beliefs, that's discrimination on the basis of
9 A. Correct. 9 religion?
10 Q. "We do not in any way discourage those who may 10 A. Correct.
11 not subscribe to the basis of faith in Article II, but 11 Q. And is it your view -- is it the University's
12 we do recognize that having Christian leadership is 12 view that religious student groups cannot do that?
13 important." 13 A. The religious belief part or --
14 A. Correct. 14 Q. Can religious groups exclude individuals because
15 Q. Okay. And then on 7991 Andy responds, and he 15 of their religious beliefs?
16 says, "I recognize the wish to have leadership 16 A. No.
17 requirements based on Christian beliefs. However, 17 Q. So a Muslim group cannot reject a Christian
18 Registered Student Organizations are considered 18 leader?
19 University of Iowa programs and thus must follow the 19 A. If it's a violation of University rights -- Human
20 Human Rights Clause in its entirety." 20 Rights Policy, and, again, in all of the context, yes.
21 A. Um-hum. 21 Q. Yes what?
22 Q. "Having a restriction on leadership related to 22 A. Yes, they can -- no, they cannot violate the
23 religious beliefs is contradictory to that clause." 23 University of Iowa's Human Rights Policy.
24 A. Um-hum. 24 Q. So are there Muslim student groups on campus?
25 Q. Is that a correct statement of the Human Rights 25 A. Yes.
251 252
1 Q. Do you think it's a violation of the Human Rights 1 need to discuss any changes with the rest of the
2 Policy when they require their leaders to be Muslim? 2 leadership team, but I do have a question. Would
3 A. No. 3 changing the language --" do you see where I am?
4 Q. You just said "yes" a minute ago. 4 A. I can --
5 A. I'm getting so tired and confused. 5 Q. I'm on 7991 --
6 Q. Yes. 6 A. Yes.
7 A. I apologize. 7 Q. -- in Document 167. She says, "Would changing
8 Q. Well, I just really want to understand. This is 8 the language of the constitution from 'must subscribe'
9 a very critical question because -- let's finish reading 9 to something like 'are requested to subscribe' or 'are
10 this email. Okay. Right here Andy just told Katrina, 10 strongly encouraged to subscribe' make it so that the
11 right, that having a restriction on leadership related 11 constitution is no longer contradictory? Again, I will
12 to religious beliefs contradicts the Human Rights 12 need to discuss changes, but your input in this matter
13 Clause. 13 is greatly appreciated."
14 A. Correct. 14 And then Andy, at the next page, at 7990, says,
15 Q. Okay. So if the Muslim -- according to Andy, if 15 "I just received word that we would not approve the
16 a Muslim group rejects a Christian leader, that violates 16 change in language you proposed. Student orgs are free
17 the Human Rights Policy. That's what Andy is saying, 17 to express whatever language they desire in their
18 correct? 18 mission purpose, but the University and the Center for
19 A. Yes, yes, yes. 19 Student Involvement and Leadership must enforce our
20 Q. Okay. Is Andy correct, in your view? 20 Human Rights Clause when it comes to leadership and
21 A. Yes. 21 membership."
22 Q. And that's the University's position? 22 A. Yes.
23 A. Yes. 23 Q. Is that the official position of the University?
24 Q. Okay. And then above that, Katrina says to Andy: 24 A. Yes.
25 "Thank you for your clarification. Obviously, I will 25 Q. Okay. So a religious group on campus cannot even
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1 encourage its members to have its same religious 1 says, "Membership in the NLG is open to all students,
2 beliefs? That's a fair characterization of what Andy 2 faculty and staff at the University of Iowa College of
3 said, right? 3 Law who agree with the statement of purpose in Article
4 A. Right. 4 I"?
5 Q. And you just said that that's a correct position 5 A. Yes, I see that.
6 of the University? 6 Q. Do you know if this organization is one of the 24
7 A. Yes, and he said that he received word from the 7 or 25 that are still under review?
8 General Counsel's Office that the language they proposed 8 A. I don't -- I can't recall without looking at the
9 was not acceptable. 9 list.
10 Q. Okay. I'm gonna ask you to look at Document 10 Q. Would you have flagged that language as
11 Number 184. (Marking.) Do you recognize that document? 11 problematic for review by the General Counsel's Office?
12 A. I'm assuming it was part of, again, the 12 A. (Pause.) I'm sorry.
13 production of documents. 13 Q. Take a minute and read the first paragraph that
14 Q. It's titled "Constitution of the Iowa National 14 has the Statement of Purpose in it.
15 Lawyers Guild," correct? 15 A. (Pause.) Okay.
16 A. Correct. 16 Q. And what you just read in Article I, that's the
17 Q. And the number at the bottom is 2409? 17 Statement of Purpose for the Iowa National Lawyers
18 A. Correct. 18 Guild?
19 Q. And it says "BLinC-Def 002409." Do you see that? 19 A. That's correct.
20 A. Correct. 20 Q. And that statement includes political statements
21 (The reporter requested a clarification.) 21 about protecting workers and so forth, correct?
22 MR. BAXTER: Dash Def, D-e-f, for Defendant, 22 A. Correct.
23 002409. 23 Q. And then under Article II, Section 1, the
24 BY MR. BAXTER: 24 constitution says that membership in the -- in this
25 Q. Under Article II Membership, do you see that it 25 organization is only open to students, faculty, and

255 256
1 staff who agree with the Statement of Purpose in Article 1 is the final word from the University, correct?
2 I, correct? 2 A. Correct, because they received word not to
3 A. Correct. 3 approve the language, and that word came from the Office
4 Q. So they can exclude people who don't agree with 4 of General Counsel.
5 Article I? 5 Q. Okay. And they also -- that email -- I'm
6 A. As stated in their constitution. 6 referring to Document 167 -- also states that a
7 Q. And that is discrimination on the basis of creed? 7 religious organization can't even encourage its leaders
8 A. Yes. 8 to be a certain religion, correct?
9 Q. So that should violate the Human Rights Policy 9 A. Correct.
10 under your theory that we just discussed with respect to 10 Q. And that's the official position of the
11 the InterVarsity email, correct? 11 University?
12 A. Correct. 12 A. No.
13 Q. Okay. So is it still your position, after 13 Q. Well, you said that that was the guidance from
14 reading the email from Andy, that the InterVarsity 14 the legal counsel's office, correct?
15 constitution is still under review by the lawyer's 15 A. I'm sorry. I need to -- regroup here. How Andy
16 office? 16 was advised is the position of the University.
17 A. I -- I -- I don't know. I apologize for not 17 Q. Okay. And Andy was advised to tell her that it
18 knowing that. It -- it very well may be there. It 18 was not permissible to have the language that she has on
19 might not be. It could -- it's very dynamic -- it could 19 the top of the second page --
20 have -- I know this is a month or so ago. It appears 20 A. Correct.
21 that the -- the General Counsel's Office has given Andy 21 Q. -- that leaders are requested to subscribe or
22 the direction as it relates in that June 12th -- but if 22 strongly encouraged to subscribe to their beliefs?
23 it's a backup there or something else, I guess, I don't 23 A. Correct.
24 know. 24 Q. Okay. If I go onto OrgSync today and download
25 Q. But it's fair to assume that this email from Andy 25 the constitution of the Iowa National Lawyers Guild,
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 257 258
1 that means that they are currently a Registered Student 1 document marked 192. (Marking.) This is a copy of the
2 Organization, correct? 2 constitution of the House of Lorde that was downloaded
3 A. Correct. 3 from the University's website, from the OrgSync website.
4 Q. And unless their constitution is still in the 4 (The reporter requested a spelling.)
5 Office of General Counsel, they've already been 5 MR. BAXTER: L-o-r-d-e.
6 approved? 6 (Mr. Blomberg left the room.)
7 A. Again, there are 17 with the General Counsel's 7 BY MR. BAXTER:
8 Office that are registered and there are seven that are 8 Q. I'm gonna ask you to flip four pages in.
9 deregistered. 9 A. Okay.
10 Q. But if they're not currently in the lawyer's 10 Q. And do you see it says -- where it says "Article
11 office, that means they've already been approved? 11 2: Mission"?
12 A. I think under review pending -- there were a 12 A. Correct.
13 section of student organizations that de -- selected to 13 Q. And then it says that, "The House of Lorde is an
14 reregister on their own. I don't believe they're part 14 organization founded to advocate for the political
15 of that, so I believe the answer is yes. 15 interests of Black Lesbian et al GBTQPA+ students at the
16 Q. Okay. But today any -- any organization that is 16 University of Iowa and metro Iowa City community." Do
17 currently on OrgSync, their con -- except for the 17 you see that?
18 fraternities and sororities, their constitutions have 18 A. I see that, yes.
19 already been reviewed and approved, except for maybe 17 19 Q. Okay. And then, skipping two more pages over,
20 who are currently -- 20 where it says "General Student Membership --"
21 A. Correct. 21 A. Yes.
22 Q. -- in the University's lawyers' office? 22 Q. And then the second tab -- the second bullet
23 A. Correct. 23 point, says, "Selection of membership may be based off a
24 Q. Okay. If you can bear with me a few moments, 24 general interview by the executive board or open by
25 we're getting very close. I'm going to show you a 25 association. Either option will be discussed on an
259 260
1 individual basis to maintain the purpose of the 1 was reserved for black queer individuals. Are you -- as
2 organization as a space for black queer individuals 2 far as you know, is this constitution one of the ones
3 and/or the support thereof." 3 that is in the legal office at the University?
4 A. Correct. 4 A. I don't know.
5 Q. Do you believe this language is in conflict with 5 Q. Okay. Is there any problem with the statement in
6 the Human Rights Policy. I'm sorry. I'm gonna scratch 6 here that selection and membership may be based off a
7 that question. Is this language in violation of the 7 general interview? Is the interview process alone a
8 Human Rights Policy? 8 problem?
9 A. Yes. 9 A. No.
10 Q. And why? 10 Q. Okay. I'm gonna show you two more constitutions.
11 (Mr. Blomberg entered.) 11 Number -- well, I will just ask you: Do you know if --
12 A. Because of the race piece and -- that space is 12 Multiethnic Undergrad Hawkeye InterVarsity is one of the
13 only open to -- says black. 13 groups under review in the lawyer's office?
14 Q. Black queer individuals, right? 14 A. I -- I believe that they are. I know that they
15 A. Correct. 15 reached out to Andy yesterday.
16 Q. So that would violate both the race and the 16 Q. How do you know that they reached out to Andy
17 gender identity or sexual orientation perhaps -- 17 yesterday?
18 A. Yes. 18 A. Andy told me.
19 Q. -- provision? And is this constitution -- 19 Q. Is -- do you know if International Neighbors is
20 MR. BAXTER: Excuse me -- can we just go off 20 one of the groups whose constitution is before the
21 the record for a minute? 21 lawyers at the University?
22 (Mr. Blomberg left the room.) 22 A. At this point, without the list in front of me, I
23 MR. BAXTER: We'll go back on the record. 23 feel like I'm not giving -- giving accurate information.
24 BY MR. BAXTER: 24 I have that list.
25 Q. So you said it was a problem because the space 25 Q. And as far as you know, is Christian Legal
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 261 262
1 Society still a Registered Student Organization? 1 MR. BAXTER: Would you rather do that right
2 A. They may or may not be with the General Counsel's 2 now or do it tomorrow?
3 Office. 3 MR. CARROLL: What are you gonna do; just go
4 Q. Okay. The University has scheduled a mandatory 4 through his?
5 welcome-back meeting on August 19. Are you aware of 5 MR. BAXTER: Go through his Interrogatory
6 that? 6 Responses and the University's Interrogatory Responses.
7 A. Yes. 7 MR. CARROLL: Can you come back tomorrow
8 Q. And you've asked one representative from 8 morning?
9 every -- you said that one representative from every 9 THE WITNESS: How long would we go?
10 organization will need to be attending -- in attendance; 10 MR. BAXTER: I think it would be less than
11 is that correct? 11 an hour.
12 A. Correct. 12 THE WITNESS: An additional hour?
13 Q. And what's the purpose of that? 13 MR. BAXTER: It probably will be less. It
14 A. We provide this meeting each year. It's to go 14 probably will be a half-hour but --
15 over policies, regulations, what's coming up for the 15 THE WITNESS: It seems like some of what we
16 year. We are changing our student organization database 16 talked about relates to those -- to those.
17 management system, which is significant. They need to 17 MR. CARROLL: Well, why don't we just take a
18 be aware of that. Giving two sessions has been the 18 break? You've been here all day. If you could come
19 customary -- at the beginning of the semester 19 back, we have -- we're starting up at nine. Are you
20 orientation because many of the student leaders are new. 20 staying?
21 MR. BAXTER: Okay. That's all I have except 21 MR. BAXTER: I'm staying.
22 for one topic. We haven't talked about the 22 (The reporter asked if counsel wanted the
23 Interrogatories, which he's also noticed for the 23 record closed.)
24 Interrogatories. 24 Mr. BAXTER: We'll go off the record. I'm
25 MR. CARROLL: Um-hum. 25 sorry.
264
263
1 CERTIFICATE
1 (A discussion was held off the record.)
2 I, Sandra E. Edwards, a Certified Shorthand
2 (Whereupon, the proceedings adjourned at 4:16
Reporter of the State of Iowa, do hereby certify that at
3 p.m., August 8, 2018.) 3 the time and place heretofore indicated, there appeared
before me the following named person, to-wit:
4 (The reporter marked the exhibits listed on 4
5 pages 2 through 7 for identification.) WILLIAM NELSON,
5
6 who was by me first duly sworn to testify to the truth,
6 to the whole truth, and nothing but the truth in the
7
above-entitled cause; that I reported in shorthand the
8 7 testimony of said witness, reduced the same to print by
means of computer-assisted transcription under my
9 8 supervision and direction, and that the foregoing
10 deposition is a true record of the testimony given by
9 said witness and of all proceedings had on the taking of
11 said deposition at the above time and place.
12 10
I further certify that I am not employed by or
13 11 related to any of the parties or counsel in this case,
nor am I financially interested in the outcome of these
14
12 proceedings.
15
13 IN WITNESS WHEREOF, I have set my hand this 20th
16 day of August, 2018.
17 14
18 15 Sandra E. Edwards
19 Certified Shorthand Reporter
16
20 17
18
21 19
22 20
21
23 22
24 23
24
25 25
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 1

222:17, 223:2, 225:2, 20 [5] - 134:14, 140:13, 3981 [1] - 210:3

'
225:13, 225:14, 226:4, 221:22, 240:18, 240:25 3:18 [1] - 231:19
226:15, 226:16, 226:18 200 [1] - 156:1 3:25 [1] - 231:19
'are [2] - 252:9 132 [5] - 220:4, 224:2, 225:8, 2003 [1] - 113:22 3rd [3] - 155:25, 156:2,
'cuz [1] - 102:25 225:9, 226:21 2004 [2] - 113:18, 146:12 221:23
'must [1] - 252:8 133 [1] - 227:16 2008 [4] - 120:25, 121:22,
13th [4] - 77:23, 100:12, 133:16, 133:17 4
0 102:10, 239:10 2009 [2] - 120:25, 125:3
14 [8] - 49:24, 52:6, 52:17, 201 [1] - 156:1
122:4, 125:11, 131:14, 4 [2] - 15:2, 86:4
2012 [1] - 148:13
000273 [1] - 126:24 400 [1] - 242:23
135:3 2014 [3] - 144:3, 147:12,
002409 [2] - 253:19, 253:23 46 [2] - 113:7, 146:13
140 [2] - 231:14, 231:24 148:7
141 [1] - 235:2 47 [1] - 120:20
2017 [10] - 24:13, 44:3, 44:6,
1 143 [1] - 236:5 52:6, 52:17, 59:2, 62:9,
4:16 [1] - 263:2
14th [4] - 44:3, 48:12, 52:16, 69:8, 77:7, 138:21 4th [1] - 239:8
1 [11] - 56:2, 60:18, 87:11, 155:22 2018 [5] - 8:2, 160:16,
87:24, 89:2, 111:21, 15 [5] - 15:6, 15:16, 75:1, 160:18, 162:4, 263:3 5
148:21, 186:19, 209:12, 131:20, 184:5 20th [14] - 113:18, 134:3,
221:23, 254:23 15-minute [1] - 107:9 146:12, 155:25, 156:4, 5 [1] - 15:2
102 [1] - 24:3 150 [2] - 152:11, 237:1 156:24, 157:8, 158:2, 500 [10] - 152:10, 152:11,
104 [3] - 23:22, 27:18, 29:5 154 [1] - 242:1 158:9, 160:16, 162:22, 154:24, 198:10, 207:7,
105 [2] - 28:1, 31:22 157 [6] - 152:12, 154:25, 220:25, 221:19, 221:22 207:10, 208:10, 220:18,
106 [3] - 32:12, 34:8, 38:22 155:6, 155:10, 155:17, 21 [3] - 15:13, 134:14, 135:13 242:20, 242:25
108 [1] - 38:21 161:24 2107 [1] - 245:4 513 [2] - 154:25, 155:13
109 [3] - 38:22, 43:19, 242:22 15th [7] - 8:18, 156:12, 22 [2] - 134:14, 135:4 53 [2] - 121:20, 121:25
10:27 [1] - 77:2 162:14, 209:12, 221:23, 220 [1] - 122:4 54 [1] - 121:24
10:35 [1] - 77:3 236:15, 236:16 24 [9] - 15:13, 239:25, 240:2, 550 [2] - 207:8, 207:11
11 [11] - 12:21, 15:6, 15:14, 16 [1] - 132:23 240:16, 240:18, 240:25, 5th [2] - 221:23, 239:8
116:8, 129:1, 129:5, 130:2, 160 [2] - 152:11, 154:22 241:12, 246:4, 254:6
130:10, 131:7, 131:15, 167 [3] - 247:1, 252:7, 256:6 2409 [1] - 253:17
17 [10] - 27:15, 133:8, 133:9, 24:7 [11] - 16:25, 22:23,
6
131:24
110 [3] - 49:12, 50:5 240:25, 241:1, 246:5, 24:15, 36:9, 54:16, 54:20,
111 [1] - 52:2 246:9, 257:7, 257:19 75:22, 107:25, 108:16, 6 [1] - 224:8
112 [1] - 54:22 173 [3] - 160:18, 161:19, 110:23, 111:6 6/22/18 [1] - 129:13
113 [3] - 56:20, 56:21, 56:23 163:10 25 [5] - 240:2, 240:16, 241:1, 6/22/2018 [2] - 129:12,
114 [1] - 81:21 174 [2] - 162:3, 164:1 241:12, 254:7 130:10
115 [1] - 85:2 175 [1] - 160:17 26 [3] - 24:13, 24:14, 31:16 6:12-20 [1] - 111:21
116 [2] - 85:6, 101:8 17th [1] - 27:14 26th [2] - 30:25, 108:13
118 [1] - 99:22 18 [1] - 134:14 27 [1] - 19:15 7
119 [1] - 104:9 1828 [1] - 243:9 28 [2] - 19:15, 243:12
11:08 [1] - 104:4 184 [1] - 253:11 2:03 [1] - 180:22
7 [1] - 263:5
11:16 [1] - 104:5 19 [2] - 134:14, 261:5 2:11 [1] - 180:22
7/19 [1] - 54:24
12 [8] - 129:21, 129:22, 192 [1] - 258:1 2nd [1] - 248:8
75 [1] - 157:2
131:8, 132:1, 133:1, 1:03 [1] - 136:8
7990 [1] - 252:14
133:12, 143:20 1st [26] - 40:13, 40:15, 44:6, 3 7991 [2] - 249:15, 252:5
120 [2] - 107:3, 107:4 48:5, 48:9, 59:2, 59:10,
7992 [1] - 248:16
121 [9] - 122:2, 181:1, 181:6, 59:19, 62:3, 62:8, 69:8,
3 [1] - 14:3 7993 [1] - 248:1
181:8, 181:10, 181:13, 77:7, 81:25, 156:8, 158:6,
158:9, 160:18, 160:21, 30 [1] - 237:24 7994 [1] - 247:8
181:21, 181:22
161:25, 162:20, 162:24, 30(B)(6 [1] - 115:18
122 [2] - 183:8, 183:9
125 [2] - 184:9, 184:11 163:5, 163:10, 236:9, 300 [2] - 155:2, 155:23 8
248:7 31 [1] - 228:3
126 [1] - 185:5
32 [1] - 228:3
127 [1] - 186:2 8 [3] - 8:2, 162:4, 263:3
33 [2] - 147:13, 147:14
128 [1] - 199:20 2 81 [1] - 107:19
34 [2] - 147:13, 147:16
12:04 [1] - 136:8 85 [1] - 35:18
37 [1] - 170:13
12th [1] - 255:22 2 [9] - 12:15, 16:18, 112:11, 88 [1] - 35:17
3713 [1] - 235:20
13 [1] - 56:2 115:16, 149:7, 189:7, 8:52 [1] - 8:2
3888 [1] - 184:2
130 [1] - 225:11 258:11, 263:5 8th [4] - 162:20, 162:24,
39 [4] - 237:19, 237:23,
131 [11] - 205:16, 222:9, 2-7-0 [1] - 131:12 163:5, 164:19
238:16, 246:2

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27:21, 27:24, 29:1, 37:21, adverse [1] - 72:23 amount [2] - 123:1, 147:24
9
37:25, 68:12, 68:13, 113:2, advice [2] - 151:7, 167:10 analogy [2] - 64:14, 174:22
204:16, 230:5 advised [4] - 110:20, 236:23, Andy [54] - 13:10, 14:17,
9-12 [1] - 224:8 Action [1] - 223:15 256:16, 256:17 138:6, 138:7, 138:9,
90 [1] - 12:12 actions [6] - 40:6, 40:18, advisor [5] - 23:14, 33:22, 138:16, 139:3, 139:7,
91 [3] - 16:5, 19:5, 35:18 61:11, 201:22, 202:3, 79:8, 236:19, 236:24 140:10, 142:4, 143:1,
92 [3] - 18:9, 18:10, 19:14 202:8 advocate [1] - 258:14 156:19, 157:5, 165:21,
935 [1] - 171:13 activities [4] - 9:12, 190:7, affair [1] - 202:11 167:7, 185:23, 186:16,
94 [1] - 23:20 200:23, 201:13 Affecting [1] - 129:20 187:5, 187:12, 187:16,
activity [4] - 63:25, 67:2, affecting [3] - 130:2, 130:5, 187:25, 188:4, 188:24,
A 70:24, 202:13 130:7 191:8, 195:17, 195:22,
actual [6] - 18:7, 42:11, affiliated [2] - 123:10, 123:12 198:23, 227:3, 227:9,
42:23, 43:8, 86:24, 243:4 affiliation [3] - 146:18, 179:9, 235:10, 235:16, 236:14,
a.m [5] - 8:2, 77:2, 77:3,
actually [7] - 26:9, 112:3, 229:2 237:5, 241:23, 243:21,
104:4, 104:5
146:14, 176:9, 222:15, affiliations [2] - 178:18, 248:10, 248:17, 249:15,
ABC [1] - 153:8
246:3 179:22 251:10, 251:15, 251:17,
abide [2] - 47:18, 70:24 251:20, 251:24, 252:14,
adapted [1] - 126:10 affirm [2] - 88:25, 106:10
ability [2] - 162:25, 249:1 253:2, 255:14, 255:21,
add [5] - 71:20, 72:8, 72:15, affirming [2] - 65:3, 136:20
able [3] - 23:7, 52:25, 95:7 255:25, 256:15, 256:17,
147:9, 183:9 afforded [1] - 182:13
absence [1] - 237:5 260:15, 260:16, 260:18
Added [1] - 149:7 afterwards [1] - 79:24
absent [1] - 29:23 Andy's [1] - 142:24
added [5] - 48:11, 88:6, ago [6] - 101:13, 125:24,
absolutely [4] - 109:7, 155:8, Angie [1] - 11:7
127:1, 149:19, 164:2 231:1, 237:18, 251:4,
212:5, 238:22 Anita [20] - 22:6, 22:16, 23:1,
adding [1] - 10:3 255:20
abstain [7] - 63:15, 63:19, 27:19, 141:17, 141:23,
addition [1] - 8:24 agree [8] - 48:16, 76:4,
63:20, 63:25, 64:4, 78:6, 142:4, 142:5, 143:1, 143:3,
additional [18] - 9:18, 9:20, 76:19, 196:12, 197:16,
78:7 143:4, 143:9, 143:11,
34:18, 40:25, 41:1, 42:17, 254:3, 255:1, 255:4
abstinent [1] - 62:24 151:8, 165:21, 167:7,
59:16, 72:9, 100:11, 102:6, agreed [9] - 63:14, 67:5,
accept [1] - 88:25 227:4, 227:7, 227:9
112:20, 126:25, 135:22, 71:4, 72:8, 72:20, 77:21,
acceptable [13] - 64:5, 78:9, Anita's [1] - 195:22
162:8, 164:2, 164:5, 187:6, 81:7, 83:20, 167:23
84:17, 100:25, 102:11, 262:12 annual [1] - 9:13
agreed -upon [1] - 167:23
110:23, 215:18, 234:19, answer [11] - 22:4, 52:8,
Additionally [4] - 161:6, agreement [5] - 190:15,
234:20, 240:12, 240:13, 95:14, 95:20, 103:6, 112:1,
161:11, 161:12, 163:22 191:11, 194:23, 197:6
241:8, 253:9 133:20, 137:18, 139:20,
additions [1] - 77:20 ahead [5] - 56:12, 105:3,
accepted [6] - 37:8, 61:9, 226:8, 257:15
address [2] - 229:4, 229:18 107:2, 208:4, 243:3
65:23, 74:7, 103:8, 103:23 answered [1] - 117:24
addressed [4] - 158:19, ahold [1] - 137:7
access [7] - 35:2, 35:3, 74:1, answers [1] - 249:4
160:12, 165:21, 188:15 al [1] - 258:15
147:22, 206:17, 216:12, anti [1] - 20:3
addressing [1] - 181:15 align [1] - 61:16
233:22 anti-retaliation [1] - 20:3
adhere [1] - 210:10 alignment [1] - 242:6
accidently [1] - 67:19 anxiety [2] - 103:12, 107:16
adjourned [1] - 263:2 allegations [2] - 73:15,
accommodate [1] - 12:13 apologies [1] - 168:20
adjudicated [1] - 22:14 110:15
according [2] - 197:11, apologize [28] - 15:12,
adjudicator [3] - 22:20, 23:2, allied [1] - 123:11
251:15 19:23, 22:21, 32:2, 38:24,
23:9 Allocation [1] - 124:6
account [1] - 31:16 46:1, 49:9, 52:9, 53:1,
adjust [1] - 209:13 allow [23] - 27:4, 27:6, 59:15,
accuracy [2] - 34:6, 105:23 54:21, 55:11, 86:11, 87:22,
adjustments [1] - 132:10 64:9, 78:17, 90:13, 121:5,
accurate [14] - 13:7, 49:23, 123:5, 147:7, 161:10,
administer [1] - 117:14 127:16, 167:22, 169:25,
141:11, 144:4, 155:1, 166:25, 209:13, 224:15,
administered [1] - 219:20 173:2, 173:7, 173:22,
171:21, 195:5, 196:2, 225:21, 226:10, 228:13,
administration [4] - 126:6, 173:23, 176:10, 176:23,
212:9, 217:16, 217:19, 229:14, 246:8, 251:7,
126:7, 175:5, 201:2 176:25, 177:16, 192:11,
237:11, 237:14, 260:23 255:17
Administrative [3] - 182:5, 197:23, 218:6, 234:24
accurately [2] - 37:7, 223:18 apostrophe [1] - 223:9
182:7, 247:14 allowed [11] - 26:4, 62:18,
accused [1] - 22:12 appeal [16] - 50:19, 50:23,
administrative [6] - 9:11, 65:22, 137:7, 177:19,
acknowledge [1] - 58:13 51:6, 52:1, 55:4, 55:7,
9:22, 10:5, 138:12, 142:2, 177:21, 198:1, 213:4,
acknowledged [1] - 174:1 73:3, 73:4, 73:10, 73:25,
206:4 214:8, 218:14, 219:23
acknowledging [1] - 58:18 74:8, 74:22, 76:9, 76:12,
admission [2] - 38:15, 49:3 allowing [4] - 33:21, 192:9,
acronym [1] - 124:3 104:14, 137:4
admit [5] - 214:5, 214:18, 205:9, 234:22
act [3] - 165:11, 165:16, appealing [1] - 82:12
217:1, 217:4, 217:6 allows [6] - 91:4, 127:8,
200:18 appeals [2] - 51:23, 54:14
admitted [5] - 38:13, 46:13, 127:18, 211:12, 213:11
acted [1] - 173:12 appear [1] - 160:19
49:1, 65:15, 218:8 alone [3] - 47:19, 95:1, 260:7
acting [2] - 99:16, 212:1 appearance [1] - 212:9
advance [2] - 26:3, 185:13 amendment [1] - 126:14
action [13] - 20:19, 21:8, appeared [1] - 36:16
advanced [1] - 39:25 Amendment [1] - 95:21

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Applicable [1] - 223:5 182:6, 182:8, 209:10, 134:1, 134:7, 134:10,

B
applicable [1] - 64:6 247:14 134:18, 134:23, 135:3,
applicant [4] - 41:25, 42:10, assisted [1] - 14:17 135:7, 135:12, 136:4,
42:21, 223:22 Associate [12] - 8:24, 9:2, backup [1] - 255:23 136:11, 136:14, 137:21,
applicants [1] - 223:17 9:18, 10:12, 11:2, 11:7, Baker [20] - 14:18, 27:19, 139:21, 140:5, 148:1,
Applicants [1] - 223:21 13:12, 22:7, 39:14, 141:25, 28:5, 39:9, 39:18, 42:25, 163:2, 163:8, 163:20,
application [5] - 111:9, 143:8, 199:22 59:14, 59:20, 62:10, 74:11, 167:1, 168:9, 178:24,
111:13, 112:6, 112:9, association [1] - 258:25 85:16, 108:19, 113:12, 180:19, 180:24, 180:25,
112:14 assume [9] - 34:2, 54:18, 117:24, 119:17, 146:12, 181:4, 181:9, 181:13,
applied [5] - 63:17, 64:2, 85:14, 108:4, 137:9, 149:25, 201:21, 201:22, 181:16, 181:19, 189:17,
78:11, 127:10, 166:17 174:11, 183:13, 196:9, 201:23 189:20, 190:4, 190:5,
applies [1] - 136:1 255:25 Baker 's [3] - 39:5, 39:8 194:15, 209:3, 209:5,
apply [1] - 209:21 assumed [1] - 9:19 ballpark [1] - 156:4 210:6, 210:7, 213:21,
appreciate [1] - 32:11 assuming [4] - 26:16, 50:14, barring [1] - 79:16 213:22, 219:2, 219:5,
appreciated [1] - 252:13 156:16, 253:12 base [1] - 244:15 219:8, 219:11, 222:21,
approach [1] - 204:18 assumption [4] - 41:8, based [53] - 26:16, 29:15, 222:25, 223:8, 223:10,
53:22, 76:8, 196:3 30:12, 31:17, 41:12, 42:16, 225:18, 225:22, 226:13,
appropriate [11] - 39:25,
Athletes [1] - 223:15 45:15, 47:12, 61:17, 77:16, 228:18, 228:20, 228:21,
41:14, 51:11, 60:20, 77:13,
attached [1] - 28:12 79:3, 83:24, 84:20, 106:3, 229:21, 229:24, 231:17,
77:18, 79:3, 79:6, 123:18,
Attached [1] - 31:22 109:21, 125:4, 150:11, 231:21, 231:22, 232:8,
234:16, 234:17
attaching [1] - 85:3 150:15, 151:7, 164:8, 238:14, 238:23, 239:1,
approve [6] - 186:9, 186:13,
attachment [2] - 223:2 164:15, 165:4, 166:6, 239:3, 253:22, 253:24,
195:11, 234:8, 252:15,
172:12, 172:16, 184:19, 258:5, 258:7, 259:20,
256:3 attaining [1] - 190:13
190:21, 192:17, 192:21, 259:23, 259:24, 261:21,
approved [9] - 79:7, 103:5, attainment [1] - 190:14
193:6, 193:10, 193:22, 262:1, 262:5, 262:10,
161:20, 189:7, 239:14, attempted [2] - 59:7, 119:15
194:8, 196:22, 198:11, 262:13, 262:21, 262:24
241:17, 257:6, 257:11, attendance [1] - 261:10
199:3, 199:8, 199:11, bear [1] - 257:24
257:19 attending [2] - 174:13,
203:1, 207:17, 215:5, became [10] - 8:22, 8:23,
April [17] - 154:10, 154:17, 261:10
216:4, 218:20, 219:17, 8:24, 8:25, 9:1, 9:25, 45:5,
155:22, 155:25, 156:4, attention [8] - 15:5, 17:16,
239:5, 240:10, 241:8, 206:14, 237:7, 241:6
156:23, 157:8, 158:2, 82:1, 85:1, 88:20, 153:15,
243:25, 245:22, 249:17, become [3] - 139:7, 174:16,
158:8, 160:16, 161:24, 154:1, 226:7
258:23, 260:6 249:1
161:25, 162:22, 220:25, attest [1] - 194:4
bases [1] - 72:3 becoming [1] - 112:14
221:19, 221:22 attorney [3] - 13:2, 95:14,
basic [2] - 177:4, 184:22 began [3] - 152:1, 185:9,
area [5] - 9:12, 9:13, 9:20, 141:5
basing [2] - 70:4, 246:15 185:18
137:14, 142:13 audible [1] - 137:18
Basis [1] - 245:8 begin [2] - 50:17, 51:24
areas [2] - 111:23, 236:3 audit [1] - 148:13
basis [14] - 71:14, 127:19, beginning [3] - 140:25,
argued [1] - 65:18 August [7] - 8:2, 59:8, 59:13,
146:20, 171:25, 172:21, 155:7, 261:19
arise [2] - 30:6, 30:7 59:17, 239:10, 261:5,
175:15, 177:10, 192:3, behalf [8] - 12:1, 45:10,
arisen [1] - 25:21 263:3
212:21, 213:12, 249:11, 59:21, 116:6, 119:17,
arose [4] - 120:10, 134:2, author [1] - 185:22
250:8, 255:7, 259:1 175:7, 188:1
152:5, 205:11 authored [2] - 140:11,
bass [1] - 216:14 behavior [1] - 223:20
arrived [1] - 113:22 170:15
batch [2] - 157:10, 162:3 behaviors [1] - 223:24
arriving [2] - 35:15, 147:4 authority [6] - 33:9, 45:9,
batches [1] - 157:12 behind [11] - 12:15, 14:3,
Article [14] - 87:11, 87:24, 66:7, 118:2, 165:17, 236:1
Bates [1] - 19:10 16:11, 18:9, 34:8, 43:19,
88:15, 88:21, 89:2, 249:11, authorized [4] - 116:5,
Baxter [4] - 8:3, 62:13, 56:23, 181:10, 181:13,
253:25, 254:3, 254:16, 118:5, 150:5, 175:2
122:7, 125:13 183:14
254:23, 255:1, 255:5, automatically [2] - 22:14,
BAXTER [122] - 8:10, 11:1, belief [24] - 48:22, 91:6, 92:1,
258:10 241:9
16:9, 16:15, 16:17, 16:19, 92:5, 92:8, 92:13, 92:20,
article [1] - 237:17 available [2] - 35:4, 143:19
16:21, 16:25, 17:2, 17:4, 97:6, 99:14, 99:17, 121:16,
aside [2] - 198:14, 208:19 avenue [1] - 76:12
17:6, 19:13, 36:4, 58:9, 171:16, 176:13, 192:17,
assault [2] - 168:2, 168:14 avoid [3] - 78:17, 78:22,
62:3, 62:7, 77:1, 77:4, 192:19, 193:6, 194:8,
assemble [1] - 167:22 79:10
77:5, 91:14, 95:23, 96:24, 195:1, 195:3, 197:6,
assembled [3] - 141:19, aware [21] - 16:1, 16:3, 32:1,
100:4, 100:7, 100:8, 104:6, 199:11, 202:3, 250:2,
141:20, 188:11 45:5, 70:7, 71:12, 119:18,
104:7, 113:16, 114:2, 250:13
assembling [1] - 166:7 120:21, 123:8, 124:11,
116:18, 116:20, 116:22, Belief [1] - 191:19
assessments [1] - 9:20 139:7, 177:1, 202:16,
116:24, 122:8, 125:14, belief -based [4] - 192:17,
assist [1] - 14:11 202:24, 219:19, 228:5,
128:12, 128:16, 128:21, 193:6, 194:8, 199:11
Assistance [1] - 11:8 230:12, 245:11, 246:18,
128:24, 128:25, 131:11, Beliefs [1] - 173:8
assistance [1] - 185:24 261:5, 261:18
131:13, 132:21, 133:24, beliefs [61] - 66:2, 66:16,
Assistant [6] - 25:7, 50:8,

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66:23, 67:2, 67:7, 67:10, Black [2] - 258:15, 259:14 236:8, 243:9, 245:4, 247:6, 230:10
69:9, 69:20, 70:11, 70:24, black [4] - 26:22, 259:2, 247:8, 247:10, 248:1, cappella [1] - 216:13
71:4, 71:17, 71:21, 72:4, 259:13, 260:1 253:17 capturing [1] - 242:5
78:3, 84:7, 89:1, 91:12, BLinC [88] - 22:23, 23:14, brand [1] - 87:2 Care [1] - 11:8
91:14, 93:3, 93:12, 93:14, 24:11, 24:15, 27:12, 28:8, brand -new [1] - 87:2 career [1] - 36:7
93:24, 95:3, 97:1, 97:4, 28:12, 28:13, 29:3, 30:13, Braun [5] - 228:16, 228:25, carefully [1] - 115:9
97:5, 99:21, 124:14, 30:23, 31:6, 32:17, 36:9, 229:2, 229:12, 229:16 Carroll [1] - 8:4
124:16, 125:4, 171:17, 42:1, 42:6, 43:5, 44:5, BRAUN [1] - 228:16 CARROLL [68] - 10:16,
171:18, 173:3, 174:16, 44:24, 45:10, 45:19, 46:3, break [21] - 12:11, 12:12, 10:20, 15:11, 16:7, 16:14,
175:23, 191:4, 191:12, 47:19, 50:23, 53:16, 54:19, 58:23, 76:25, 90:15, 90:19, 16:16, 16:18, 16:20, 18:14,
191:14, 191:25, 192:4, 55:4, 55:7, 56:1, 60:18, 90:20, 102:23, 103:2, 19:9, 36:2, 55:10, 62:1,
197:20, 197:24, 198:1, 61:12, 63:8, 63:9, 65:18, 103:7, 103:11, 104:1, 62:4, 69:14, 76:25, 86:9,
198:16, 200:23, 201:14, 66:9, 67:5, 67:13, 68:13, 104:3, 107:9, 135:5, 95:13, 95:17, 95:20, 100:5,
203:2, 203:14, 203:16, 68:23, 69:9, 69:20, 70:14, 135:10, 135:11, 136:5, 104:1, 104:3, 113:25,
203:21, 204:3, 204:20, 70:18, 71:6, 72:1, 72:8, 136:16, 231:15, 262:18 116:13, 116:19, 116:21,
249:17, 249:23, 250:8, 72:15, 72:20, 72:22, 73:4, breakdown [1] - 129:23 128:14, 128:19, 128:23,
250:15, 251:12, 253:2, 73:10, 75:22, 77:21, 78:2, breaks [1] - 12:11 132:19, 133:20, 133:23,
256:22 78:13, 78:17, 82:23, 83:20, Brett [2] - 62:12, 65:5 133:25, 134:6, 134:16,
beliefs /purposes [2] - 84:7, 85:9, 89:7, 94:8, brief [3] - 55:12, 183:4, 206:3 134:19, 134:25, 135:5,
190:16, 194:25 104:22, 114:10, 125:25, briefly [1] - 9:5 136:6, 139:19, 145:14,
believers [1] - 202:4 134:2, 136:21, 138:4, bring [1] - 33:22 145:21, 161:9, 166:24,
below [5] - 27:21, 27:24, 139:8, 140:8, 140:14, broader [3] - 211:7, 229:3, 178:21, 181:7, 181:12,
29:1, 29:10, 54:15 193:16, 193:24, 196:16, 234:18 181:14, 181:17, 218:24,
benefits [3] - 120:15, 183:6, 200:13, 201:12, 202:23, brought [3] - 53:12, 130:10, 219:4, 219:6, 219:10,
184:21 203:7, 203:13, 203:15, 234:14 219:13, 226:5, 226:11,
Bernie [4] - 169:1, 169:5, 204:1, 204:2, 205:1, Brown [2] - 199:21, 199:22 228:17, 228:19, 229:15,
174:12, 175:14 205:12, 228:4, 230:2, Bruce [1] - 228:6 229:22, 231:15, 238:11,
best [3] - 148:2, 162:25, 253:19 238:25, 261:25, 262:3,
Budgeting [1] - 124:6
246:9 BLinC 's [19] - 28:18, 40:6, 262:7, 262:17
build [1] - 167:16
better [2] - 41:12, 159:10 46:4, 46:14, 47:3, 47:8, carrying [1] - 150:25
build -a-wall [1] - 167:16
between [36] - 24:1, 41:24, 48:16, 49:5, 67:6, 89:1, case [23] - 17:17, 21:5, 26:3,
bullet [1] - 258:22
42:10, 42:17, 42:21, 42:25, 89:3, 99:12, 101:25, 28:9, 33:23, 33:25, 40:4,
Business [7] - 17:13, 19:3,
43:16, 44:18, 44:20, 44:23, 200:22, 201:13, 201:22, 42:1, 42:7, 58:1, 58:18,
34:17, 45:2, 47:25, 199:23,
48:3, 63:21, 66:3, 67:3, 202:3, 202:8 58:19, 59:14, 118:14,
200:10
78:8, 79:18, 90:5, 91:8, BLinC -Def [1] - 253:19 136:16, 183:24, 192:22,
bylaws [4] - 156:13, 207:18,
91:19, 92:15, 92:20, 93:13, blind [2] - 218:15, 219:15 193:5, 201:20, 205:5,
207:20, 210:21
98:15, 122:6, 125:12, Blomberg [14] - 8:4, 62:13, 207:1, 214:24, 218:10
135:16, 143:1, 159:8, 62:14, 62:15, 122:7, cases [6] - 20:4, 21:5,
161:25, 169:14, 176:15, 125:13, 136:10, 167:24,
C 108:14, 108:21, 180:15,
187:9, 188:8, 206:13, 168:8, 170:24, 181:2, 182:15
238:3, 238:6 258:6, 259:11, 259:22 campus [32] - 9:12, 25:14, categorically [7] - 46:12,
beyond [8] - 31:18, 34:6, BLOMBERG [6] - 17:1, 17:3, 71:10, 72:11, 92:2, 92:8, 71:2, 78:12, 84:1, 84:8,
51:16, 96:7, 97:6, 98:20, 38:23, 135:1, 222:23, 93:4, 93:11, 93:14, 93:24, 169:20, 193:1
152:23, 242:10 246:6 94:20, 95:1, 99:2, 123:9, categories [8] - 83:24,
bias [1] - 224:10 Board [9] - 229:17, 229:20, 124:12, 138:15, 154:20, 146:16, 149:8, 149:18,
Bible [3] - 112:3, 224:11 230:1, 230:7, 230:8, 173:14, 174:12, 177:6, 150:7, 150:8, 167:25,
Bible 's [1] - 111:15 230:11, 230:13, 230:14, 178:18, 179:7, 208:6, 191:2
bigoted [2] - 202:4, 202:8 230:17 218:12, 233:8, 234:19, category [4] - 170:3, 210:9,
Bill [9] - 24:22, 52:11, 52:12, board [3] - 245:8, 245:22, 242:13, 245:13, 250:24, 220:10, 221:10
53:3, 53:12, 53:21, 54:5, 258:24 252:25 caused [2] - 139:11, 240:11
55:18, 142:5 Boddicker [1] - 230:23 candidates [2] - 84:20, cc'd [5] - 18:23, 21:17, 32:19,
binder [10] - 12:14, 16:10, bold [1] - 164:4 102:14 44:1, 108:1
16:11, 16:12, 35:14, 35:17, book [2] - 10:6, 232:24 cannot [16] - 20:9, 93:25, censored [1] - 234:8
122:4, 129:5, 131:14, booklet [1] - 232:24 171:25, 172:8, 190:14, center [2] - 10:10, 137:10
238:18 boss [1] - 73:20 191:11, 191:21, 194:22, Center [19] - 9:9, 9:24, 10:9,
bisexual [1] - 123:11 bottom [22] - 27:18, 29:10, 197:5, 215:9, 217:2, 13:13, 14:25, 22:8, 117:6,
bit [12] - 10:17, 10:18, 10:23, 34:9, 38:23, 126:24, 248:21, 250:12, 250:17, 117:7, 118:1, 118:2,
44:17, 53:11, 58:25, 86:9, 181:22, 184:1, 184:11, 250:22, 252:25 137:13, 141:19, 141:21,
126:9, 162:16, 174:22, 186:18, 210:4, 224:21, capability [1] - 33:16 142:1, 207:6, 235:20,
217:21, 234:7 224:22, 233:3, 235:19, capacity [3] - 10:5, 32:24, 235:24, 247:15, 252:18

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centered [1] - 214:1 chose [2] - 111:6, 124:25 59:16, 62:1, 67:5, 67:17, 36:23, 38:12, 42:17, 43:24,
centers [1] - 9:15 chosen [1] - 156:2 67:18, 84:12, 98:12, 44:18, 44:22, 45:16, 50:1,
central [1] - 144:10 Christ [6] - 17:13, 19:3, 113:25, 130:16, 165:2, 50:7, 57:2, 57:6, 59:17,
certain [28] - 20:21, 24:8, 34:18, 45:3, 89:18, 89:23 181:7, 240:11 60:4, 60:5, 60:10, 60:14,
30:8, 31:16, 31:25, 46:10, Christ 's [1] - 48:1 clerical [1] - 138:24 60:16, 65:16, 77:24, 80:1,
54:2, 68:20, 70:11, 75:5, Christian [25] - 46:4, 47:3, clicked [1] - 130:9 81:24, 85:15, 100:10,
91:12, 97:1, 97:3, 99:6, 47:8, 47:16, 47:19, 48:17, climate [2] - 64:9, 64:12 100:12, 102:10, 104:13,
108:17, 115:13, 130:16, 49:5, 62:18, 110:21, close [2] - 243:15, 257:25 108:19, 113:12, 122:12,
147:3, 150:3, 151:3, 113:13, 113:15, 118:23, closed [1] - 262:23 128:6, 128:8, 136:23,
176:20, 182:18, 206:17, 118:24, 123:14, 146:11, CLS [9] - 62:18, 63:8, 137:1, 137:4, 137:5, 140:7,
211:25, 227:2, 237:22, 245:12, 246:1, 248:6, 114:10, 119:19, 120:1, 145:10, 154:11, 154:23,
237:25, 256:8 249:7, 249:8, 249:12, 121:11, 124:8, 124:12, 155:24, 156:10, 156:22,
certainly [8] - 10:19, 20:11, 249:17, 250:17, 251:16, 124:20 156:23, 157:5, 157:21,
24:16, 116:14, 145:18, 260:25 Club [3] - 10:7, 243:11, 244:9 157:24, 157:25, 158:4,
176:22, 228:13 Christians [3] - 89:17, 89:23, club [11] - 26:22, 27:3, 158:7, 159:10, 160:12,
Cervantes [9] - 18:22, 20:25, 146:21 167:16, 168:11, 169:7, 161:16, 162:8, 162:13,
24:11, 25:17, 34:12, 35:2, Christiansen [1] - 237:5 169:17, 169:22, 214:14, 188:10, 188:11, 198:24,
38:2, 39:13, 73:17 chronology [1] - 36:22 214:20, 218:12 201:7, 209:2, 209:6, 209:8,
Cervantes ' [1] - 107:24 circulating [1] - 206:22 clubs [16] - 26:21, 26:22, 227:18, 228:10, 234:18,
cetera [7] - 83:9, 111:21, circumstances [2] - 57:17, 53:11, 53:14, 214:6, 214:8, 235:5, 236:13, 236:15
160:11, 190:16, 194:24, 76:22 218:5, 218:6, 218:7, 219:4, Communication [1] - 238:7
216:12, 227:2 cites [1] - 248:22 219:5, 219:6, 219:17, communications [10] - 37:1,
chain [3] - 206:8, 236:8, City [2] - 93:20, 258:16 219:20, 219:23 57:10, 60:7, 139:25,
247:7 Civil [1] - 219:9 Code [1] - 125:18 156:21, 159:12, 183:23,
challenge [1] - 51:13 claim [1] - 65:13 collect [1] - 188:20 188:8, 188:16, 230:19
challenges [2] - 122:15, clar [1] - 167:9 collecting [3] - 158:17, Communications [1] - 238:3
153:3 clarification [20] - 91:13, 187:25, 198:21 community [2] - 99:4, 258:16
challenging [1] - 133:17 96:21, 113:14, 119:21, collective [1] - 152:8 compared [1] - 196:12
chance [3] - 115:4, 232:14, 126:2, 131:10, 132:9, College [5] - 123:11, 123:12, compilation [2] - 220:8,
247:4 137:17, 140:4, 147:23, 199:23, 200:10, 254:2 227:13
change [6] - 126:1, 126:17, 163:19, 170:17, 190:3, column [4] - 129:11, 223:5, compiled [1] - 13:4
149:13, 153:8, 220:1, 194:12, 210:5, 223:7, 223:11, 224:1 Complainant [22] - 17:12,
252:16 232:5, 238:5, 251:25, com [1] - 77:16 34:16, 34:17, 38:5, 38:14,
changed [6] - 9:10, 88:9, 253:21 Combine [1] - 148:22 38:15, 38:19, 42:18, 43:1,
154:6, 204:23, 205:2, clarifications [1] - 164:6 coming [2] - 12:25, 261:15 43:16, 44:19, 44:25, 45:15,
237:23 clarify [3] - 77:25, 98:18, commence [1] - 33:16 46:11, 46:22, 110:16,
changes [21] - 27:15, 68:23, 136:24 commencement [1] - 133:19 110:19, 110:22, 111:5,
85:20, 85:23, 85:24, 85:25, clarifying [1] - 228:3 111:9, 112:22
commencing [1] - 18:5
86:12, 86:13, 86:15, 87:6, clarity [1] - 160:14 Complainant 's [1] - 112:1
comments [4] - 31:23, 32:1,
132:13, 133:6, 133:13, class [4] - 91:9, 92:22, 32:5, 59:16 complained [2] - 177:17,
133:16, 134:22, 148:9, 173:13, 174:3 Commit [1] - 83:16 177:18
193:19, 252:1, 252:12 classes [8] - 26:25, 145:1, complaining [2] - 233:17,
committed [1] - 67:14
changing [4] - 180:4, 252:3, 166:12, 166:13, 173:11, 234:23
committee [2] - 183:6, 204:7
252:7, 261:16 190:12, 194:21, 216:9 complaint [34] - 16:24,
Committee [1] - 124:6
Chapter [1] - 224:8 classifications [2] - 164:8, 17:23, 19:2, 19:5, 20:8,
common [1] - 175:23
chapter [3] - 207:22, 208:6, 165:5 20:9, 20:20, 22:13, 29:24,
commun [1] - 50:16
223:19 Clause [26] - 144:2, 144:3, 30:17, 32:17, 68:2, 68:5,
communicate [8] - 50:13,
chapter 's [3] - 223:18, 144:11, 152:13, 157:7, 68:8, 68:10, 68:13, 68:19,
56:15, 56:16, 80:1, 223:18,
223:20, 223:23 161:14, 162:9, 163:24, 68:25, 69:13, 69:16, 108:8,
230:6, 230:8, 230:10
chapters [1] - 239:8 164:9, 164:16, 190:1, 108:12, 134:3, 148:23,
communicated [15] - 29:8,
characteristics [2] - 190:13, 190:4, 190:6, 190:13, 174:1, 174:7, 177:20,
33:3, 56:1, 59:11, 60:1,
194:21 190:17, 191:4, 191:5, 177:24, 180:6, 180:9,
109:5, 140:19, 163:1,
characterization [1] - 253:2 191:12, 191:22, 191:24, 216:20, 218:19
209:12, 221:25, 223:24,
charged [1] - 37:11 194:21, 248:21, 249:20, Complaint [1] - 17:10
224:6, 230:13, 230:14,
check [7] - 58:6, 135:8, 251:13, 252:20 complaint -driven [2] - 180:6,
241:24
145:12, 227:1, 241:22, clause [6] - 95:22, 144:7, 180:9
communicates [1] - 230:7
243:5, 243:6 144:8, 194:25, 248:22, complaints [3] - 29:23,
communicating [2] - 29:9,
checked [1] - 105:22 249:23 173:20, 218:20
109:2
checking [1] - 144:17 clean [1] - 135:11 complete [14] - 35:14, 69:25,
communication [74] - 18:20,
chief [1] - 21:20 clear [14] - 19:10, 36:2, 141:11, 144:4, 144:18,
24:1, 28:4, 28:7, 31:8,

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148:18, 152:12, 154:15, confirm [2] - 34:6, 37:6 103:5, 103:9, 103:22, contribute [1] - 217:25
154:23, 155:1, 155:4, confirmed [2] - 39:6, 208:20 103:23, 105:5, 105:7, controversial [1] - 204:3
155:6, 156:16, 245:17 confirms [2] - 56:13, 106:6 114:12, 119:1, 131:5, conversation [13] - 22:22,
completed [3] - 8:18, 111:9, conflict [11] - 79:11, 91:21, 144:19, 154:14, 156:13, 25:25, 26:12, 26:23, 31:15,
243:4 96:18, 144:25, 167:5, 157:17, 165:11, 167:2, 31:17, 41:13, 69:3, 105:12,
complexities [3] - 207:17, 176:1, 180:15, 180:16, 168:16, 207:20, 223:6, 105:18, 159:14, 182:22,
217:9, 217:18 220:16, 249:5, 259:5 223:9, 239:13, 241:20, 205:14
compliance [17] - 70:16, conflicting [10] - 144:21, 245:9, 248:7, 252:8, conversations [7] - 43:16,
71:8, 71:18, 71:22, 72:5, 155:10, 155:18, 157:20, 252:11, 254:24, 255:6, 80:20, 105:6, 108:23,
77:19, 83:16, 119:20, 158:15, 158:19, 159:20, 255:15, 256:25, 257:4, 202:16, 228:12, 231:11
120:2, 158:2, 161:25, 159:22, 160:13, 161:3 258:2, 259:19, 260:2, convoluted [1] - 234:3
171:3, 235:6, 237:4, 241:4, conflicts [2] - 155:15, 199:1 260:20 coordinating [1] - 141:16
248:20 confused [6] - 44:17, 53:11, Constitution [2] - 131:1, Coordinator [3] - 13:11,
compliant [5] - 236:21, 101:22, 102:25, 123:4, 253:14 25:5, 138:10
236:23, 237:10, 239:9 251:5 constitutional [1] - 123:17 copied [2] - 49:20, 49:25
complicated [1] - 229:16 confusing [2] - 52:1, 53:8 Constitutional [1] - 129:16 copies [4] - 133:15, 187:7,
complicating [1] - 178:8 connect [2] - 49:10, 153:25 constitutions [30] - 26:17, 222:15, 222:17
complied [5] - 117:16, connected [1] - 207:21 70:12, 99:6, 99:20, 117:11, copy [11] - 34:15, 35:9, 80:4,
156:11, 158:12, 158:14 connection [5] - 34:22, 48:2, 117:13, 139:13, 140:16, 89:3, 125:24, 131:17,
comply [8] - 83:14, 84:24, 202:11, 233:2, 238:3 141:10, 141:20, 141:22, 134:13, 157:9, 222:12,
100:20, 106:14, 127:15, Connie [11] - 30:20, 31:8, 144:1, 151:1, 152:10, 222:21, 258:1
171:10, 189:25, 241:14 31:15, 39:6, 39:10, 51:11, 152:11, 153:20, 186:22, cor [1] - 29:4
component [4] - 96:19, 74:21, 74:25, 75:3, 108:14, 188:9, 198:11, 198:13, core [1] - 223:23
96:22, 98:5, 139:20 149:3 198:19, 207:18, 210:21, Corinthians [2] - 111:21,
components [1] - 132:8 Connie 's [3] - 28:7, 42:16, 221:18, 228:7, 235:7, 224:8
con [3] - 153:10, 156:12, 43:14 237:15, 257:18, 260:10 corporate [1] - 95:18
257:17 consideration [5] - 28:17, constructed [1] - 235:24 Correct [11] - 45:23, 59:3,
concern [10] - 29:20, 29:21, 83:11, 84:1, 84:9, 146:17 construing [1] - 118:2 96:3, 115:24, 148:24,
29:25, 140:19, 202:2, considered [7] - 74:6, consultation [2] - 195:9, 150:17, 153:22, 169:12,
202:25, 203:6, 203:7, 161:14, 161:15, 163:23, 207:24 203:24, 210:6, 226:17
230:12, 232:23 168:5, 189:24, 249:18 consulted [1] - 228:6 correct [452] - 11:12, 12:22,
concerned [9] - 48:23, consistent [11] - 95:24, 96:1, contact [1] - 211:6 12:23, 18:7, 18:15, 23:3,
114:10, 114:14, 118:19, 120:7, 124:24, 130:17, contacted [1] - 110:16 23:11, 28:24, 28:25, 29:6,
118:22, 118:25, 203:21, 148:19, 200:23, 215:19, contain [1] - 160:23 29:18, 32:18, 34:3, 34:4,
231:4, 232:18 215:23, 243:14 content [2] - 233:18, 234:9 34:12, 34:13, 34:19, 34:20,
concerning [6] - 17:11, consists [1] - 10:6 contents [2] - 183:17, 201:7 37:8, 37:18, 38:1, 40:8,
60:18, 69:9, 69:21, 75:15, Constance [27] - 18:22, contest [5] - 51:8, 65:9, 40:11, 40:18, 41:4, 41:18,
124:16 20:25, 22:22, 23:8, 23:10, 65:10, 73:10, 74:16 43:2, 43:3, 43:5, 43:9,
concerns [13] - 72:17, 24:10, 24:14, 28:4, 28:16, contested [1] - 65:6 44:1, 44:2, 44:4, 44:6,
119:19, 120:2, 120:5, 31:1, 31:21, 34:11, 35:7, context [14] - 23:7, 25:19, 44:7, 44:9, 45:7, 45:8,
140:23, 141:3, 203:5, 73:16, 75:20, 83:4, 105:6, 41:1, 42:19, 53:1, 61:15, 45:10, 45:11, 46:1, 46:6,
203:9, 230:20, 230:25, 105:8, 107:24, 109:21, 69:4, 74:18, 112:20, 170:7, 46:22, 46:23, 47:1, 47:4,
232:12, 234:21 112:18, 112:24, 149:6, 170:8, 183:1, 183:3, 47:5, 48:5, 48:11, 48:13,
conclusion [4] - 81:25, 149:21, 149:24, 171:7 250:20 48:14, 49:16, 49:17, 49:19,
122:19, 174:5, 244:10 Constance 's [5] - 21:23, contingent [3] - 190:15, 49:22, 49:24, 49:25, 50:25,
condition [2] - 197:5, 197:19 22:1, 29:2, 83:8, 104:23 191:11, 194:23 51:17, 52:6, 52:12, 52:19,
conditioning [1] - 125:3 constit [1] - 26:9 continue [5] - 112:2, 115:1, 52:20, 53:3, 53:4, 53:6,
conduct [8] - 66:2, 142:10, constitution [81] - 34:17, 188:4, 219:23, 220:13 53:19, 54:10, 55:5, 55:7,
142:13, 142:14, 191:1, 35:4, 35:6, 48:9, 48:13, continued [2] - 9:23, 158:20 55:14, 55:19, 55:20, 59:2,
191:3, 201:13, 203:22 62:20, 64:25, 65:3, 66:20, Continuing [2] - 19:24, 42:6 62:14, 63:16, 64:18, 65:20,
conducted [5] - 35:25, 82:3, 66:23, 67:11, 68:24, 69:10, continuing [1] - 10:11 65:21, 65:24, 66:4, 66:5,
82:7, 207:7, 221:2 69:21, 71:7, 71:17, 71:21, contract [1] - 188:9 66:6, 66:12, 66:13, 66:14,
conducting [1] - 139:12 72:5, 72:9, 72:16, 77:21, contradict [1] - 164:15 66:17, 66:18, 66:21, 66:24,
conducts [1] - 23:18 78:3, 85:4, 85:9, 85:11, contradictory [16] - 144:5, 66:25, 67:3, 67:4, 67:7,
confession [1] - 171:16 85:18, 85:21, 88:22, 89:2, 161:14, 161:15, 162:10, 67:8, 68:6, 68:25, 69:1,
confident [2] - 162:18, 89:7, 89:20, 90:2, 90:8, 163:13, 163:21, 163:23, 69:10, 69:11, 69:13, 69:18,
162:21 90:16, 94:8, 94:23, 95:6, 164:10, 164:13, 164:24, 69:22, 70:20, 70:25, 71:1,
Confidential [1] - 17:10 95:8, 96:12, 96:17, 98:7, 165:3, 166:18, 167:6, 71:4, 71:5, 72:11, 72:18,
confidentiality [2] - 19:19, 100:14, 100:16, 100:24, 248:22, 249:23, 252:11 72:19, 72:20, 72:21, 72:23,
19:25 100:25, 101:15, 102:17, contradicts [1] - 251:12 73:3, 73:6, 73:8, 73:11,

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73:17, 73:25, 74:25, 75:13, 181:21, 182:2, 182:3, 140:20, 152:22, 167:9,
D
75:14, 75:16, 75:19, 76:2, 182:8, 182:9, 186:20, 182:24, 191:9, 194:10,
76:3, 76:22, 76:23, 77:7, 189:10, 189:12, 189:13, 195:10, 195:21, 198:15,
77:8, 78:4, 78:5, 78:9, 190:9, 190:23, 193:1, 198:17, 206:20, 208:21, DACA [2] - 166:20, 166:22
78:15, 78:18, 78:24, 80:16, 193:18, 193:20, 193:23, 209:18, 211:2, 211:23, dash [1] - 253:22
82:8, 82:24, 82:25, 83:2, 195:23, 196:19, 196:23, 239:16, 239:19, 240:12, data [3] - 153:5, 198:21,
83:7, 83:15, 83:19, 83:20, 197:8, 197:10, 197:22, 245:25, 246:23, 256:4, 198:22
83:21, 84:2, 84:3, 84:5, 198:3, 198:4, 198:6, 257:5 database [3] - 35:5, 153:5,
84:15, 84:22, 84:25, 85:4, 198:12, 198:20, 199:9, counsel [13] - 12:4, 90:22, 261:16
85:5, 88:5, 88:7, 88:10, 199:10, 199:13, 199:16, 95:21, 140:22, 145:19, date [8] - 24:18, 129:15,
89:7, 89:19, 90:17, 90:18, 199:18, 199:19, 200:15, 163:3, 189:17, 195:7, 130:10, 134:3, 148:6,
93:4, 93:5, 94:2, 95:11, 200:20, 203:23, 204:23, 196:6, 196:8, 199:17, 156:2, 236:16, 241:6
95:12, 95:25, 96:10, 97:17, 204:24, 206:9, 208:11, 239:20, 262:22 dated [8] - 44:3, 49:15, 50:3,
97:20, 97:22, 98:2, 99:4, 208:13, 209:1, 213:2, Counsel 's [19] - 117:23, 52:5, 113:17, 160:18,
99:7, 99:8, 100:14, 100:15, 214:7, 215:6, 215:10, 180:13, 180:17, 188:3, 162:4
100:17, 100:18, 100:21, 216:23, 216:25, 217:7, 195:14, 196:4, 198:24, dates [5] - 24:20, 34:16,
100:22, 101:21, 102:6, 218:1, 218:2, 218:9, 220:24, 239:24, 240:23, 159:8, 159:9, 221:21
102:7, 103:10, 103:14, 218:21, 219:24, 220:2, 241:10, 241:21, 246:5, day-to-day [2] - 116:11,
103:15, 103:18, 103:19, 221:1, 222:14, 226:17, 246:17, 253:8, 254:11, 116:15
103:20, 106:5, 106:10, 226:22, 227:10, 227:22, 255:21, 257:7, 261:2 days [5] - 52:18, 52:22, 55:5,
106:11, 106:15, 106:16, 227:23, 231:7, 233:12, counsel 's [1] - 256:14 100:11, 206:17
106:18, 106:19, 107:9, 233:18, 233:19, 233:21, counsels [1] - 210:25 de [2] - 245:14, 257:13
107:10, 108:2, 108:3, 233:24, 235:23, 236:3, count [1] - 143:18 deadline [2] - 245:19, 245:20
108:5, 108:6, 111:7, 236:10, 237:16, 237:20, counted [1] - 242:22 deal [1] - 142:16
111:11, 111:13, 111:14, 239:14, 239:19, 240:15, counter [1] - 198:16 dealings [1] - 108:25
111:25, 112:4, 112:13, 240:24, 241:5, 241:15, countering [1] - 73:12 Dean [12] - 9:3, 10:13, 10:15,
112:19, 113:3, 113:4, 242:18, 242:21, 244:21, couple [5] - 85:25, 88:21, 11:2, 39:14, 43:25, 50:8,
113:6, 113:21, 114:9, 244:25, 245:2, 245:10, 206:16, 210:20 50:13, 53:24, 142:12,
114:13, 115:5, 115:20, 247:12, 247:20, 247:24, course [5] - 108:18, 108:25, 143:5, 199:22
115:23, 115:25, 116:4, 248:3, 248:4, 248:9, 204:16, 230:5 Deans [1] - 11:7
116:7, 117:18, 118:3, 248:12, 248:15, 248:23, Court [2] - 185:1, 200:12 debating [1] - 19:11
118:4, 118:7, 118:17, 248:24, 249:2, 249:3, courtesy [1] - 162:17 December [2] - 138:21,
118:24, 120:19, 123:19, 249:9, 249:14, 249:25, 148:13
covenant [5] - 90:6, 91:20,
123:21, 123:23, 124:10, 250:10, 251:14, 251:18, decide [1] - 166:5
92:16, 98:16, 101:12
124:12, 124:18, 125:5, 251:20, 253:5, 253:15,
covered [4] - 190:17, 191:5, decided [2] - 55:21, 216:9
125:6, 125:8, 125:9, 253:16, 253:18, 253:20,
191:12, 194:25 deciding [1] - 37:4
126:18, 126:25, 130:3, 254:19, 254:21, 254:22,
created [4] - 13:17, 13:18, decision [18] - 34:22, 41:3,
131:11, 131:15, 131:16, 255:2, 255:3, 255:11,
185:12, 242:8 74:10, 76:9, 76:11, 83:1,
131:25, 133:13, 136:2, 255:12, 256:1, 256:2,
credo [2] - 176:12, 176:23 84:4, 106:10, 119:16,
138:6, 138:13, 139:24, 256:8, 256:9, 256:14,
credos [1] - 173:9 121:4, 125:2, 137:7,
140:1, 140:2, 140:16, 256:20, 256:23, 257:2,
creed [19] - 41:17, 170:2, 165:17, 204:9, 208:18,
140:17, 142:17, 142:22, 257:3, 257:21, 257:23,
170:5, 171:15, 171:22, 208:20, 246:11, 246:14
143:12, 143:15, 148:7, 258:12, 259:4, 259:15,
171:25, 172:3, 172:16, decisions [2] - 37:2, 141:7
148:8, 148:20, 149:11, 261:11, 261:12
172:22, 173:4, 173:13, decla [1] - 184:25
150:12, 150:13, 150:19, corrected [5] - 17:1, 17:2,
173:15, 173:24, 174:18, declaration [1] - 185:1
151:22, 152:4, 152:18, 17:4, 28:20, 237:15
174:19, 175:16, 175:25, deemed [1] - 248:21
153:22, 157:10, 157:18, correctly [2] - 157:16, 157:23
176:24, 255:7 Def [2] - 253:19, 253:22
158:2, 158:3, 159:1, 162:1, correlate [1] - 130:1
Creed [1] - 146:15 DEF [1] - 253:22
162:15, 163:6, 163:14, correspond [1] - 132:25
crime [2] - 150:16, 168:12 defend [3] - 203:25, 204:1,
163:15, 164:12, 164:17, corresponds [4] - 131:15,
criminal [2] - 168:3, 168:17 204:2
164:20, 164:21, 165:25, 131:23, 132:2, 133:11
critical [1] - 251:9 Defendant [1] - 253:22
166:3, 167:21, 169:3, Cory [20] - 22:6, 22:7, 22:20,
169:6, 169:9, 170:3, 170:4, cryptic [1] - 54:11 Defendants [1] - 15:7
22:21, 23:7, 27:19, 141:17,
171:11, 171:19, 171:20, CSIL [5] - 143:14, 152:8, Defendants ' [1] - 14:6
141:23, 141:25, 142:5,
173:6, 175:3, 175:8, 158:25, 165:10, 165:16 defense [1] - 202:22
185:24, 186:8, 186:16,
175:16, 175:17, 175:19, cultural [2] - 9:14, 9:15 define [1] - 39:18
188:5, 195:18, 205:18,
175:20, 175:23, 176:3, current [3] - 141:11, 155:2, defines [1] - 171:15
206:4
176:4, 176:16, 177:11, 237:11 definitely [3] - 60:13, 79:25,
Cory's [2] - 23:1, 207:2
177:12, 177:15, 178:13, customary [1] - 261:19 109:4
Counsel [27] - 39:17, 58:9,
178:15, 179:4, 179:5, definition [1] - 111:15
80:24, 128:12, 139:16,
179:18, 180:1, 180:10, delay [1] - 209:17

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delete [1] - 189:7 development [1] - 142:3 Discipline [1] - 82:3 Division [4] - 10:13, 11:5,
deleted [5] - 102:16, 102:21, difference [4] - 42:25, 92:20, disconnect [1] - 122:16 212:22, 219:1
102:22, 103:9, 103:21 127:2, 135:16 discourage [1] - 249:10 doc [3] - 33:14, 101:8, 237:4
deleting [1] - 103:4 differences [1] - 135:21 discovered /learned [1] - Doctrine [6] - 48:2, 48:7,
delineated [1] - 100:17 different [11] - 25:12, 119:23, 206:7 87:1, 87:16, 87:17, 89:15
Democratic [1] - 172:18 128:11, 153:23, 174:19, discovery [2] - 133:21, 239:1 docu [2] - 121:6, 134:12
Democrats [3] - 172:7, 204:18, 205:1, 205:6, discretion [1] - 165:11 Document [66] - 16:4, 18:9,
172:10, 172:15 224:16, 225:9 discrim [1] - 71:2 24:3, 27:25, 32:12, 38:21,
denied [19] - 38:6, 43:4, differentiation [1] - 204:22 discriminate [12] - 26:4, 52:2, 54:22, 81:21, 99:22,
46:12, 46:13, 46:24, 47:2, differently [1] - 226:12 45:15, 70:19, 72:2, 127:19, 101:6, 101:8, 104:9, 107:3,
47:7, 47:15, 47:18, 48:17, difficult [1] - 107:17 171:25, 190:24, 191:25, 107:19, 120:20, 121:20,
49:6, 65:19, 120:12, diligently [1] - 24:19 192:3, 192:7, 192:9, 121:23, 122:2, 122:3,
173:10, 192:23, 193:2, Dinette [1] - 182:7 213:12 125:11, 129:1, 129:21,
193:3, 216:19, 216:21 direct [8] - 13:6, 20:5, 21:23, discriminates [1] - 71:13 130:1, 130:10, 131:7,
denier [2] - 64:9, 64:12 36:20, 57:10, 83:9, 198:24, discriminating [1] - 121:17 131:8, 131:23, 132:1,
denies [1] - 174:17 228:10 discrimination [27] - 32:17, 132:23, 132:25, 133:8,
deny [5] - 76:21, 121:1, directed [3] - 118:17, 220:23, 124:20, 146:19, 148:23, 133:12, 146:13, 147:13,
121:11, 124:8, 191:20 230:8 149:1, 172:16, 172:21, 157:2, 160:17, 161:19,
denying [1] - 124:24 directing [2] - 22:18, 102:14 175:15, 177:10, 190:22, 162:3, 163:10, 170:13,
departments [1] - 236:4 direction [11] - 88:24, 192:17, 192:18, 192:21, 181:1, 181:21, 183:8,
deponent [1] - 8:3 139:15, 166:6, 166:10, 193:6, 193:10, 193:22, 184:9, 186:2, 199:20,
deposed [2] - 10:21, 11:20 180:18, 194:9, 195:8, 194:8, 196:22, 199:9, 205:16, 220:3, 222:9,
Deposition [2] - 115:18 195:14, 195:21, 211:24, 200:18, 201:12, 202:19, 222:17, 223:2, 224:2,
deposition [11] - 12:25, 13:3, 255:22 213:7, 215:5, 216:4, 250:8, 225:7, 225:12, 227:16,
14:9, 115:22, 121:7, directions [1] - 240:13 255:7 231:14, 235:2, 236:5,
147:21, 150:6, 175:6, directive [1] - 151:5 discriminatory [2] - 47:12, 236:25, 247:1, 252:7,
183:16, 188:19, 194:14 directly [17] - 11:13, 45:17, 121:14 253:10, 256:6
deprive [1] - 146:16 60:14, 74:24, 76:2, 76:5, discuss [6] - 33:23, 33:24, document [136] - 12:16,
depth [3] - 109:6, 227:14, 78:17, 82:10, 83:2, 143:11, 40:4, 239:10, 252:1, 14:2, 14:8, 14:16, 15:4,
227:15 151:21, 151:24, 184:16, 252:12 16:22, 16:23, 17:7, 17:14,
deregister [2] - 178:23, 187:9, 230:11, 236:23, discussed [10] - 30:25, 17:17, 17:18, 18:2, 18:6,
248:25 65:12, 108:16, 110:4, 18:7, 18:13, 18:17, 19:4,
179:6
Director [17] - 8:21, 8:23, 185:17, 204:12, 235:12, 19:14, 23:23, 24:5, 24:21,
deregistered [16] - 156:14,
8:24, 8:25, 9:1, 9:3, 9:7, 236:9, 255:10, 258:25 28:1, 28:11, 32:13, 32:19,
184:5, 237:19, 239:5,
9:19, 9:22, 10:4, 32:24, discussing [1] - 183:2 32:22, 33:15, 34:8, 35:12,
240:19, 240:22, 241:2,
40:3, 53:9, 142:1, 209:10, discussion [31] - 10:25, 36:21, 37:3, 38:25, 39:25,
241:3, 241:7, 241:13,
229:17 26:20, 41:24, 42:9, 42:21, 43:19, 43:21, 49:12, 49:13,
245:14, 245:16, 246:3,
director [1] - 149:24 43:8, 51:18, 60:24, 77:9, 51:22, 52:3, 54:23, 54:25,
246:5, 246:10, 257:9
85:17, 106:20, 109:6, 56:23, 56:24, 57:22, 58:11,
deregistering [1] - 179:4 Directors [4] - 13:12, 22:8,
122:6, 124:21, 125:12, 81:21, 82:12, 82:14, 82:16,
derived [1] - 74:20 25:7, 143:8
134:9, 136:7, 149:12, 82:18, 85:2, 85:6, 86:16,
described [1] - 42:19 dis [1] - 213:7
166:9, 166:10, 180:21, 87:5, 97:12, 97:13, 99:23,
description [2] - 159:11, disabled [1] - 153:9
181:3, 181:18, 204:14, 104:10, 108:1, 113:9,
194:23 disabling [1] - 154:9
205:7, 213:18, 217:21, 121:21, 122:4, 122:9,
design [2] - 96:7, 98:21 disagree [1] - 115:15
225:20, 231:18, 234:15, 122:22, 125:15, 125:20,
designate [1] - 116:16 disagreed [8] - 47:3, 47:16,
263:1 125:23, 126:1, 126:2,
designed [1] - 83:23 48:23, 49:5, 65:20, 119:13,
discussions [3] - 60:17, 126:5, 127:25, 128:24,
designee [1] - 95:18 203:10, 204:7
77:12, 104:21 129:4, 129:5, 131:21,
desire [2] - 111:10, 252:17 disagreement [3] - 79:18,
dispute [2] - 33:24, 40:24 132:3, 132:8, 133:11,
detail [7] - 66:22, 67:10, 190:15, 194:24
disputing [2] - 59:18, 76:9 135:14, 135:18, 146:10,
69:9, 69:20, 70:11, 71:16, disagreements [1] - 61:19
147:17, 147:19, 148:2,
72:3 disagrees [1] - 46:3 disqualifications [1] - 83:24
153:12, 157:1, 157:2,
detailed [1] - 71:21 disappointed [1] - 201:22 distinction [1] - 46:8
160:2, 160:6, 160:15,
determine [7] - 40:9, 110:3, disappointment [2] - 201:24 distinguish [2] - 101:18,
163:12, 164:1, 165:7,
110:11, 141:10, 165:12, disapproves [1] - 101:25 101:20
170:14, 170:22, 171:9,
177:3, 180:13 disassociating [1] - 179:3 distinguishable [1] - 63:8
171:12, 181:24, 183:10,
determining [2] - 40:5, 40:17 disband [4] - 178:15, 178:19, Diversity [10] - 14:25, 18:22,
183:15, 184:13, 184:16,
develop [1] - 131:4 178:23, 178:25 20:12, 21:2, 21:21, 22:15,
184:18, 185:6, 185:11,
developed [1] - 73:16 discerned [1] - 167:6 37:9, 39:16, 149:23,
186:2, 186:10, 186:24,
Development [3] - 13:11, discipline [3] - 33:6, 119:23, 170:19
186:25, 189:14, 195:17,
25:6, 138:10 182:15 diversity [1] - 21:20

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199:5, 205:17, 205:21, drafting [1] - 104:15 232:15, 233:14, 233:15, entries [1] - 129:14
205:23, 210:1, 220:4, draw [2] - 15:5, 212:11 233:18, 233:23, 234:1, entry [1] - 133:12
222:6, 222:7, 226:14, driven [2] - 180:6, 180:9 234:4, 234:11, 236:8, environmental [2] - 64:8,
227:9, 227:11, 227:17, drives [1] - 234:7 236:9, 246:3, 247:2, 247:4, 64:12
232:3, 234:13, 235:2, drove [1] - 69:17 247:7, 247:17, 247:21, EOD [36] - 23:16, 23:17,
236:6, 237:1, 237:8, drunken [1] - 142:15 248:3, 251:10, 255:11, 23:18, 28:18, 36:1, 41:9,
237:12, 239:4, 245:3, due [2] - 194:12, 236:16 255:14, 255:25, 256:5 51:12, 59:21, 59:22, 61:10,
253:11, 258:1 duly [1] - 8:6 email 's [1] - 209:4 61:17, 69:15, 69:17, 69:22,
document 's [1] - 224:21 during [10] - 65:7, 90:19, emailed [9] - 57:13, 57:15, 74:7, 74:9, 74:19, 74:23,
documents [61] - 13:4, 90:20, 107:11, 119:24, 57:16, 57:17, 57:18, 58:6, 75:9, 75:13, 76:10, 76:12,
13:14, 13:16, 13:17, 13:18, 186:6, 196:16, 206:7, 80:10, 80:12, 208:24 82:10, 82:12, 82:18, 108:5,
13:22, 14:12, 14:15, 14:21, 213:18, 242:9 emails [13] - 57:21, 57:22, 142:21, 142:22, 148:25,
15:5, 15:13, 15:20, 15:24, duties [1] - 171:8 60:11, 60:12, 79:23, 80:14, 150:1, 170:15, 171:3,
16:1, 34:14, 34:19, 34:21, dynamic [1] - 255:19 156:17, 156:18, 160:18, 174:3, 201:16
35:7, 35:13, 36:12, 36:18, 162:3, 220:25, 234:20, EOD 's [2] - 148:22, 174:5
66:21, 66:24, 114:8, 121:8, 247:18 EOD -related [1] - 82:18
123:1, 127:23, 133:14,
E
embrace [5] - 64:18, 64:21, equal [2] - 95:22, 216:12
134:13, 134:15, 135:9, 96:15, 98:2, 98:23 Equal [9] - 18:21, 20:12,
146:10, 147:25, 153:4, e-mailed [1] - 27:18 emphasis [1] - 163:14 21:1, 21:20, 22:15, 37:9,
153:10, 154:14, 156:13, Earl [2] - 170:20, 170:21 employee [2] - 229:19 39:16, 149:23, 170:19
160:7, 161:6, 161:13, Earl's [1] - 171:2 employees [5] - 158:25, equivalent [1] - 199:25
163:3, 163:7, 163:22, early [3] - 62:16, 141:13, 159:2, 165:10, 165:16, Eric [2] - 16:7, 19:9
183:13, 183:14, 185:10, 185:16 202:7 Erika [2] - 237:5, 237:7
187:2, 187:13, 187:19, earnest [1] - 32:10 employer [1] - 8:15 Erin [4] - 209:8, 209:10,
188:1, 188:19, 188:20, edit [1] - 235:17 employment [2] - 39:12, 209:11, 235:16
189:3, 207:1, 209:14, editing [1] - 235:18 184:24 error [2] - 50:10, 50:15
239:17, 239:22, 242:2, edits [1] - 105:24 enable [1] - 72:10 essence [1] - 84:6
242:8, 253:13 effect [2] - 81:16, 248:16 enact [1] - 211:9 essentially [1] - 99:3
Dodge [2] - 21:18, 21:19 effectively [1] - 46:5 encompassing [1] - 190:7 established [4] - 40:7,
dodging [1] - 178:6 effort [10] - 32:9, 32:10, 37:6, encourage [3] - 148:19, 203:19, 205:2, 213:3
done [15] - 25:22, 111:22, 141:16, 178:17, 179:6, 253:1, 256:7 Estell [7] - 43:25, 44:16,
135:8, 173:19, 180:3, 185:9, 189:1, 220:20, encouraged [2] - 252:10, 44:20, 47:14, 49:16, 49:18,
188:24, 198:11, 207:10, 228:2 256:22 62:12
218:18, 221:9, 221:12, efforts [1] - 235:6 end [4] - 59:12, 96:3, 106:2, et [8] - 83:9, 111:21, 160:11,
227:3, 227:9, 227:11, eight [1] - 241:2 123:7 190:16, 194:24, 216:12,
248:13 Eikenberry [1] - 62:12 ended [3] - 77:22, 144:15, 227:2, 258:15
double [4] - 58:6, 145:12, either [6] - 95:1, 121:11, 224:5 Event [2] - 25:7, 138:14
227:1, 241:22 162:19, 182:23, 201:19, enforce [2] - 218:20, 252:19 event [1] - 203:1
double -check [4] - 58:6, 258:25 enforced [1] - 204:25 events [3] - 9:13, 10:8,
145:12, 227:1, 241:22 elected [2] - 73:4, 89:3 enforcement [7] - 128:10, 138:15
down [20] - 10:17, 12:10, electronic [1] - 60:10 130:17, 132:10, 140:25, eventually [2] - 146:5,
26:8, 60:15, 66:16, 86:9, eligible [6] - 46:2, 79:14, 141:4, 153:24, 180:4 208:21
110:16, 111:4, 126:9, 120:14, 169:24, 223:21 enforcing [1] - 20:23 evidence [7] - 82:23, 83:2,
130:10, 130:25, 146:2, eliminate [1] - 84:8 engaged [3] - 200:17, 83:3, 83:6, 109:12, 110:11,
146:4, 148:21, 161:9, eliminated [1] - 84:1 201:12, 202:19 202:3
186:18, 200:21, 213:21, email [76] - 28:6, 28:15, engineering [1] - 26:22 ex [1] - 150:18
223:11, 225:19 28:16, 28:22, 29:3, 29:7, Enrichment [1] - 14:25 ex-spouse [1] - 150:18
download [1] - 256:24 29:12, 30:1, 30:10, 31:21, ensure [6] - 70:16, 71:8, exact [3] - 171:8, 183:3,
downloaded [1] - 258:2 34:16, 36:23, 38:11, 38:12, 71:17, 71:21, 72:5, 83:25 209:19
dozen [1] - 15:17 49:15, 49:19, 50:3, 55:12, ensuring [2] - 84:17, 102:12 exactly [11] - 16:19, 25:9,
draft [20] - 27:20, 28:8, 57:5, 57:25, 58:2, 58:6, entered [3] - 140:2, 167:24, 68:7, 69:1, 80:13, 81:16,
28:12, 28:23, 29:11, 30:19, 60:4, 60:6, 60:12, 80:2, 259:11 138:6, 138:7, 158:18,
31:5, 31:11, 31:12, 31:19, 80:3, 85:2, 85:3, 140:11, Entered [1] - 140:5 180:13, 241:23
31:22, 31:24, 32:1, 32:6, 157:14, 158:9, 160:10, entering [1] - 222:7 EXAMINATION [1] - 8:9
55:12, 80:2, 80:3, 80:4, 160:16, 160:19, 160:20, entire [6] - 115:5, 163:17, examined [1] - 8:7
156:17 160:23, 161:19, 162:3, 175:1, 188:19, 198:10, example [9] - 27:2, 35:4,
drafted [6] - 156:18, 186:7, 162:11, 162:23, 163:10, 203:25 89:18, 150:10, 176:5,
195:16, 235:9, 235:14, 164:19, 182:1, 182:10, entirety [4] - 71:24, 109:18, 179:21, 192:20, 208:5,
235:23 201:19, 206:21, 209:1, 177:2, 249:20 237:14
Drafter [1] - 55:12 221:19, 229:18, 229:23, entitled [2] - 135:14, 175:7 examples [4] - 145:3, 145:7,

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146:16, 159:15 existence [1] - 193:16 76:9, 76:22, 109:21, fifth [1] - 184:24
Excel [2] - 189:11, 222:5 expect [4] - 69:25, 73:24, 109:23, 178:1, 178:9 fight [1] - 124:20
except [6] - 134:12, 210:10, 74:8, 82:11 factual [7] - 51:8, 73:10, figment [2] - 192:8, 192:16
242:16, 257:17, 257:19, expectation [1] - 70:3 73:16, 73:24, 74:16, 74:18, file [3] - 73:13, 74:1, 74:2
261:21 expectations [1] - 69:25 105:23 filed [8] - 19:2, 20:8, 20:10,
exception [8] - 130:20, expected [10] - 67:6, 67:22, faculty [7] - 23:13, 204:6, 20:20, 22:13, 68:25, 69:13,
173:1, 210:19, 213:9, 70:7, 70:8, 73:14, 73:18, 234:5, 234:6, 234:21, 246:18
215:12, 215:14, 218:4, 73:21, 73:25, 148:10, 254:2, 254:25 filing [1] - 17:12
239:15 210:9 failed [2] - 63:9, 158:15 final [8] - 28:8, 31:22, 41:5,
exceptions [2] - 209:23, experience [2] - 75:6, 107:17 failure [3] - 19:19, 114:7, 88:6, 118:2, 165:17,
215:22 explain [6] - 35:13, 69:2, 241:14 246:14, 256:1
excerpts [1] - 36:17 94:19, 102:8, 126:13, Failure [1] - 19:24 finalized [3] - 27:20, 28:23,
exchange [1] - 79:23 164:10 fair [10] - 54:18, 123:13, 29:11
exclude [16] - 78:12, 167:18, explained [2] - 73:2, 159:21 135:25, 140:12, 150:4, financial [2] - 144:7, 144:8
168:2, 169:17, 172:3, explains [3] - 148:4, 165:7, 217:8, 217:20, 244:10, financial 's [1] - 157:23
172:7, 172:10, 172:14, 249:5 253:2, 255:25 findings [23] - 28:8, 28:12,
173:2, 173:14, 173:24, explanation [4] - 53:23, 54:4, faith [4] - 29:15, 30:12, 32:23, 33:24, 35:25, 36:4,
177:9, 179:20, 214:15, 54:12, 208:14 171:16, 249:11 51:9, 51:16, 59:18, 60:25,
250:14, 255:4 explanatory [1] - 220:11 Faith [14] - 29:16, 48:1, 61:6, 66:8, 73:11, 73:24,
excluded [3] - 167:3, 168:16, explicit [1] - 224:9 78:22, 86:21, 86:25, 88:4, 74:19, 74:24, 75:10, 75:13,
172:18 express [20] - 44:16, 45:13, 89:4, 89:15, 100:19, 75:17, 76:1, 76:5, 82:12,
excludes [4] - 175:14, 61:2, 92:1, 92:8, 93:24, 102:13, 106:13, 170:1, 104:22
178:10, 178:11, 192:15 94:5, 94:20, 94:22, 95:1, 173:25, 245:8 Findings [22] - 28:24, 31:14,
exclusion [1] - 172:12 95:5, 95:7, 99:6, 201:2, faith-based [2] - 29:15, 34:22, 37:8, 38:3, 38:11,
Excuse [2] - 15:12, 226:3 201:10, 201:18, 202:2, 30:12 42:16, 51:11, 59:21, 61:9,
excuse [31] - 16:6, 16:7, 202:25, 252:17 fall [2] - 148:7, 191:2 61:17, 65:7, 69:17, 69:22,
19:20, 24:4, 32:17, 34:10, expressed [4] - 42:2, 42:7, false [7] - 94:12, 196:17, 74:7, 74:20, 74:22, 104:23,
38:24, 46:1, 52:9, 62:1, 93:14, 234:11 196:18, 197:13, 197:21, 109:14, 110:14, 201:16,
62:15, 68:9, 88:16, 113:25, expressing [1] - 93:11 198:11, 199:3 203:7
144:11, 151:11, 165:15, expression [4] - 99:9, 99:12, familiar [7] - 121:21, 122:9, fine [6] - 32:3, 49:11, 119:3,
167:7, 175:13, 184:3, 99:14, 99:16 131:20, 185:5, 212:14, 138:2, 160:1, 226:11
184:10, 187:12, 192:13, expressly [1] - 66:16 235:2, 236:6 Finger [10] - 14:18, 24:1,
208:4, 223:15, 223:22, extended [4] - 206:13, familiarize [1] - 247:2 24:25, 25:1, 25:5, 27:19,
224:13, 224:20, 243:12, 206:16, 213:24, 215:18 familiarizing [1] - 201:6 29:7, 108:13, 138:9, 203:5
246:8, 259:20 extra [2] - 208:8, 208:9 family [2] - 20:16, 20:19 Finger 's [1] - 25:2
executive [3] - 245:7, extracted [1] - 36:25 far [17] - 12:5, 15:23, 19:6, finish [3] - 226:7, 238:10,
245:22, 258:24 eye [2] - 218:15, 219:15 51:6, 51:15, 75:2, 88:8, 251:9
Executive [7] - 9:1, 9:3, 10:4, eyes [1] - 227:2 118:1, 134:20, 136:3, First [2] - 14:7, 95:21
32:24, 40:2, 88:24, 229:17 200:1, 219:22, 223:4, first [43] - 17:16, 18:4, 30:22,
exempt [3] - 127:8, 211:16, 228:5, 244:17, 260:2, 34:9, 55:13, 81:9, 82:2,
F
211:18 260:25 85:18, 89:16, 97:15, 98:13,
exemption [17] - 126:11, February [12] - 113:17, 106:3, 109:17, 116:1,
127:3, 127:6, 127:7, face [15] - 60:5, 60:14, 60:16, 134:3, 141:1, 141:13, 129:19, 138:20, 139:7,
127:11, 127:14, 209:16, 80:1, 98:4, 100:19, 100:25, 146:12, 153:9, 154:9, 152:24, 153:9, 154:9,
211:2, 211:4, 211:5, 211:8, 101:9, 101:16, 106:13, 185:16, 221:4, 221:21, 156:22, 162:19, 162:24,
211:14, 212:8, 212:11, 106:17 242:9, 242:17 163:5, 166:1, 170:18,
212:13, 212:17, 213:23 face-to-face [4] - 60:5, federal [5] - 91:4, 93:16, 185:13, 194:18, 200:12,
exhibit [5] - 12:15, 17:24, 60:14, 60:16, 80:1 94:9, 94:17, 216:10 205:13, 220:22, 220:24,
18:8, 43:19, 181:20 Facebook [3] - 34:15, 35:9, Federalist [1] - 208:5 221:7, 221:9, 221:12,
Exhibit [16] - 16:18, 18:2, 35:20 FedEx [1] - 35:13 222:20, 223:1, 223:2,
18:3, 19:14, 27:17, 88:2, facilities [1] - 10:7 feelings [1] - 201:18 227:11, 233:3, 236:14,
113:7, 115:16, 115:17, fact [15] - 36:20, 62:23, Fellowship [2] - 245:12, 239:8, 254:13
115:20, 132:25, 185:5, 66:15, 77:17, 78:2, 81:11, 246:1 five [3] - 12:21, 55:5, 240:2
231:24, 242:1 95:17, 101:24, 105:12, Fellowship 's [1] - 248:6 flag [2] - 243:21, 245:6
exhibits [5] - 16:8, 18:4, 112:25, 124:23, 134:10, felonies [1] - 168:24 flagged [7] - 167:4, 198:14,
181:14, 181:15, 263:4 174:8, 208:3, 246:16 felt [3] - 81:4, 81:7 199:11, 244:11, 245:22,
exist [7] - 48:9, 76:18, factor [1] - 178:8 female [1] - 90:14 245:23, 254:10
134:22, 177:16, 177:19, facts [16] - 30:23, 30:24, Feminist [2] - 36:9, 75:23 flagging [1] - 199:2
177:21 31:2, 31:6, 37:7, 38:9, few [2] - 12:4, 257:24 flip [13] - 16:4, 27:25, 28:10,
existed [1] - 196:16 40:24, 59:14, 60:22, 76:7, fifteen [1] - 15:15 28:11, 38:21, 101:5,

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157:11, 200:11, 222:9, 50:10 123:11, 192:23, 192:25, Governance [1] - 189:8
222:16, 224:25, 243:8, fraternities [32] - 126:3, 193:3, 193:4 governing [12] - 34:2, 66:21,
258:8 126:12, 127:1, 127:3, Gazette [1] - 237:18 66:24, 153:4, 153:10,
flow [4] - 59:12, 60:9, 60:21, 127:10, 127:12, 127:15, GBTQPA [1] - 258:15 154:14, 156:13, 161:6,
60:23 127:18, 130:21, 184:4, gender [10] - 71:14, 96:19, 161:13, 163:22, 209:14
focus [3] - 62:25, 97:14, 207:12, 207:19, 208:19, 97:1, 97:4, 98:5, 98:7, government [6] - 120:12,
142:13 209:21, 209:24, 210:11, 99:7, 101:3, 218:6, 259:17 121:1, 121:4, 121:13,
focused [1] - 64:11 210:18, 210:22, 211:7, Gender [1] - 96:22 124:22, 124:23
folder [3] - 181:5, 181:10, 211:9, 211:12, 211:18, general [10] - 59:15, 63:12, Government [1] - 236:20
181:11 212:7, 213:24, 217:22, 145:2, 176:17, 182:12, Graduate [3] - 245:12, 246:1,
follow [11] - 33:13, 58:9, 217:25, 218:4, 235:8, 183:24, 206:6, 231:5, 248:6
58:12, 63:9, 89:17, 146:6, 235:13, 239:11, 242:16, 258:24, 260:7 great [3] - 77:1, 81:20,
159:9, 159:12, 176:23, 257:18 General [47] - 39:17, 80:24, 231:17
187:8, 249:19 Fraternities [1] - 211:15 117:23, 139:16, 140:20, greatly [1] - 252:13
Follow [1] - 189:9 Fraternity [3] - 209:11, 152:22, 167:9, 180:13, greed [1] - 89:24
follow -up [4] - 63:9, 159:9, 209:16, 239:7 180:16, 182:24, 188:2, Greek [1] - 111:16
159:12, 187:8 fraternity [2] - 130:20, 191:8, 194:10, 195:9, ground [1] - 12:5
Follow -up [1] - 189:9 210:21 195:14, 195:21, 196:4, grounds [1] - 40:10
followed [1] - 67:25 Fraternity /Sorority [1] - 9:11 198:15, 198:17, 198:24, group [71] - 41:25, 42:10,
following [6] - 34:14, 75:11, free [3] - 95:1, 95:2, 252:16 206:20, 208:20, 209:18, 42:22, 45:14, 46:5, 63:15,
83:14, 112:22, 180:2, freedom [2] - 93:6, 231:12 211:1, 211:23, 220:24, 64:11, 67:21, 68:11, 68:18,
247:18 freedoms [1] - 231:13 239:16, 239:19, 239:23, 71:10, 71:13, 72:11, 74:16,
follows [2] - 8:8, 111:13 frequently [1] - 20:4 240:12, 240:23, 241:10, 79:11, 79:12, 84:17, 92:7,
followup [5] - 145:18, 187:4, Friday [2] - 52:16, 52:18 241:21, 245:5, 245:7, 93:24, 94:3, 94:5, 96:17,
187:6, 209:7, 242:11 friends [2] - 20:16, 20:20 245:25, 246:5, 246:17, 102:12, 112:15, 121:12,
football [5] - 214:3, 214:14, front [7] - 12:15, 15:4, 246:23, 253:8, 254:11, 123:8, 146:22, 153:8,
214:21, 218:13, 219:7 222:10, 224:22, 224:25, 255:21, 256:4, 257:5, 166:19, 167:11, 168:1,
forbade [1] - 62:20 229:7, 260:22 257:7, 258:20, 261:2 168:10, 168:11, 168:25,
forbid [1] - 213:7 full [11] - 144:18, 152:12, generalities [1] - 61:24 169:1, 174:11, 174:13,
force [1] - 217:1 154:15, 155:1, 155:4, generally [2] - 11:22, 217:21 174:17, 176:1, 176:25,
Form [1] - 17:10 156:16, 158:25, 160:24, generate [1] - 176:15 177:6, 177:16, 178:9,
form [22] - 17:23, 19:25, 237:11, 238:18 genetic [1] - 149:10 178:11, 178:15, 179:14,
36:23, 54:3, 89:23, 92:4, full-time [1] - 158:25 Georgina [4] - 21:18, 21:19, 179:17, 192:6, 192:10,
94:3, 94:21, 95:2, 160:19, fullest [1] - 33:15 22:4 192:15, 193:1, 202:19,
166:11, 166:12, 168:11, fully [2] - 70:7, 218:23 gist [3] - 86:15, 113:23, 204:10, 216:13, 219:7,
169:1, 169:7, 175:22, function [4] - 27:6, 83:12, 114:4 221:7, 232:24, 232:25,
178:18, 179:7, 222:4, 117:6, 177:1 given [31] - 21:6, 32:23, 233:8, 239:12, 241:16,
243:4, 248:11 functions [2] - 10:1, 199:24 65:13, 96:15, 98:3, 98:24, 242:13, 242:15, 242:16,
formal [2] - 32:16, 171:15 funding [8] - 121:2, 121:5, 101:12, 108:20, 110:9, 244:4, 245:24, 250:17,
formed [3] - 167:11, 168:1, 121:12, 123:14, 123:17, 127:7, 127:14, 143:23, 251:16, 252:25
168:10 124:8, 124:24, 125:4 143:25, 144:23, 145:3, group 's [6] - 64:18, 66:20,
forms [1] - 89:24 funneled [1] - 188:3 145:9, 159:4, 162:14, 123:9, 125:4, 174:19,
fornication [1] - 111:19 future [4] - 83:18, 83:23, 166:7, 166:10, 174:2, 231:12
forth [5] - 34:18, 52:12, 89:1, 132:4, 132:5 175:1, 177:25, 183:6, groups [92] - 25:11, 26:4,
148:19, 254:21 186:5, 198:22, 208:8, 29:15, 29:25, 30:12, 30:15,
208:9, 210:19, 239:8, 36:3, 62:23, 64:17, 67:10,
forward [10] - 37:19, 41:2, G
67:15, 70:16, 70:17, 70:23, 255:21 67:22, 67:25, 68:8, 70:2,
80:17, 194:11, 195:6, glee [2] - 26:21, 27:3 70:11, 71:12, 71:16, 72:1,
gain [1] - 35:2 goal [3] - 148:17, 216:3, 72:2, 75:15, 84:14, 92:4,
195:9
gaps [1] - 163:3 236:21 94:21, 95:2, 99:2, 99:3,
forwarded [2] - 29:11,
Gaskill [4] - 110:17, 110:20, God [5] - 96:15, 98:3, 98:24, 124:9, 124:12, 153:19,
239:20
110:21 101:12, 111:23 154:21, 155:23, 156:10,
forwarding [7] - 29:6, 39:5,
gather [1] - 227:1 God 's [11] - 90:4, 91:7, 158:1, 158:5, 158:12,
39:7, 50:21, 236:18,
247:23 gathered [1] - 189:14 91:18, 92:14, 93:12, 96:7, 158:14, 159:24, 162:19,
gathering [2] - 14:11, 15:20 96:8, 97:15, 98:14, 98:21 162:22, 162:23, 164:18,
founded [1] - 258:14
gauge [1] - 182:19 God -given [4] - 96:15, 98:3, 167:22, 169:25, 172:2,
four [2] - 12:21, 258:8
gay [19] - 38:7, 38:16, 42:9, 98:24, 101:12 173:7, 173:14, 173:23,
fourth [1] - 110:15
43:2, 46:13, 48:16, 49:1, Gordon [3] - 200:3, 200:4, 175:21, 175:22, 178:18,
Fourth [1] - 14:6
49:4, 65:15, 65:23, 71:3, 200:5 178:23, 179:7, 179:20,
frame [1] - 159:8
110:21, 110:22, 112:2, govern [2] - 74:14, 233:25 191:14, 197:2, 200:1,
frankly [3] - 24:20, 44:17,

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202:11, 202:12, 205:9, 202:2, 202:6, 202:10, 97:9, 98:4, 98:8, 99:10,
I
208:1, 212:23, 212:25, 234:20, 241:13 99:13, 100:20, 101:1,
220:21, 220:22, 221:5, heard [4] - 108:7, 108:10, 101:9, 102:3, 102:18,
221:8, 221:11, 221:15, 162:23, 202:25 106:14, 111:1, 112:7, idea [1] - 41:12
221:16, 221:25, 222:2, hearing [2] - 20:13, 218:11 112:15, 113:2, 114:6, identification [1] - 263:5
227:18, 234:25, 236:21, heightened [1] - 68:7 114:11, 117:11, 117:16, identified [3] - 146:18, 159:9,
236:22, 237:9, 237:10, held [23] - 8:19, 10:25, 11:10, 118:2, 118:9, 118:13, 161:22
237:19, 239:5, 239:23, 44:5, 77:2, 104:4, 122:6, 118:16, 118:20, 118:25, identify [4] - 63:5, 83:25,
240:3, 240:16, 241:12, 125:12, 134:9, 136:7, 119:20, 120:3, 120:8, 99:7
245:18, 245:24, 250:12, 136:8, 171:18, 176:13, 120:14, 122:17, 125:7, identity [8] - 96:19, 96:22,
250:14, 250:24, 260:13, 180:21, 180:22, 181:3, 126:10, 126:19, 127:11, 97:1, 97:4, 98:5, 98:7,
260:20 181:18, 213:18, 225:20, 134:13, 135:17, 135:22, 101:3, 259:17
guess [4] - 51:1, 106:7, 231:18, 231:19, 240:7, 141:12, 142:20, 144:2, II [3] - 249:11, 253:25, 254:23
110:14, 255:23 263:1 144:11, 144:12, 144:13, III [3] - 87:11, 87:24, 89:2
guest [1] - 10:8 help [3] - 143:14, 156:17, 144:16, 144:17, 145:1, illegal [1] - 91:6
Guests [1] - 25:7 227:4 147:6, 147:8, 148:5, illustrations [1] - 145:8
guidance [20] - 143:23, helped [1] - 14:14 148:22, 149:1, 150:6, imagination [2] - 192:8,
143:25, 144:1, 144:23, helpful [1] - 66:19 150:10, 150:14, 152:12, 192:16
145:10, 159:4, 159:5, Herrald [1] - 228:6 154:15, 155:4, 157:7, imagine [4] - 139:9, 145:7,
159:24, 164:23, 165:2, heterosexual [2] - 63:6, 93:1 157:16, 160:24, 161:14, 238:2, 244:13
166:10, 175:5, 180:12, heterosexuals [5] - 63:17, 162:9, 163:24, 164:9, Imam [3] - 233:6, 233:8,
186:5, 191:7, 193:13, 63:18, 83:25, 90:13, 90:14 164:16, 164:24, 165:12, 234:10
196:1, 199:6, 246:23, Hi [1] - 247:22 165:19, 166:13, 167:12, IMAM [1] - 233:7
256:13 highlighted [6] - 19:16, 167:20, 168:4, 168:5, immediate [2] - 13:11,
guide [1] - 159:14 19:17, 27:21, 27:23, 27:24, 168:19, 169:21, 171:24, 204:13
Guidelines [2] - 129:17, 29:1 172:9, 172:13, 172:24, immediately [3] - 140:7,
131:2 174:21, 175:2, 175:18, 140:10, 183:14
hire [2] - 11:18, 139:9
guidelines [1] - 35:6 176:1, 176:2, 178:2, 178:5, immigrants [1] - 167:18
historical [5] - 25:24, 108:20,
Guild [3] - 253:15, 254:18, 178:12, 190:1, 190:4, immigration [2] - 150:12,
204:17, 205:9, 215:15
256:25 190:6, 190:21, 191:22, 167:12
historically [2] - 117:24,
191:23, 191:24, 192:12, immorality [4] - 89:25,
229:18
193:7, 193:9, 193:15,
H history [2] - 120:1, 124:12 111:16, 224:10, 224:14
194:11, 196:21, 197:12,
hold [5] - 33:23, 67:6, 131:6, impact [2] - 117:9, 203:7
197:23, 198:16, 199:15,
207:16, 249:1 impetus [1] - 162:11
half [3] - 57:5, 235:15, 202:1, 209:14, 209:20,
homosexual [4] - 63:5, 64:4, implicated [1] - 164:16
262:14 210:10, 213:1, 213:10,
66:2, 202:13 implications [3] - 29:15,
half-hour [1] - 262:14 215:2, 215:20, 215:24,
homosexuality [11] - 48:23, 30:6, 30:12
halfway [1] - 249:6 216:7, 217:3, 217:9, 218:9,
49:6, 93:3, 93:12, 99:7, implies [1] - 92:25
hall [1] - 60:15 218:16, 237:11, 241:14,
111:21, 112:4, 202:12, importance [2] - 26:21,
halls [1] - 138:25 242:7, 244:5, 244:12,
202:15, 203:21, 224:9 109:4
hand [5] - 56:23, 186:1, 244:24, 248:20, 249:20,
honestly [1] - 186:15 important [11] - 10:22, 12:5,
226:16, 227:16, 231:23 249:25, 250:19, 250:23,
hotel [1] - 10:8 21:13, 41:21, 42:20, 69:24,
handed [1] - 181:2 251:1, 251:12, 251:17,
hour [5] - 12:12, 58:22, 84:10, 84:13, 212:10,
hands [2] - 86:10, 182:18 252:20, 255:9, 259:6,
262:11, 262:12, 262:14 249:7, 249:13
handwriting [4] - 24:7, 24:9, 259:8
House [2] - 258:2, 258:13 impose [1] - 76:6
54:10, 55:2 human [7] - 89:18, 148:14,
HR [9] - 26:10, 190:13, imposed [1] - 68:18
handwritten [1] - 243:14 171:1, 171:10, 193:21,
190:17, 191:4, 191:5, impressed [1] - 81:10
Hannah [3] - 18:20, 45:6, 200:24, 201:15
191:12, 194:21, 194:25 impression [1] - 248:5
45:17 humanity [2] - 96:9, 98:22
huge [1] - 174:15 improper [1] - 176:18
happy [2] - 10:24, 12:13 hundreds [1] - 13:23
Human [181] - 22:11, 22:12, IMU [6] - 40:3, 137:24,
hard [2] - 55:10, 80:3 hurtful [1] - 200:19
26:18, 26:25, 27:13, 30:15, 137:25, 138:3, 138:4,
Hawkeye [1] - 260:12 husband [8] - 90:6, 90:11,
32:23, 38:5, 39:6, 41:16, 138:8
head [10] - 12:7, 85:23, 91:3, 91:8, 91:19, 92:15,
46:17, 47:9, 47:20, 48:20, in-depth [2] - 227:14, 227:15
102:25, 155:19, 158:17, 98:15, 101:11
49:7, 66:11, 67:14, 71:24, inaccurately [1] - 231:2
179:24, 200:5, 201:5, hypothetically [2] - 48:15,
72:3, 72:5, 72:17, 79:3, inadvertently [1] - 67:19
238:17, 238:19 49:4
82:9, 82:24, 83:17, 90:12, inappropriate [2] - 67:20,
headed [1] - 141:14 hypotheticals [1] - 150:21
91:9, 91:11, 91:17, 91:22, 111:20
heading [1] - 148:10
92:1, 92:10, 92:18, 92:23, inaudible [1] - 163:18
hear [10] - 59:13, 103:3, 94:14, 94:16, 95:9, 95:10, inaudible ) [1] - 170:16
201:1, 201:9, 201:17, 96:20, 96:23, 96:25, 97:3, incident [3] - 120:24, 121:19,

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124:7 207:13, 220:20, 224:18, 261:23, 261:24 117:7, 137:13, 141:21,

incidents [2] - 120:9, 120:21 224:23, 225:4, 225:15, Interrogatory [2] - 262:5, 142:1, 207:6, 235:21,
include [12] - 21:18, 31:17, 225:23, 226:18, 226:20, 262:6 235:25, 247:15, 252:19
78:3, 114:7, 120:13, 248:17 interrupt [1] - 10:16 involves [1] - 53:10
146:24, 155:4, 161:13, injunction [4] - 140:1, 140:2, Interrupted [1] - 151:11 involving [2] - 45:16, 119:19
163:23, 165:3, 182:15, 140:5, 200:13 InterVarsity [7] - 245:11, Iowa [48] - 8:16, 8:24, 8:25,
209:14 input [4] - 31:11, 31:13, 246:1, 246:18, 248:6, 9:2, 9:4, 9:19, 9:21, 10:1,
included [16] - 31:13, 36:18, 31:18, 252:12 255:11, 255:14, 260:12 10:4, 25:8, 25:15, 32:25,
48:6, 66:1, 86:1, 87:1, Inquiry [1] - 17:10 InterVarsity 's [1] - 246:12 36:7, 64:21, 82:23, 91:5,
87:8, 144:3, 144:18, 150:7, insert [3] - 71:23, 118:17, interview [7] - 67:18, 79:2, 93:20, 96:19, 96:23, 117:8,
150:8, 154:14, 166:13, 174:16 84:18, 102:12, 258:24, 119:25, 120:12, 122:17,
170:2, 237:12 inserted [2] - 84:7, 118:15 260:7 135:19, 137:11, 138:13,
includes [2] - 111:17, 254:20 inserting [1] - 118:20 interviewed [1] - 88:23 139:1, 141:12, 154:15,
including [15] - 72:1, 89:20, insertion [2] - 83:9, 126:18 interviewer [1] - 42:9 217:13, 228:15, 228:17,
89:25, 90:1, 90:7, 90:16, insight [1] - 149:17 interviews [2] - 39:11, 79:5 228:22, 229:1, 229:3,
96:11, 96:16, 99:20, instance [1] - 115:12 invest [1] - 134:2 229:4, 229:18, 229:19,
101:14, 114:11, 133:15, instances [3] - 36:15, 76:1, investigate [3] - 30:18, 236:20, 237:19, 249:19,
188:22, 189:25, 190:7 146:19 174:3, 174:4 253:14, 254:2, 254:17,
inclusion [4] - 26:18, 126:4, instant [1] - 25:22 investigated [3] - 22:14, 256:25, 258:16
126:8, 160:24 institute [1] - 25:22 173:21, 177:25 Iowa 's [20] - 26:18, 27:13,
inconsistent [7] - 118:9, institution [7] - 62:25, investigating [1] - 21:5 38:5, 66:11, 71:24, 83:17,
140:25, 141:4, 201:14, 127:15, 139:2, 179:3, investigation [30] - 20:13, 102:3, 116:1, 120:8,
244:6, 244:12, 245:6 206:15, 211:9, 211:14 21:6, 21:15, 22:18, 23:5, 135:20, 148:5, 169:21,
incorrect [3] - 231:7, 231:8, institutions [1] - 211:6 24:11, 25:4, 27:12, 28:13, 172:8, 178:2, 178:5, 202:1,
231:10 instructed [1] - 195:5 35:25, 36:13, 37:14, 39:9, 212:20, 217:3, 242:7,
incorrectly [1] - 50:3 instructin g [1] - 56:15 53:17, 61:13, 73:11, 74:19, 250:23
incredible [1] - 123:1 instruction [3] - 164:19, 82:3, 82:7, 107:25, 108:5, issue [12] - 33:9, 37:4, 37:13,
independent [4] - 37:6, 166:6, 212:1 108:7, 109:10, 109:11, 55:25, 62:17, 114:5,
122:21, 122:23, 147:11 174:24, 177:23, 178:4, 123:20, 123:21, 147:10,
instructions [2] - 160:23,
indicate [2] - 71:13, 72:2 193:17, 193:25, 196:16 175:8, 245:20
186:21
indicated [9] - 48:16, 72:15, investigations [4] - 22:10, issued [7] - 27:20, 28:18,
insufficient [1] - 110:2
78:1, 78:9, 93:2, 93:23, 22:11, 23:18, 82:9 66:9, 67:16, 74:20, 178:3,
integrate [2] - 218:23,
97:13, 97:16, 111:9 investigative [2] - 21:5, 200:12
219:18
indicates [2] - 106:7, 148:6 83:11 issues [11] - 20:4, 28:23,
Integrity [5] - 48:2, 48:7,
indicating [4] - 147:18, investigator [6] - 36:11, 57:25, 64:12, 109:3, 152:5,
87:1, 89:16, 101:7
224:23, 225:4, 247:18 37:4, 75:20, 75:25, 76:2, 210:20, 234:2, 234:3,
integrity [2] - 223:25, 224:6
indicating ) [2] - 128:20, 76:5 245:21, 248:18
intended [1] - 70:22
225:5 investigator 's [1] - 75:10 itself [1] - 195:17
intent [2] - 43:13, 93:12
indirect [1] - 20:6 investigators ' [1] - 65:6 IV [1] - 40:2
intention [6] - 90:5, 91:7,
individual [6] - 20:9, 146:17, invitation [1] - 244:18 IX [9] - 127:7, 127:13,
91:18, 92:14, 97:15, 98:14
174:12, 175:15, 188:2, invitation -only [1] - 244:18 127:20, 209:22, 211:2,
interaction [1] - 176:15
259:1 invitations [1] - 244:2 211:3, 211:16, 211:22,
interest [3] - 42:2, 42:7,
individually [1] - 94:20 invite [1] - 138:4 212:12
230:13
individuals [7] - 14:14, interests [1] - 258:15 invited [7] - 243:15, 243:17,
21:17, 169:5, 250:14, interim [4] - 11:15, 11:18, 244:4, 244:7, 244:10, J
259:2, 259:14, 260:1 142:24, 158:13 244:23, 245:1
inferring [1] - 43:6 interject [1] - 229:15 inviting [1] - 140:11 J.T [9] - 53:5, 53:7, 53:8,
infers [1] - 90:14 internal [2] - 148:13, 221:2 involve [4] - 22:20, 33:20, 53:9, 53:11, 53:12, 53:14,
information [25] - 13:6, 13:7, International [1] - 260:19 44:19, 207:23 53:16, 54:5
15:1, 59:25, 110:3, 149:10, international [2] - 207:17, involved [17] - 9:6, 20:13, Jacob [15] - 44:19, 46:21,
150:9, 152:12, 152:20, 207:24 21:15, 22:22, 22:24, 23:2, 49:16, 49:18, 55:13, 56:16,
152:24, 157:22, 182:12, international -based [1] - 25:12, 33:8, 37:20, 39:10, 59:9, 59:11, 62:12, 81:24,
183:21, 183:22, 183:24, 207:17 50:18, 63:10, 86:20, 100:1, 104:14, 200:3,
184:20, 184:22, 185:7, internationally [1] - 207:21 141:20, 171:6, 220:20, 200:4, 200:5
198:23, 222:3, 227:13, 236:22
interpret [4] - 171:22, 175:2, Jacob 's [3] - 45:1, 50:15,
237:25, 238:18, 238:20, involvement [5] - 25:11,
194:11, 215:2 50:22
260:23 108:4, 108:20, 136:21,
interpretation [6] - 25:24, Jake [4] - 46:8, 52:24, 54:7,
informed [4] - 195:20, 228:6, 186:17
167:10, 180:17, 195:5, 65:5
230:1, 230:3 Involvement [15] - 9:9, 9:24,
198:7, 205:5 Jake's [1] - 51:19
initial [12] - 154:22, 154:25, 10:9, 13:13, 22:8, 117:6,
Interrogatories [3] - 15:2, January [9] - 140:13, 141:1,

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141:13, 143:7, 185:14, 25:5, 25:18, 27:19, 29:7, 94:17, 95:11, 125:5, led [1] - 141:17
221:4, 221:20, 242:9, 29:8, 29:9, 108:13, 138:9, 211:11, 216:10 left [10] - 81:11, 143:3, 143:4,
242:17 138:11, 203:5 lawn [1] - 194:13 151:20, 168:8, 226:16,
Jennifer [4] - 22:2, 22:3, Kristi 's [1] - 29:21 lawsuit [5] - 13:19, 16:2, 239:5, 247:19, 258:6,
149:22, 149:23 Krogmeier [2] - 182:2, 182:4 18:5, 230:2, 246:19 259:22
job [3] - 116:25, 171:2, 171:4 Kutcher [14] - 13:10, 14:17, lawyer [2] - 20:14, 139:22 legal [4] - 95:14, 199:17,
join [10] - 146:21, 192:10, 138:6, 138:9, 140:11, lawyer 's [3] - 255:15, 257:10, 256:14, 260:3
214:20, 216:14, 216:15, 142:4, 156:20, 157:5, 260:13 Legal [9] - 9:13, 62:18,
216:19, 243:18, 244:7, 185:23, 187:25, 195:18, lawyers [1] - 260:21 113:13, 113:15, 118:23,
244:23 227:3, 235:10, 235:16 Lawyers [3] - 253:15, 118:24, 123:14, 146:11,
joined [2] - 138:18, 138:19 Kutcher 's [2] - 138:7, 237:5 254:17, 256:25 260:25
joke [1] - 236:18 lawyers ' [1] - 257:22 length [2] - 54:2, 234:2
judge [2] - 139:25, 140:24 L layer [1] - 166:9 Lesbian [1] - 258:15
judge 's [2] - 137:6, 141:3 layers [4] - 207:24, 234:3, lesbian [1] - 123:11
judgment [1] - 166:4 234:6, 234:7 less [3] - 53:25, 262:10,
L-o-r-d-e [1] - 258:5
judicial [1] - 20:4 lead [2] - 46:5, 232:25 262:13
labeled [10] - 19:14, 126:24,
July [6] - 44:3, 48:12, 49:24, leader [18] - 45:21, 46:2, letter [59] - 18:23, 18:25,
131:7, 131:9, 134:14,
52:6, 52:16, 52:17 64:13, 65:23, 70:6, 71:3, 19:6, 21:7, 21:11, 21:17,
157:2, 162:2, 164:1,
jumped [2] - 118:12, 248:10 78:21, 110:23, 111:10, 39:20, 42:20, 44:1, 44:8,
205:15, 245:4
June [30] - 156:7, 156:12, 112:14, 157:6, 169:24, 49:16, 49:18, 49:23, 50:3,
lack [1] - 159:10
158:6, 158:9, 160:18, 172:19, 174:14, 174:16, 50:22, 51:2, 51:19, 52:22,
language [67] - 19:16, 20:2,
160:21, 161:25, 162:4, 175:14, 250:18, 251:16 55:18, 72:12, 73:12, 80:5,
20:7, 72:9, 72:16, 106:17,
162:14, 162:20, 162:24, leaders [42] - 29:16, 40:6, 100:1, 100:9, 101:15,
106:25, 127:3, 135:22, 102:21, 103:4, 104:16,
163:5, 163:10, 164:19, 41:25, 42:11, 42:22, 62:24,
144:5, 144:21, 144:25,
208:23, 208:24, 209:12, 63:15, 63:24, 63:25, 64:3, 105:20, 105:25, 106:18,
155:10, 155:15, 155:18,
209:13, 221:23, 236:9, 64:18, 64:21, 65:2, 67:6, 107:1, 113:24, 114:1,
157:14, 157:15, 157:19,
236:15, 236:16, 248:7, 70:1, 70:23, 72:4, 83:23, 114:4, 114:18, 114:20,
157:20, 158:15, 158:19,
255:22 84:12, 84:18, 165:18, 115:2, 115:5, 115:7,
159:20, 159:22, 159:25, 115:14, 118:8, 118:12,
justify [1] - 94:25 169:8, 170:1, 172:11,
160:13, 161:2, 161:3,
173:3, 173:15, 173:24, 119:9, 120:18, 122:14,
161:13, 161:15, 163:12, 122:19, 123:16, 136:20,
K 163:13, 163:18, 163:21,
178:10, 179:12, 191:14,
197:24, 198:3, 199:12, 136:22, 137:2, 139:11,
163:23, 164:2, 164:4,
223:19, 246:13, 250:4, 146:11, 155:22, 156:7,
Katrina [7] - 248:3, 248:11, 164:5, 164:11, 164:13,
250:5, 250:7, 251:2, 256:7, 156:9, 156:10, 157:8,
248:13, 248:17, 249:4, 164:23, 165:2, 165:3,
256:21, 261:20 157:12
251:10, 251:24 165:18, 166:18, 167:6,
Leaders [5] - 17:13, 19:3, Letter [2] - 53:2, 53:20
keep [6] - 16:9, 16:11, 16:12, 198:20, 199:2, 209:20,
34:18, 45:2, 48:1 letter 's [1] - 44:3
58:25, 145:19, 145:20 212:11, 223:5, 242:6,
Leadership [15] - 9:9, 9:25, letters [3] - 49:21, 156:5,
keeping [2] - 96:8, 98:21 243:14, 244:11, 245:6,
10:9, 13:13, 22:9, 117:7, 158:18
Ken [2] - 199:21, 199:22 248:21, 248:25, 252:3,
117:8, 137:14, 141:22, letting [2] - 109:3, 234:22
kept [1] - 10:3 252:8, 252:16, 252:17,
142:2, 207:6, 235:21, level [7] - 26:4, 26:5, 51:14,
kick [1] - 226:6 253:8, 254:10, 256:3,
235:25, 247:15, 252:19 121:5, 151:2, 151:3,
kicked [1] - 245:13 256:18, 259:5, 259:7
leadership [45] - 26:4, 38:6, 235:17
kind [19] - 23:4, 30:6, 36:4, large [1] - 147:24
38:14, 38:19, 45:19, 46:24, Levin [2] - 80:22, 80:23
36:22, 37:1, 52:25, 112:6, larger [1] - 10:14
47:2, 47:7, 47:15, 48:17, LGBTQ [1] - 99:3
124:20, 127:6, 137:14, last [22] - 28:16, 32:19,
49:6, 65:14, 65:19, 67:18, liaison [2] - 39:15, 39:17
164:4, 198:20, 201:10, 41:15, 55:5, 75:24, 88:1,
70:8, 79:8, 79:15, 110:10, Life [14] - 8:22, 8:23, 9:7, 9:8,
206:5, 207:17, 207:21, 114:21, 126:15, 126:16,
121:13, 154:12, 164:7, 9:11, 10:14, 11:5, 11:6,
214:23, 216:3, 238:7 130:15, 146:14, 177:22,
165:4, 169:4, 174:17, 50:9, 125:19, 151:19,
kinds [4] - 77:18, 84:11, 194:19, 200:21, 206:14,
190:8, 190:14, 191:11, 209:11, 209:16, 239:7
201:2, 201:18 224:5, 228:16, 228:25,
191:21, 192:24, 193:4, life [2] - 111:22, 111:23
King [3] - 247:11, 247:13, 242:9, 242:17, 247:8
194:22, 197:6, 197:20, lifelong [5] - 90:6, 91:20,
247:14 late [6] - 141:13, 185:14,
204:22, 205:10, 223:21, 92:16, 98:16, 101:11
knowing [3] - 41:9, 51:22, 221:3, 221:4, 221:20
247:23, 249:2, 249:7, limit [1] - 169:4
255:18 latter [2] - 179:15, 227:3
249:12, 249:16, 249:22, line [10] - 51:20, 79:7, 85:2,
knowledge [7] - 14:17, Laurynn [5] - 247:11, 247:13,
251:11, 252:2, 252:20 89:16, 89:22, 180:2,
23:15, 25:22, 120:1, 247:14, 247:22, 247:25
learned [2] - 30:22, 31:5 200:12, 200:22, 206:4,
147:11, 149:20, 246:9 Law [3] - 123:11, 123:12,
least [2] - 29:6, 97:22 233:10
Kristi [17] - 14:17, 24:1, 254:3
leave [2] - 96:5, 206:13 lingo [1] - 138:1
24:22, 24:24, 25:1, 25:2, law [14] - 91:4, 93:9, 93:16,
leaving [2] - 151:15, 206:15 list [14] - 52:11, 83:22,
93:18, 93:20, 94:1, 94:9,

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115:21, 155:6, 227:24, 151:20, 151:24, 204:12, marriage [27] - 62:21, 62:25, meetings [1] - 59:8
237:13, 237:21, 239:13, 206:12, 206:17 63:2, 63:16, 63:20, 63:21, Melissa [13] - 11:6, 11:13,
240:3, 240:5, 246:2, 254:9, Lyn's [4] - 51:21, 53:24, 63:22, 64:1, 66:3, 67:2, 11:15, 11:19, 182:1,
260:22, 260:24 74:5, 137:3 69:10, 69:21, 70:25, 78:3, 204:12, 227:18, 228:12,
listed [6] - 15:5, 72:3, Lyubov [1] - 247:17 78:7, 78:8, 90:6, 91:4, 230:20, 230:24, 236:12
146:15, 164:9, 170:18, LYUBOV [1] - 247:17 91:5, 91:20, 92:16, 93:4, member [9] - 21:1, 70:6,
263:4 98:16, 101:12, 111:19, 111:5, 170:19, 200:7,
litigation [6] - 15:21, 125:25, M 124:16, 169:14 204:6, 204:7, 245:1, 249:1
128:5, 187:14, 189:15, married [2] - 176:10, 176:19 Members [1] - 245:5
232:21 mass [4] - 233:14, 233:15, members [22] - 70:1, 143:22,
live [4] - 46:4, 46:14, 47:8, magnitude [1] - 188:25 234:4, 234:20 149:25, 168:17, 176:6,
89:1 Mahdi [3] - 233:7, 233:8, massive [1] - 123:1 176:19, 179:20, 187:10,
lives [1] - 89:18 234:10 masturbation [1] - 111:18 191:19, 197:24, 198:5,
logic [1] - 101:21 MAHDI [1] - 233:7 materials [2] - 17:19, 43:15 199:11, 200:17, 202:14,
logical [1] - 196:9 mailed [1] - 27:18 matter [5] - 15:24, 51:3, 203:14, 205:8, 223:13,
longstanding [1] - 25:24 mails [1] - 247:19 139:8, 216:4, 252:12 230:14, 245:7, 245:8,
look [64] - 12:14, 14:2, 14:21, main [1] - 86:15 McHale [3] - 209:8, 209:10, 245:22, 253:1
18:12, 23:22, 31:21, 32:12, maintain [6] - 9:23, 10:11, 235:16 membership [21] - 26:5,
34:6, 38:23, 43:18, 49:12, 19:19, 19:24, 62:19, 259:1 mean [21] - 10:20, 15:19, 70:9, 86:4, 87:20, 164:7,
52:2, 54:22, 56:20, 56:22, maintained [1] - 9:16 20:7, 25:10, 37:16, 73:5, 165:4, 176:10, 190:8,
81:20, 83:5, 86:16, 87:9, maintenance [1] - 194:13 101:24, 116:10, 122:21, 190:14, 191:10, 191:21,
88:15, 89:14, 97:12, 99:22, major [5] - 9:13, 85:20, 132:6, 137:9, 142:11, 194:22, 197:20, 204:22,
104:9, 107:2, 107:19, 85:25, 86:12, 86:13 146:23, 170:9, 172:2, 205:10, 214:16, 244:20,
110:13, 111:3, 121:20, majority [3] - 60:15, 143:17, 179:1, 191:23, 224:19, 252:21, 254:24, 258:23,
121:23, 122:22, 125:10, 188:12 228:19, 234:15, 245:4 260:6
128:4, 129:1, 132:22, male [2] - 90:14, 139:3 meaning [3] - 92:25, 179:25, Membership [3] - 253:25,
135:7, 144:23, 146:9, man [10] - 63:21, 66:3, 67:3, 204:11 254:1, 258:20
158:20, 162:4, 164:1, 78:8, 93:13, 169:14, means [10] - 46:5, 54:19, memo [3] - 33:13, 34:11,
174:24, 177:2, 183:8, 214:20, 216:13, 216:19, 54:21, 103:16, 159:20, 194:16
184:8, 185:4, 190:25, 216:21 170:6, 241:20, 244:13, Memorial [16] - 8:25, 9:1,
199:20, 205:15, 205:25, manage [3] - 54:12, 183:2, 257:1, 257:11 9:2, 9:4, 9:19, 9:21, 10:2,
216:20, 220:3, 220:24, 211:2 meant [7] - 27:23, 69:2, 10:4, 25:8, 25:15, 32:25,
223:1, 223:4, 224:1, managed [2] - 184:20, 159:22, 164:23, 165:2, 117:8, 137:11, 137:12,
227:15, 228:4, 231:14, 186:16 188:4, 203:10 137:23, 138:13
232:15, 236:5, 236:25, management [3] - 35:5, media [3] - 36:18, 238:12 men [4] - 176:15, 214:5,
253:10 153:6, 261:17 Media [1] - 238:13 214:16, 214:18
looked [6] - 19:5, 83:3, manages [1] - 54:13 meet [10] - 25:17, 40:3, Men's [2] - 243:11, 244:9
100:5, 216:17, 216:18, mandatory [1] - 261:4 40:19, 57:19, 67:23, 136:5, men's [6] - 26:21, 27:3,
221:11 Manual [2] - 135:19, 135:20 178:10, 179:13, 179:16, 214:9, 218:13, 218:22
looking [19] - 15:3, 27:9, March [2] - 155:25, 156:2 245:18 mentioned [3] - 12:4, 59:1,
28:22, 29:5, 83:1, 85:22, Marcus [17] - 17:12, 46:21, meeting [77] - 24:10, 24:14, 222:5
86:16, 105:20, 115:20, 48:15, 48:22, 57:2, 57:3, 24:22, 26:15, 30:25, 33:20, merit [2] - 74:4, 74:12
144:20, 155:14, 158:23, 57:8, 57:11, 57:14, 57:15, 33:23, 34:15, 40:9, 40:12, Message [1] - 233:4
163:25, 190:20, 198:19, 57:25, 58:3, 58:7, 63:10, 40:14, 40:16, 40:17, 40:22, message [4] - 223:18,
199:6, 222:18, 239:23, 72:24, 110:6, 192:23 40:24, 41:4, 41:6, 41:7, 223:20, 233:6, 247:10
254:8 Marcus ' [1] - 57:7 41:9, 41:12, 44:5, 44:8, messages [2] - 223:23,
looks [3] - 41:2, 51:16, 171:9 Mark [4] - 228:23, 229:10, 48:5, 48:10, 52:21, 53:16, 223:24
Lorde [2] - 258:2, 258:13 229:12, 229:16 56:2, 57:3, 59:1, 59:5, Messenger [3] - 34:15, 35:9,
lost [1] - 174:22 mark [2] - 25:23, 184:11 59:6, 59:12, 59:18, 60:2, 35:20
lunch [4] - 135:6, 136:5, marked [17] - 16:12, 181:14, 60:18, 60:21, 60:23, 61:20, met [5] - 57:14, 59:10, 81:9,
136:16, 136:17 181:16, 181:20, 183:9, 61:23, 62:2, 62:8, 62:9, 108:13, 110:20
lust [1] - 111:19 184:1, 185:5, 186:1, 210:3, 62:16, 62:17, 62:23, 64:16, Met [1] - 52:10
Lyn [34] - 11:11, 14:18, 50:7, 231:23, 235:1, 241:25, 65:6, 65:7, 66:15, 68:23, metro [1] - 258:16
50:10, 51:6, 51:18, 52:10, 246:25, 247:8, 248:1, 69:8, 69:17, 72:14, 72:15, Michelene [2] - 232:10,
53:23, 53:24, 54:8, 54:12, 258:1, 263:4 77:6, 77:9, 78:1, 79:19, 232:13
56:15, 57:2, 57:6, 58:13, Marking [8] - 183:10, 184:12, 79:24, 80:11, 80:21, 81:1, Michelene 's [1] - 233:4
73:14, 73:20, 74:12, 80:12, 185:5, 205:16, 227:17, 81:3, 81:4, 81:5, 81:12, middle [6] - 114:24, 144:15,
81:1, 104:13, 104:21, 231:24, 236:5, 242:1 81:25, 84:5, 108:13, 200:22, 210:2, 210:8,
106:20, 136:19, 136:22, marking [5] - 16:8, 236:25, 124:23, 138:14, 239:9, 210:13
137:2, 139:11, 151:15, 247:1, 253:11, 258:1 261:5, 261:14 might [20] - 26:5, 30:6, 30:7,

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30:12, 38:9, 39:24, 57:17, move [6] - 37:19, 70:22, 53:12, 55:14, 55:18, 163:5, 163:9
57:18, 144:25, 158:15, 122:1, 195:6, 195:8, 103:13, 104:8, 106:10, Notice [2] - 115:17, 115:18
164:11, 164:15, 164:16, 208:21 136:15, 142:5 noticed [3] - 34:8, 115:21,
176:11, 176:18, 186:24, moving [6] - 41:2, 67:15, never [14] - 18:5, 57:13, 261:23
189:3, 191:2, 215:14, 70:15, 70:16, 194:11, 57:14, 75:7, 165:23, notification [3] - 21:12,
255:19 247:21 179:21, 195:24, 196:1, 241:17, 241:20
military [5] - 177:10, 179:9, multi [1] - 9:14 202:25, 203:6, 203:12, notified [2] - 21:13, 109:7
179:10, 179:21, 179:22 Multiethnic [1] - 260:12 217:16 notifying [1] - 19:1
Military [8] - 149:9, 177:7, multiple [2] - 185:20, 230:18 new [13] - 25:10, 53:24, 87:2, notion [7] - 54:6, 65:13, 69:4,
177:11, 177:13, 178:11, mumbled [2] - 107:12, 98:24, 128:17, 142:8, 69:5, 92:12, 207:21, 212:6
178:12, 178:19, 179:13 107:13 149:8, 154:13, 154:14, nuance [2] - 234:14, 234:23
Miller [15] - 17:12, 46:21, mumbling [1] - 107:14 194:7, 205:11, 247:23, nuances [1] - 23:6
47:6, 48:15, 48:23, 49:4, Muslim [5] - 250:17, 250:24, 261:20 Number [27] - 12:15, 14:3,
57:2, 57:8, 57:11, 58:1, 251:2, 251:15, 251:16 newspaper [1] - 237:17 16:4, 18:9, 19:15, 23:22,
58:7, 65:19, 72:24, 110:6, must [13] - 88:23, 88:25, next [29] - 28:16, 42:1, 45:25, 29:5, 81:21, 104:9, 107:3,
192:23 89:3, 102:12, 161:15, 50:20, 51:20, 56:16, 83:10, 107:19, 121:20, 121:24,
Miller 's [1] - 63:10 182:14, 189:25, 243:15, 88:1, 89:22, 90:4, 96:6, 122:2, 129:1, 129:5, 130:1,
mind [3] - 30:11, 56:3, 123:4 244:3, 244:10, 245:8, 96:14, 106:9, 106:12, 131:7, 131:8, 146:13,
mine [1] - 77:16 249:19, 252:19 107:8, 111:4, 121:24, 147:13, 186:2, 189:7,
minor [4] - 79:21, 85:24, Myers [1] - 182:7 137:5, 189:6, 189:21, 220:4, 226:4, 237:1,
86:12, 86:13 200:21, 207:2, 235:15, 253:11
Mintner [6] - 13:11, 14:18, 235:19, 247:8, 247:16,
N number [14] - 15:1, 99:2,
141:18, 185:25, 186:8, 247:21, 252:14 112:11, 116:8, 148:21,
186:17 nice [1] - 135:11 154:25, 155:2, 225:1,
Mintner 's [1] - 142:23 name [10] - 8:13, 9:10, 44:21, nine [5] - 12:21, 137:4, 235:20, 237:22, 237:23,
minute [11] - 86:17, 95:14, 75:24, 110:5, 220:1, 238:15, 238:22, 262:19 240:18, 253:17, 260:11
101:13, 114:17, 178:21, 228:16, 228:25, 233:4 nine -day [1] - 137:4 numbered [4] - 15:6, 49:12,
180:20, 218:24, 247:1, named [7] - 9:2, 9:18, 10:12, NLG [1] - 254:1 171:13, 243:8
251:4, 254:13, 259:21 11:6, 44:21, 228:25, 229:2 nobody [1] - 204:9 Numbers [1] - 226:1
minutes [1] - 12:12 names [2] - 62:11, 71:12 nominee [1] - 89:3 numbers [4] - 19:10, 24:20,
misogyny /homophobia [1] - Nate [3] - 80:22, 80:23, 80:25 nominees [1] - 88:22 135:1, 224:20
217:25 nation [1] - 217:22 Nominees [1] - 88:25
National [3] - 253:14,
Miss [1] - 19:1 non [3] - 63:18, 83:25, 90:14 O
missed [2] - 241:5, 241:6 254:17, 256:25 non-heterosexuals [3] -
missing [2] - 18:15, 222:6 national [2] - 207:20, 208:6 63:18, 83:25, 90:14
natural [1] - 153:24 o-r-g-apostrophe -s [1] -
mission [7] - 64:18, 64:22, NonAcadStudorg [1] -
nature [5] - 63:13, 64:15, 223:9
123:9, 167:23, 178:10, 233:11
77:12, 81:19, 122:14 Nondiscrimination [2] - oath [1] - 103:13
194:20, 252:18
Mission [1] - 258:11 NCAA [4] - 212:23, 212:25, 135:14, 135:17 object [3] - 95:13, 116:13,
213:4, 213:5 nondiscrimination [4] - 178:22
missions [1] - 26:24
nebulous [1] - 232:20 148:18, 211:19, 213:11, obligation [6] - 34:1, 34:5,
misstatement [2] - 69:14,
necessarily [3] - 33:24, 218:4 89:17, 103:16, 128:2,
178:22
51:25, 69:23 none [2] - 25:23, 99:19 128:3
misunderstanding [2] -
need [27] - 12:11, 12:12, Obtainment [1] - 191:10
203:2, 203:4 nonimmigrants [1] - 167:3
20:11, 30:17, 39:18, 63:1, obtainment [1] - 194:22
mixing [1] - 218:25 normal [6] - 35:23, 36:11,
106:8, 112:23, 116:9, 108:18, 108:25, 115:8, obviously [3] - 219:7,
model [3] - 131:5, 223:19,
132:18, 146:5, 149:3, 230:5 236:22, 251:25
223:23
155:3, 182:20, 207:23, notation [1] - 243:20 occasion [1] - 143:20
Model [1] - 26:9
209:13, 212:10, 234:18, note [7] - 26:16, 50:17, 54:7, occasions [2] - 75:1, 75:2
Modestou [3] - 22:2, 22:3,
241:22, 243:5, 248:14, 54:8, 55:5, 80:9, 209:3 occur [1] - 41:5
149:24
252:1, 252:12, 256:15, notebook [1] - 222:24 occurred [8] - 40:12, 44:23,
modified [2] - 41:17, 209:14
261:10, 261:17 noted [1] - 144:6 80:13, 137:6, 154:9,
moment [2] - 35:19, 193:15
needed [7] - 56:14, 132:8, 203:12, 221:20, 221:24
moments [1] - 257:24 notes [6] - 27:10, 34:15,
141:8, 151:7, 153:23, 35:9, 35:20, 132:19, occurring [2] - 194:13,
month [5] - 59:8, 126:15,
189:5, 196:4 239:10
126:16, 184:24, 255:20 200:12
needing [1] - 57:19 October [1] - 113:22
months [2] - 130:15, 174:14 nothing [12] - 8:7, 32:9,
needs [2] - 62:25, 234:14 37:19, 79:20, 97:7, 103:17, offer [2] - 38:20, 49:2
morning [3] - 8:11, 8:12,
Neighbors [1] - 260:19 135:9, 150:10, 150:14, offered [1] - 38:14
262:8
NELSON [1] - 8:5 168:3, 168:19, 199:8 Office [46] - 9:8, 18:21,
most [1] - 26:3
Nelson [10] - 8:14, 28:5, notice [4] - 76:16, 162:19, 20:12, 21:1, 22:14, 37:8,
mostly [1] - 188:16

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39:16, 39:17, 80:24, 244:10, 245:12, 245:18, 142:14, 153:5, 157:6, outreaches [1] - 59:9
117:23, 139:15, 142:12, 245:24, 254:6, 260:2, 175:12, 183:5, 183:7, outside [17] - 25:14, 62:21,
143:4, 149:23, 152:21, 260:12, 260:20, 261:8, 184:21, 189:8, 200:14, 62:24, 63:1, 63:16, 63:20,
152:22, 167:9, 180:13, 261:9, 261:22 200:17, 207:25, 208:6, 63:21, 63:22, 64:1, 66:3,
180:17, 188:3, 194:10, one's [2] - 17:4, 133:3 216:24, 243:18, 244:9, 67:2, 70:24, 78:8, 96:7,
195:9, 195:15, 195:21, ones [4] - 120:17, 161:22, 244:19, 249:8, 250:5, 98:20, 111:19, 194:13
196:4, 198:25, 206:19, 240:9, 260:2 250:6, 254:6, 254:25, outsider [1] - 138:23
206:20, 208:20, 209:18, ongoing [10] - 70:16, 71:8, 256:7, 257:16, 258:14, oversight [5] - 9:11, 9:22,
211:23, 239:16, 239:19, 71:17, 71:22, 72:5, 72:17, 259:2, 261:10, 261:16 10:6, 142:2, 199:23
239:24, 241:11, 241:21, 77:19, 83:16, 128:6, 239:2 organization 's [2] - 144:19, overturn [1] - 119:15
245:25, 246:5, 246:17, open [6] - 11:11, 244:15, 250:7 own [13] - 12:1, 35:4, 61:2,
253:8, 254:11, 255:21, 254:1, 254:25, 258:24, organizations [41] - 23:6, 74:10, 89:18, 123:4, 136:1,
256:3, 257:5, 257:8, 261:3 259:13 25:13, 26:24, 40:7, 69:24, 165:11, 195:22, 197:12,
office [19] - 21:22, 23:16, opening [2] - 194:18, 194:19 84:12, 117:5, 117:10, 213:6, 213:15, 257:14
37:11, 60:14, 82:10, 151:3, openly [1] - 110:22 125:19, 125:22, 130:2,
182:23, 206:13, 206:14, operate [2] - 180:6, 211:10 131:4, 135:23, 137:8, P
206:16, 220:24, 235:23, operating [1] - 120:6 153:3, 163:4, 172:4, 175:9,
236:2, 255:16, 256:14, operation [4] - 10:6, 10:10, 182:12, 182:14, 183:3,
257:11, 257:22, 260:3, 184:21, 185:10, 203:8, p.m [7] - 136:8, 136:9,
10:15, 136:1
260:13 204:3, 207:8, 210:9, 180:22, 180:23, 231:19,
Operations [2] - 135:19,
Officer [1] - 88:25 211:10, 212:16, 213:25, 231:20, 263:3
135:20
officer [1] - 21:20 214:10, 220:19, 227:22, P000270 [1] - 131:7
operations [1] - 10:7
officers [3] - 84:18, 102:12, 227:25, 228:2, 233:22, P270 [1] - 131:9
opinion [3] - 77:14, 77:15,
171:3 244:22, 245:13, 248:21, page [40] - 19:10, 32:19,
212:8
official [9] - 32:16, 41:5, 250:4, 257:13 34:9, 34:19, 41:15, 45:1,
opinions [2] - 36:25, 171:17
59:24, 198:7, 199:5, Organizations [16] - 33:7, 56:14, 88:2, 110:13, 111:4,
opportunity [25] - 33:22,
212:20, 252:23, 256:10 36:6, 53:13, 116:3, 120:16, 114:24, 126:22, 126:23,
38:6, 38:14, 38:20, 40:25,
officially [1] - 239:14 129:20, 137:20, 175:4, 170:18, 171:12, 183:4,
46:12, 46:14, 65:14, 73:2,
officials [5] - 201:18, 202:7, 183:25, 189:24, 191:18, 184:1, 189:6, 189:21,
74:12, 74:22, 76:16, 76:18,
202:17, 202:18 214:12, 221:17, 227:20, 200:11, 207:2, 210:3,
102:6, 110:10, 173:10,
often [2] - 35:24, 234:20 233:16, 249:18 210:12, 224:22, 225:1,
174:2, 191:21, 192:24,
old [2] - 128:17, 128:19 organized [1] - 177:6 233:3, 235:10, 235:15,
193:2, 193:4, 205:13,
once [2] - 51:15, 241:17 orgs [2] - 235:7, 252:16 235:20, 247:8, 247:16,
216:12, 216:19, 244:14
Once [4] - 27:20, 28:23, OrgSync [9] - 129:9, 153:4, 248:1, 252:14, 256:19
Opportunity [9] - 18:21,
29:10, 189:7 210:22, 239:13, 248:11, pages [6] - 13:22, 88:21,
20:12, 21:2, 21:21, 22:15,
One [2] - 111:12, 243:15 256:24, 257:17, 258:3 242:23, 258:8, 258:19,
37:9, 39:16, 149:23,
orientation [19] - 45:16, 263:5
one [92] - 10:21, 12:21, 170:19
45:21, 46:25, 47:13, 47:17, Pam [3] - 182:2, 182:4, 182:5
13:12, 13:25, 15:1, 15:2, oppose [1] - 89:23
16:23, 18:3, 22:7, 24:16, 70:20, 71:14, 72:24, 78:14, paper [3] - 13:24, 13:25
opposed [2] - 202:12, 202:13
25:6, 26:10, 26:17, 40:6, 78:18, 78:23, 84:21, 92:25, par [1] - 174:11
opposite [1] - 111:20
40:9, 40:18, 40:21, 51:16, 94:15, 101:2, 121:18, paragraph [27] - 28:16, 40:1,
option [1] - 258:25
67:16, 69:6, 75:3, 85:16, 146:15, 259:17, 261:20 41:15, 44:10, 44:17, 45:13,
oral [6] - 32:5, 145:10,
88:14, 91:15, 97:12, 97:15, origin [2] - 150:3, 207:18 82:2, 82:21, 83:10, 87:11,
145:11, 159:4, 188:10,
112:21, 116:1, 116:9, Original [2] - 233:4, 247:10 87:14, 88:6, 89:2, 106:3,
188:17
119:21, 120:11, 123:22, original [12] - 10:2, 29:12, 110:15, 110:16, 146:14,
order [1] - 169:24
125:18, 126:5, 126:6, 45:6, 45:16, 54:24, 55:1, 163:17, 194:18, 194:19,
Org [2] - 233:7
126:24, 129:18, 129:19, 83:6, 96:8, 98:22, 128:17, 200:16, 210:2, 210:8,
org's [2] - 223:5, 223:8
130:19, 130:25, 134:12, 147:19, 233:6 210:13, 249:6, 254:13
Organization [16] - 13:10,
135:13, 136:5, 140:23, originally [1] - 237:23 parallel [1] - 53:10
25:6, 82:4, 83:13, 122:13,
141:3, 143:9, 143:20, origins [1] - 237:24 pardon [1] - 16:6
129:16, 131:1, 138:10,
146:10, 149:24, 153:2, outcome [7] - 21:14, 206:6, part [50] - 10:9, 14:20, 21:4,
141:9, 154:12, 154:20,
157:9, 161:17, 161:18, 218:11, 243:22, 244:1, 21:8, 23:5, 26:23, 39:10,
189:8, 219:12, 220:11,
162:11, 164:8, 165:5, 246:22 41:11, 50:15, 51:12, 51:21,
257:2, 261:1
171:3, 177:5, 178:9, 181:5, outdoor [1] - 138:15 54:13, 73:13, 77:23, 86:20,
organization [49] - 19:1,
183:4, 190:20, 191:2, outer [1] - 235:10 88:17, 104:15, 109:2,
22:10, 22:12, 25:20, 28:19,
209:6, 222:1, 224:5, OutLaw [1] - 123:9 112:2, 112:13, 114:7,
35:5, 40:4, 44:24, 51:8,
225:16, 226:18, 227:3, OutLaws [1] - 122:13 114:22, 117:6, 124:21,
64:8, 64:20, 64:22, 70:7,
230:17, 230:19, 232:12, outline [1] - 55:13 138:21, 144:9, 147:22,
83:12, 83:23, 113:1,
236:3, 236:4, 236:22, outlined [1] - 245:9 147:24, 149:12, 153:9,
119:22, 122:16, 140:12,
243:8, 244:3, 244:7, 154:9, 155:12, 164:6,
141:9, 142:3, 142:9, outreach [2] - 235:6, 235:12

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176:12, 177:22, 189:5, peppered [1] - 235:7 211:13, 214:6, 219:19, 172:9, 172:13, 172:24,
198:13, 205:7, 207:12, perhaps [14] - 54:25, 67:20, 227:7, 234:14, 234:17, 174:21, 175:2, 175:19,
208:10, 209:17, 212:14, 75:24, 140:13, 144:5, 237:7, 258:23, 260:22 176:3, 178:2, 178:5,
239:9, 244:4, 248:20, 149:25, 182:16, 186:17, policies [14] - 33:10, 74:14, 178:13, 190:21, 192:12,
250:13, 253:12, 257:14 188:10, 199:4, 213:3, 116:2, 130:2, 130:4, 130:7, 193:7, 193:9, 193:15,
participant [1] - 39:21 215:13, 234:18, 259:17 130:18, 132:9, 132:13, 193:16, 194:11, 196:21,
participants [1] - 166:20 period [4] - 38:18, 151:16, 134:12, 134:20, 189:25, 197:12, 197:23, 198:17,
participate [3] - 45:20, 156:3, 237:6 213:15, 261:15 199:15, 202:1, 209:15,
137:8, 140:12 periods [1] - 215:18 Policies [2] - 22:11, 129:20 209:20, 210:10, 213:2,
participated [3] - 39:9, permissible [3] - 64:1, 64:20, policies /procedures [1] - 213:10, 215:2, 215:20,
45:19, 187:18 256:18 130:16 215:24, 216:8, 217:3,
participating [1] - 78:13 permit [1] - 83:12 policy [56] - 20:1, 20:3, 217:9, 218:9, 218:16,
particular [3] - 36:20, 36:21, permitting [1] - 146:21 26:10, 27:2, 27:7, 27:9, 219:9, 237:11, 241:14,
209:19 person [22] - 11:18, 20:22, 27:11, 33:1, 37:16, 37:20, 242:7, 244:5, 244:12,
parties [3] - 168:25, 173:2, 21:22, 36:24, 39:20, 96:15, 37:23, 40:19, 41:10, 47:21, 244:24, 250:1, 250:20,
213:20 98:1, 98:23, 116:9, 146:16, 48:19, 64:17, 68:2, 70:16, 250:23, 251:2, 251:17,
partner [2] - 138:25, 139:3 150:4, 150:5, 150:24, 79:11, 110:11, 124:25, 255:9, 259:6, 259:8
parts [2] - 12:21, 14:24 150:25, 170:18, 201:19, 126:17, 127:22, 127:23, political [10] - 146:22,
party [4] - 142:15, 169:11, 225:16, 229:9, 237:7 127:24, 128:17, 128:19, 168:25, 172:2, 172:3,
174:14, 175:14 Personal [6] - 48:2, 48:7, 139:12, 142:19, 146:19, 172:6, 173:2, 174:18,
Party [4] - 169:13, 169:24, 87:1, 87:17, 89:15, 101:6 146:20, 146:24, 148:9, 174:19, 254:20, 258:14
172:6, 172:18 personal [14] - 60:24, 61:1, 148:14, 148:18, 149:13, pornea [1] - 111:16
pass [2] - 107:7 61:2, 61:5, 61:8, 61:9, 157:23, 171:1, 171:10, pornography [2] - 89:25,
passed [7] - 38:18, 152:6, 61:11, 61:14, 61:16, 79:25, 193:21, 194:8, 196:13, 111:18
152:15, 152:16, 152:21, 86:25, 101:6, 212:2, 212:5 196:15, 198:8, 204:23, portal [3] - 153:4, 210:22,
166:5, 206:8 personally [3] - 217:13, 205:2, 205:4, 205:5, 213:6, 238:7
past [2] - 132:6, 204:18 217:14, 230:10 213:11, 217:5, 218:5, portion [1] - 108:5
pattern [1] - 174:9 persons [1] - 83:25 243:25, 244:6 portray [1] - 231:2
patterns [1] - 180:4 perspective [1] - 243:19 Policy [156] - 22:12, 26:19, posed [1] - 211:1
Paul [35] - 13:11, 13:12, pertaining [2] - 36:8, 146:10 26:25, 27:14, 30:16, 32:23, position [32] - 11:10, 42:2,
14:18, 141:18, 142:23, Pesantubbee [3] - 232:10, 38:5, 41:17, 46:17, 47:9, 42:8, 43:5, 45:20, 46:24,
142:24, 143:8, 143:9, 232:13, 233:17 47:20, 48:20, 49:8, 66:11, 47:3, 47:7, 47:15, 47:18,
143:11, 151:8, 165:22, philosophical [1] - 171:18 71:24, 72:3, 72:6, 72:18, 48:18, 49:2, 49:6, 63:7,
167:7, 167:8, 185:23, philosophically [1] - 204:18 79:4, 82:10, 82:24, 83:17, 65:19, 79:15, 98:6, 105:13,
185:24, 186:8, 186:17, philosophy [5] - 25:23, 90:12, 91:10, 91:11, 91:18, 138:23, 174:18, 191:6,
187:5, 187:10, 187:24, 91:23, 92:1, 92:11, 92:19, 191:13, 204:8, 223:21,
65:20, 65:24, 66:1, 176:1
187:25, 188:3, 188:4, 92:23, 94:14, 94:16, 95:9, 231:6, 249:2, 251:22,
piece [12] - 90:11, 91:3,
188:5, 188:6, 189:4, 191:8, 95:10, 96:23, 96:25, 97:3, 252:23, 253:5, 255:13,
92:12, 92:13, 144:11,
198:22, 198:23, 227:4, 97:9, 98:5, 98:8, 99:10, 256:10, 256:16
158:19, 159:25, 160:13,
227:14, 235:16 99:13, 100:20, 101:1, positions [3] - 8:19, 101:21,
205:10, 209:19, 212:8,
101:10, 102:4, 102:18, 231:5
pause [4] - 114:19, 183:21, 259:12
106:14, 111:1, 112:7, positive [1] - 81:12
195:4, 254:15 pieces [1] - 204:17
112:16, 113:2, 114:6, possibility [1] - 176:21
Pause [19] - 15:16, 18:16, place [8] - 41:24, 42:10,
114:11, 117:11, 117:16, possible [3] - 122:16, 188:7,
24:8, 35:21, 39:5, 44:14, 52:25, 59:2, 62:8, 77:7,
118:3, 118:9, 118:13, 237:13
87:13, 87:25, 107:18, 137:10, 193:21
118:16, 118:20, 118:25, possibly [2] - 176:14, 185:17
111:2, 112:8, 115:3, 122:4, plain [1] - 163:13
119:20, 120:3, 120:8, potential [7] - 78:22, 114:6,
172:12, 206:3, 210:14, Plaintiff 's [2] - 14:7, 19:15
120:14, 122:17, 125:7, 153:25, 155:15, 218:15,
247:3, 250:2, 254:12 plan [5] - 84:17, 96:8, 98:22,
126:10, 126:19, 127:11, 220:16, 242:5
pause ) [1] - 197:14 102:11, 185:8
134:13, 135:17, 135:22, practice [10] - 25:23, 35:23,
pay [2] - 214:21, 226:7 platform [7] - 129:9, 153:6,
141:12, 142:21, 144:12, 36:11, 37:3, 39:23, 70:5,
pending [5] - 58:19, 232:21, 169:5, 169:11, 169:13,
144:13, 144:17, 145:1, 70:10, 115:8, 146:21,
245:24, 246:17, 257:12 169:18, 169:24
147:6, 147:9, 148:5, 154:4
people [21] - 52:11, 85:14, play [2] - 214:5, 214:22
148:22, 149:1, 150:6, practices [7] - 42:12, 42:23,
143:16, 149:22, 158:22, plural [1] - 160:12
150:11, 150:14, 152:13, 43:9, 63:10, 121:15,
159:11, 169:18, 169:22, plus [2] - 161:24, 198:11 154:16, 155:5, 157:16, 128:10, 148:19
172:3, 173:3, 178:11, point [24] - 27:16, 33:5, 160:25, 164:24, 165:13, precipitated [1] - 51:2
186:6, 188:2, 188:8, 66:13, 82:1, 103:1, 103:6, 165:19, 166:14, 167:13,
188:12, 192:7, 192:15, 107:8, 119:21, 119:22, pregnancy [1] - 149:9
167:21, 168:4, 168:5,
195:3, 197:7, 217:24, 140:14, 153:24, 165:22, premarked [2] - 16:15, 16:17
168:19, 169:21, 171:24,
255:4 184:23, 187:13, 207:16, premature [1] - 246:21

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preparation [3] - 14:8, 121:7, 177:2, 177:3, 234:10, 196:21 191:12, 197:20, 197:25,
184:25 243:18, 244:19, 259:25, promote [1] - 148:17 198:2
prepare [3] - 13:3, 147:21, 260:5, 260:8 promoted [1] - 8:22 purposes /mission [1] -
183:15 problematic [14] - 76:19, promptly [1] - 30:20 190:12
prepared [3] - 12:20, 183:4, 79:5, 87:24, 89:11, 90:1, pronouncing [1] - 123:23 put [9] - 37:1, 71:6, 134:7,
206:3 90:7, 90:25, 94:12, 94:13, properly [1] - 116:17 134:16, 134:24, 181:9,
preparing [2] - 24:19, 183:16 97:16, 97:20, 97:25, propose [1] - 190:20 181:10, 195:17, 207:3
preponderance [3] - 82:22, 101:16, 254:11 proposed [2] - 252:16, 253:8 putting [1] - 118:25
109:12, 110:10 problems [5] - 30:6, 142:16, proselytizing [2] - 232:25,
present [1] - 136:10 159:16, 161:23, 242:6 233:20 Q
Present [1] - 8:3 procedural [1] - 145:15 protect [4] - 74:15, 150:11,
presented [2] - 59:14, procedure [2] - 33:12, 74:15 150:15, 216:9
qualifications [3] - 67:17,
109:22 procedures [6] - 51:7, 82:8, protected [18] - 26:25, 83:24,
82:11, 116:2, 130:18, 83:22, 84:11
presenting [1] - 60:22 91:9, 92:22, 127:20, 145:1,
148:23 qualify [2] - 116:11, 117:1
President [21] - 11:6, 45:2, 149:8, 149:18, 164:8,
Procedures [1] - 82:4 quality [1] - 81:17
50:9, 88:23, 119:16, 165:5, 166:12, 166:13,
proceed [1] - 79:18 queer [3] - 259:2, 259:14,
119:17, 122:12, 151:4, 170:2, 173:11, 173:13,
proceeding [1] - 180:14 260:1
151:19, 151:24, 152:3, 174:3, 177:13, 216:10
proceedings [1] - 263:2 questioning [2] - 79:7, 180:3
152:17, 152:22, 182:5, protecting [4] - 168:1, 191:3,
PROCEEDINGS [1] - 8:1 questions [23] - 41:1, 58:10,
184:17, 207:4, 227:19, 204:20, 254:21
59:15, 63:9, 67:20, 79:10,
228:5, 230:6, 230:8 process [39] - 11:16, 33:17, protection [1] - 95:22
84:18, 95:15, 95:20, 96:4,
president [9] - 42:3, 42:8, 33:18, 34:3, 36:12, 39:22, protections [1] - 91:16
102:13, 104:19, 111:12,
44:22, 44:24, 45:5, 45:6, 41:2, 41:11, 50:11, 51:7, protesting [2] - 123:13,
112:7, 117:19, 117:25,
49:1, 49:2, 207:22 51:12, 51:13, 51:23, 51:24, 124:12
145:8, 151:12, 165:20,
President 's [4] - 88:24, 53:23, 54:14, 54:25, 56:17, protocol [3] - 39:21, 39:24,
165:23, 166:16, 188:14,
151:2, 182:23, 206:19 60:9, 60:20, 75:7, 75:8, 79:7
241:10
presumably [1] - 153:20 141:1, 149:1, 149:2, protocols [1] - 67:18
quickly [4] - 39:3, 51:24,
presuming [1] - 78:23 151:15, 151:16, 152:1, provide [21] - 14:15, 23:7,
51:25, 115:16
presumptive [2] - 84:20, 187:19, 188:23, 203:25, 32:5, 40:25, 102:15, 128:2,
206:5, 207:5, 223:14, quite [3] - 180:16, 231:1,
102:14 128:3, 128:5, 131:3,
223:17, 233:15, 260:7 237:25
pretty [2] - 165:11, 165:16 131:17, 133:24, 133:25,
produce [6] - 15:24, 132:15, quotations [1] - 83:9
prevent [2] - 67:15, 83:23 183:19, 184:20, 188:18,
133:15, 134:14, 187:13, quote [2] - 140:24, 243:15
previous [5] - 12:24, 56:14, 223:19, 238:20, 239:20,
187:19 quote /unquote [2] - 211:16,
57:7, 147:4, 162:13 240:5, 246:23, 261:14
produced [14] - 15:20, 16:2, 243:21
previously [6] - 11:10, 17:14, provided [16] - 10:5, 13:15,
58:1, 58:3, 60:11, 80:7, quotes [1] - 36:19
59:1, 88:3, 97:17, 236:9 13:16, 15:1, 35:7, 83:3,
primarily [2] - 11:8, 37:5 80:15, 127:24, 128:13, 83:14, 112:1, 128:2, 145:8,
primary [2] - 142:13, 154:12 128:22, 188:9, 205:18, 155:9, 159:24, 183:17, R
principles [10] - 46:4, 46:15, 209:4, 222:7 184:16, 185:8, 187:5
47:4, 47:8, 47:16, 47:19, production [7] - 54:25, provides [1] - 111:13 race [2] - 259:12, 259:16
48:17, 171:17, 200:24, 57:23, 163:6, 183:13, providing [3] - 9:10, 105:24, racism [1] - 89:23
201:15 189:14, 189:19, 253:13 228:1 raise [1] - 165:24
print [1] - 125:24 Production [2] - 14:7, 19:15 provision [7] - 65:3, 89:12, raised [1] - 62:17
printed [4] - 125:24, 126:20, professional [5] - 61:15, 96:12, 113:1, 124:8, 167:3, rather [4] - 46:13, 47:2,
128:21, 185:12 61:16, 139:1, 212:6 259:19 92:13, 262:1
privileges [1] - 182:13 professor [5] - 232:4, 232:6, provisions [4] - 100:23, re [3] - 53:2, 53:20, 118:11
privy [1] - 230:18 232:7, 232:9, 232:13 103:10, 103:21, 248:23 re-ask [1] - 118:11
pro [2] - 175:14, 175:15 Professor [1] - 233:17 pulled [2] - 143:13, 143:16 reach [1] - 230:19
pro-Bernie [1] - 175:14 program [2] - 9:15, 117:14 Purpose [3] - 254:14, reached [6] - 58:16, 58:17,
pro-Trump [1] - 175:15 Program [2] - 166:20, 166:22 254:17, 255:1 138:4, 155:3, 260:15,
probable [3] - 37:13, 37:16, programatic [1] - 137:14 purpose [24] - 11:22, 18:25, 260:16
112:18 programs [5] - 9:12, 9:14, 21:10, 32:21, 32:22, 40:9, read [40] - 12:24, 19:10,
probably [10] - 14:1, 51:10, 10:1, 189:24, 249:19 40:16, 40:21, 59:4, 59:6, 19:16, 20:7, 30:1, 30:19,
93:20, 108:20, 143:18, Programs [1] - 209:11 67:20, 100:2, 100:9, 33:14, 43:11, 44:10, 44:14,
185:13, 187:9, 188:16, prohibit [4] - 91:11, 97:3, 125:20, 156:9, 176:14, 78:16, 85:21, 86:10, 87:11,
262:13, 262:14 191:13, 194:8 184:18, 197:6, 214:21, 87:23, 99:19, 109:16,
problem [20] - 76:4, 79:16, prohibiting [1] - 191:1 216:7, 252:18, 254:3, 109:17, 109:18, 114:16,
89:19, 96:11, 96:16, 99:19, prohibition [1] - 172:15 259:1, 261:13 114:17, 114:20, 115:2,
101:14, 153:14, 153:16, prohibits [6] - 97:1, 190:21, purposes [9] - 40:21, 175:6, 115:4, 115:8, 118:11,
153:17, 153:18, 153:25, 191:4, 193:9, 193:22, 179:13, 179:16, 191:5, 119:8, 120:18, 129:12,

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147:21, 161:5, 161:7, recess [5] - 77:2, 104:4, reference [7] - 39:22, 39:24, regroup [1] - 256:15
163:16, 191:16, 191:17, 136:8, 180:22, 231:19 54:6, 98:6, 98:9, 235:11, regularly [1] - 230:1
210:16, 223:11, 224:7, recheck [1] - 60:12 236:14 regulations [3] - 25:20,
254:13, 254:16 recipient [1] - 36:5 referenced [17] - 9:17, 38:11, 130:7, 261:15
reading [4] - 56:13, 118:15, recipients [1] - 185:21 40:23, 81:1, 108:12, reinstate [1] - 140:8
251:9, 255:14 recognition [4] - 28:19, 141:17, 141:18, 145:18, reinstated [3] - 140:14,
reads [3] - 41:19, 96:10, 120:13, 210:23, 210:24 180:14, 185:9, 188:14, 200:13, 238:15
212:7 recognize [40] - 12:16, 14:3, 209:15, 220:5, 232:4, reject [5] - 96:15, 98:2,
real [1] - 216:7 17:7, 18:17, 23:23, 24:5, 232:7, 232:11, 236:23 98:24, 250:7, 250:17
realized [3] - 153:2, 153:16, 28:1, 32:12, 38:25, 43:21, references [3] - 42:17, 47:24, rejected [1] - 72:23
153:23 49:13, 52:3, 54:23, 56:24, 125:19 rejects [3] - 250:5, 250:6,
really [10] - 51:3, 69:24, 81:21, 85:6, 99:23, 104:9, referencing [4] - 40:12, 251:16
74:21, 101:20, 101:24, 107:21, 113:9, 125:15, 102:11, 157:6, 214:6 related [46] - 13:5, 15:1,
112:23, 204:23, 226:7, 129:5, 129:8, 147:17, referred [9] - 26:1, 26:6, 22:10, 22:23, 23:6, 28:8,
232:19, 251:8 157:2, 170:14, 170:21, 40:14, 120:17, 129:25, 29:25, 36:5, 53:13, 53:14,
ream [2] - 13:24, 13:25 170:22, 181:24, 183:11, 137:16, 160:8, 160:20, 54:6, 57:6, 59:13, 77:19,
Reams [1] - 11:7 184:13, 186:2, 205:16, 186:24 82:18, 92:22, 101:2, 120:6,
reams [1] - 13:25 220:4, 232:1, 237:1, 242:1, referring [14] - 20:2, 23:10, 120:11, 120:25, 122:15,
reason [19] - 24:17, 43:5, 249:12, 249:16, 253:11 51:3, 67:1, 77:20, 77:22, 126:11, 126:18, 127:1,
48:18, 49:7, 50:2, 58:15, recognized [2] - 171:19, 87:15, 88:3, 98:13, 157:8, 127:3, 128:9, 129:9, 132:9,
71:6, 110:9, 127:22, 201:25 182:20, 225:11, 232:9, 135:23, 153:23, 164:6,
127:24, 174:18, 187:23, recollection [11] - 26:14, 256:6 183:4, 190:12, 194:20,
208:14, 211:17, 211:22, 27:8, 35:8, 35:19, 38:8, refers [7] - 27:22, 28:24, 209:16, 224:10, 224:14,
212:2, 213:23, 218:3, 42:14, 55:1, 89:9, 119:24, 40:15, 53:19, 55:4, 84:4, 228:2, 231:12, 234:2,
221:24 122:23, 232:15 233:13 235:8, 236:16, 249:1,
reasonably [1] - 30:20 recommendation [3] - 28:17, reflect [1] - 125:1 249:22, 251:11
reasons [3] - 67:16, 215:15, 29:2, 148:14 reflected [1] - 37:7 relates [6] - 90:12, 94:14,
215:23 recommended [2] - 27:21, refresh [1] - 232:15 200:1, 211:6, 255:22,
recalling [4] - 29:24, 32:2, 27:24 refused [2] - 47:7, 47:18 262:16
200:4, 228:14 reconsider [1] - 139:12 regard [3] - 42:11, 42:22, relation [1] - 183:1
receipt [1] - 105:2 record [38] - 8:13, 10:25, 136:21 relations [1] - 111:20
receive [11] - 35:25, 37:14, 69:15, 73:5, 73:6, 73:16, regarded [2] - 19:20, 19:25 relationship [10] - 39:12,
37:22, 74:24, 120:15, 77:4, 98:19, 104:6, 106:4, regarding [5] - 27:2, 113:12, 63:11, 90:5, 91:7, 91:19,
134:11, 134:12, 158:9, 106:9, 107:8, 122:6, 116:2, 126:3, 160:24 92:15, 94:14, 96:7, 98:15,
180:18, 210:23, 211:24 125:12, 134:8, 134:9, Regardless [1] - 210:9 98:20
received [52] - 9:17, 13:5, 136:7, 136:12, 155:20, regardless [2] - 45:21, 213:5 relationships [6] - 62:21,
17:19, 17:25, 19:4, 21:7, 160:14, 168:3, 168:17, regent [2] - 230:19, 230:22 63:1, 63:16, 63:20, 64:4,
29:23, 30:10, 30:16, 49:22, 178:22, 180:20, 180:21, regent 's [1] - 230:24 78:7
49:23, 52:22, 68:8, 68:13, 180:24, 181:3, 181:18, Regents [3] - 229:17, relevant [8] - 13:18, 16:2,
68:19, 75:7, 75:12, 75:17, 209:4, 213:18, 225:20, 229:20, 230:1 36:17, 36:25, 80:15, 84:11,
76:15, 85:14, 100:14, 231:18, 231:21, 259:21, register [1] - 27:4 84:19, 102:13
105:5, 105:13, 107:1, 259:23, 262:23, 262:24, registered [17] - 62:19, religion [12] - 91:15, 146:17,
108:8, 109:17, 115:7, 263:1 72:11, 112:15, 121:11, 146:20, 146:24, 147:9,
137:3, 139:15, 156:1, record 's [1] - 19:9 169:8, 183:7, 214:15, 149:8, 170:7, 170:8,
162:19, 162:22, 163:3, Recreati onal [2] - 53:9, 218:14, 219:6, 219:7, 171:19, 250:9, 256:8
163:4, 164:18, 164:19, 219:21 220:20, 240:19, 241:1, religious [51] - 63:19, 63:24,
173:20, 173:25, 186:22, Redington [24] - 11:11, 246:9, 246:10, 257:8 64:3, 65:20, 65:23, 66:1,
186:25, 187:7, 191:7, 11:17, 14:18, 43:25, 49:21, Registered [26] - 33:7, 36:6, 66:23, 67:6, 67:10, 69:9,
191:8, 195:8, 195:14, 50:8, 50:18, 51:6, 51:19, 53:13, 82:4, 83:13, 116:2, 69:20, 89:1, 91:12, 124:14,
216:20, 218:19, 241:19, 54:9, 57:3, 57:4, 65:17, 120:15, 129:16, 131:1, 125:4, 146:17, 171:16,
246:2, 252:15, 253:7, 73:15, 74:13, 104:21, 137:19, 141:9, 154:11, 202:4, 202:10, 202:12,
256:2 105:9, 136:19, 137:2, 154:19, 175:4, 183:25, 203:2, 203:8, 203:14,
receiving [8] - 21:10, 31:5, 139:11, 151:15, 151:20, 189:23, 191:18, 214:12, 203:16, 204:2, 212:12,
31:10, 31:12, 31:24, 32:22, 204:12, 206:12 219:11, 220:10, 221:17, 212:16, 220:21, 220:22,
33:13, 102:21 Redington 's [1] - 104:13 227:20, 233:16, 249:18, 221:11, 227:21, 227:25,
recent [7] - 26:3, 126:1, redlined [3] - 132:12, 133:15, 257:1, 261:1 228:2, 231:11, 231:12,
132:4, 132:5, 132:6, 134:21 registration [8] - 117:5, 231:13, 246:12, 249:23,
132:13 redoing [1] - 165:10 122:16, 125:21, 126:6, 250:4, 250:5, 250:6, 250:8,
recently [4] - 9:2, 10:12, refer [5] - 24:24, 29:2, 88:1, 126:7, 126:20, 130:24, 250:12, 250:13, 250:14,
133:4, 165:22 137:22, 202:8 210:24 250:15, 251:12, 252:25,

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253:1, 256:7 258:4, 262:22, 263:4 reregistered [1] - 156:15 193:3, 240:22
Religious [1] - 91:14 reporting [6] - 11:15, 142:4, reroute [1] - 154:7 resulted [1] - 109:11
rely [1] - 37:3 142:5, 151:17, 152:2, Res [1] - 38:12 retain [2] - 123:2, 127:16
relying [1] - 199:17 206:4 reservation [1] - 25:14 retained [1] - 10:2
remain [1] - 72:10 reports [3] - 13:7, 21:21, reserved [1] - 260:1 retaliate [1] - 20:5
remained [1] - 87:2 236:3 residence [1] - 138:25 retaliation [2] - 19:25, 20:3
remaining [4] - 152:15, represent [2] - 15:17, 52:17 resolution [13] - 21:16, 33:1, retirement [1] - 206:15
154:23, 155:2, 155:23 representative [4] - 33:21, 33:8, 33:16, 33:18, 50:17, retracted [3] - 38:19, 49:2,
remains [1] - 45:20 59:22, 261:8, 261:9 50:18, 51:24, 52:1, 53:13, 65:14
remarks [1] - 83:12 representatives [4] - 33:21, 53:14, 54:4, 54:13 return [1] - 84:23
remember [54] - 24:17, 40:5, 154:13, 207:25 resolve [3] - 72:10, 72:16, returned [2] - 136:15, 170:24
25:25, 26:5, 30:1, 31:1, reproduced [1] - 222:8 159:16 reverse [1] - 125:1
31:3, 36:19, 41:20, 53:15, Republican [6] - 169:7, resolved [2] - 58:19, 121:3 review [101] - 13:14, 14:8,
54:8, 56:6, 60:13, 62:11, 169:10, 169:13, 169:23, respect [4] - 37:12, 39:13, 34:22, 39:3, 66:7, 73:15,
63:2, 63:3, 65:9, 65:10, 172:6, 172:18 117:10, 255:10 73:24, 74:9, 75:9, 80:4,
72:25, 81:13, 81:15, 85:20, Republicans [2] - 169:8, respective [1] - 210:24 85:11, 85:13, 85:18,
86:3, 86:7, 86:14, 86:19, 172:14 respond [8] - 57:7, 57:8, 105:21, 106:3, 106:9,
87:7, 105:17, 105:24, Request [1] - 14:7 100:11, 116:21, 141:7, 109:14, 121:6, 121:7,
109:23, 113:23, 114:3, request [9] - 14:12, 57:7, 155:25, 162:16, 214:25 139:12, 141:8, 141:12,
114:9, 114:14, 115:11, 68:12, 100:12, 134:11, responded [5] - 29:14, 141:15, 141:16, 141:22,
118:19, 118:22, 119:3, 184:19, 207:4, 222:8, 31:25, 59:10, 103:4, 143:14, 144:1, 144:9,
119:6, 120:9, 120:23, 238:24 156:11 148:14, 150:25, 151:14,
121:3, 121:10, 121:22, requested [27] - 19:21, 42:4, respondent [2] - 20:5, 152:7, 152:9, 153:12,
122:18, 124:21, 138:16, 68:12, 91:13, 96:21, 112:22 154:22, 154:24, 155:13,
183:3, 185:22, 224:20, 105:13, 113:14, 131:10, Respondent [7] - 38:13, 170:23, 170:25, 183:5,
228:11, 231:3, 231:9, 137:17, 140:4, 147:23, 38:17, 42:18, 43:17, 44:19, 185:13, 185:18, 186:6,
240:25 161:7, 163:19, 170:17, 44:21 186:9, 187:19, 188:12,
remembering [1] - 240:24 190:3, 194:12, 210:5, responds [2] - 247:22, 189:2, 196:7, 198:10,
remind [4] - 59:4, 141:23, 213:19, 223:7, 225:16, 249:15 198:14, 205:21, 206:5,
142:23, 232:9 232:5, 238:5, 238:9, 252:9, Response [2] - 14:6, 15:7 206:7, 206:25, 207:5,
reminder [1] - 162:17 253:21, 256:21, 258:4 response [19] - 14:12, 14:15, 207:7, 207:10, 207:13,
removal [1] - 162:10 requests [4] - 14:15, 127:25, 14:19, 30:2, 30:3, 31:23, 220:9, 220:22, 221:2,
remove [2] - 158:15, 166:18 133:21, 239:1 57:22, 61:7, 97:21, 101:19, 221:5, 221:20, 224:18,
removed [1] - 161:15 Requests [1] - 15:6 104:14, 105:15, 118:10, 224:24, 225:4, 225:5,
removing [2] - 157:19, 161:2 require [19] - 41:17, 50:11, 119:2, 122:20, 127:25, 225:6, 225:15, 225:23,
renewed [1] - 241:20 62:24, 63:15, 64:17, 64:21, 192:5, 232:20, 234:24 225:24, 226:19, 226:20,
reorganization [1] - 10:13 68:4, 70:23, 71:6, 169:8, Responses [2] - 262:6 226:21, 226:25, 228:7,
repeat [6] - 15:14, 42:24, 169:10, 176:5, 179:12, responses [4] - 12:6, 15:18, 235:7, 239:6, 239:16,
46:19, 112:8, 168:7, 202:5 179:16, 195:2, 197:24, 32:6, 156:1 239:18, 239:23, 240:23,
rephrase [1] - 116:22 218:22, 219:25, 251:2 responsibile [1] - 22:17 241:8, 241:11, 242:9,
replaced [1] - 138:9 required [10] - 26:10, 65:2, responsibilities [14] - 9:6, 242:12, 242:14, 243:21,
replacement [1] - 11:17 67:9, 69:20, 71:9, 72:12, 9:16, 9:18, 9:20, 9:24, 243:22, 246:22, 247:4,
replacing [2] - 11:3, 11:4 78:19, 144:8, 182:15, 10:3, 10:12, 10:15, 21:3, 248:17, 254:7, 254:11,
report [8] - 11:13, 11:18, 216:15 116:11, 116:15, 116:25, 255:15, 257:12, 260:13
37:22, 51:2, 83:11, 151:9, requirement [16] - 63:4, 117:4, 171:5 reviewed [25] - 12:18, 13:22,
151:10, 151:20 63:19, 63:24, 63:25, 64:3, Responsibility [1] - 87:18 34:15, 34:21, 34:24, 35:9,
reported [9] - 9:14, 9:15, 64:24, 68:7, 70:11, 84:16, responsibility [5] - 21:4, 35:20, 36:12, 76:22,
116:14, 166:18, 211:19, 22:9, 22:19, 33:4, 117:15 109:15, 152:10, 155:10,
21:21, 42:3, 42:8, 43:1,
243:17, 244:3, 244:9, 156:20, 156:21, 195:24,
143:11, 151:13, 151:24 responsible [8] - 9:8, 9:25,
245:7 198:17, 208:8, 221:7,
REPORTER [3] - 124:4, 20:22, 32:25, 135:19,
Requirements [1] - 164:7 221:18, 227:20, 242:15,
136:13, 161:11 150:24, 150:25, 198:21
requirements [8] - 26:9, 242:17, 242:25, 257:19
reporter [30] - 12:6, 16:10, rest [3] - 28:11, 163:6, 252:1
26:17, 62:20, 68:18, reviewer [2] - 243:20, 245:6
19:21, 42:4, 91:13, 96:21, restate [1] - 102:20
100:17, 165:4, 246:12, reviewers [7] - 158:23,
113:14, 131:10, 137:17, restorative [1] - 77:18
249:17 165:24, 167:4, 186:22,
140:4, 147:23, 161:7, restriction [2] - 249:22,
requires [1] - 40:19 188:22, 196:2, 227:14
163:19, 170:17, 181:5, 251:11
181:6, 181:15, 190:3, requiring [2] - 203:13, reviewing [12] - 35:24, 36:10,
restructuring [1] - 11:5
194:12, 210:5, 213:19, 219:16 66:7, 75:3, 76:6, 122:24,
resubmission [1] - 240:10
223:7, 225:16, 232:5, reread [1] - 42:6 133:5, 140:15, 186:22,
resubmitted [1] - 240:10
238:5, 238:9, 253:21, reregister [2] - 241:9, 257:14 188:8, 198:13, 198:19
result [4] - 109:10, 174:23,

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reviews [2] - 152:1, 225:9 259:6, 259:8 scenarios [1] - 177:4 seem [1] - 180:15
revised [7] - 100:14, 105:5, rights [7] - 148:14, 171:1, schedule [4] - 40:3, 40:17, segregated [1] - 212:21
105:7, 132:3, 147:9, 171:10, 200:24, 201:15, 57:3, 59:8 select [2] - 244:14, 250:5
153:19, 156:12 202:11, 250:19 scheduled [1] - 261:4 selected [1] - 257:13
revisions [3] - 102:6, 102:9, Robbins [1] - 200:7 scheduling [2] - 33:20, selecting [4] - 164:14,
148:4 Rocklin [3] - 27:19, 28:4, 138:14 165:18, 191:14, 250:4
Rights [180] - 22:11, 22:12, 122:12 school [2] - 199:25, 200:1 Selection [1] - 258:23
26:18, 26:25, 27:14, 30:15, role [24] - 22:16, 23:1, 25:2, Schriver [1] - 107:24 selection [5] - 190:8, 199:11,
32:23, 38:5, 39:6, 41:16, 25:3, 25:8, 25:10, 39:8, scratch [1] - 259:6 223:14, 223:17, 260:6
46:17, 47:9, 47:20, 48:20, 39:15, 39:17, 51:22, 53:10, screen [2] - 129:6, 129:8 self [4] - 42:3, 42:8, 43:1,
49:7, 66:11, 67:14, 71:24, 53:24, 57:19, 60:20, 69:15, script [3] - 159:11, 159:15, 220:11
72:3, 72:6, 72:17, 79:4, 119:22, 138:7, 138:24, 160:8 self-explanatory [1] - 220:11
82:9, 82:24, 83:17, 90:12, 139:1, 142:6, 142:8, scripts [1] - 160:11 self-reported [3] - 42:3, 42:8,
91:10, 91:11, 91:17, 91:22, 142:23 search [1] - 57:22 43:1
92:1, 92:10, 92:18, 92:23, roles [2] - 8:19, 67:18 searched [1] - 57:21 selfishness [1] - 89:24
94:14, 94:16, 95:9, 95:10, room [7] - 168:8, 188:11, searching [2] - 11:16, 15:24 semester [1] - 261:19
96:23, 96:25, 97:3, 97:9, 188:13, 194:14, 228:12, second [35] - 19:16, 19:17, send [3] - 50:12, 188:20,
98:5, 98:8, 99:10, 99:13, 258:6, 259:22 28:10, 34:19, 40:1, 41:16, 234:1
100:20, 101:1, 101:9, rooms [1] - 138:15 43:7, 44:10, 45:1, 45:13, sender [1] - 233:15
102:4, 102:18, 106:14, rooted [1] - 111:16 82:2, 82:21, 82:22, 97:19, sending [2] - 50:16, 55:18
111:1, 112:7, 112:16, roughly [2] - 200:2, 241:1 98:19, 110:13, 110:19, sense [4] - 130:13, 212:15,
113:2, 114:6, 114:11, RSO [4] - 161:6, 161:12, 114:24, 126:23, 129:18, 212:18, 216:4
117:11, 117:16, 118:3, 163:22, 190:7 129:19, 130:25, 133:12, sent [23] - 17:23, 18:20,
118:9, 118:13, 118:16, RSOs [3] - 189:24, 190:11, 143:10, 146:13, 200:11, 30:20, 35:1, 39:20, 49:18,
118:20, 118:25, 119:20, 194:20 200:16, 227:8, 227:14, 49:21, 50:10, 54:7, 103:22,
120:3, 120:8, 120:14, rule [1] - 116:14 235:14, 249:6, 256:19, 128:8, 136:19, 136:22,
122:17, 125:7, 126:10, ruled [2] - 41:10, 217:2 258:22 154:11, 155:24, 160:21,
126:19, 127:11, 134:13, rules [8] - 12:5, 25:20, 34:1, secondly [1] - 211:1 162:13, 167:8, 220:25,
135:17, 135:22, 141:12, 34:2, 34:5, 40:7, 40:18, secretary [2] - 59:7, 59:9 233:14, 237:5, 247:17
142:21, 144:2, 144:3, 233:25 section [14] - 15:7, 86:1, sentence [25] - 40:2, 41:16,
144:11, 144:12, 144:13, ruling [1] - 140:1 87:2, 87:7, 87:19, 88:10, 42:1, 43:7, 45:18, 82:2,
144:16, 144:17, 145:1,
88:11, 114:21, 126:7, 82:22, 96:6, 96:14, 97:16,
147:6, 147:8, 148:5,
148:22, 149:1, 150:6,
S 126:21, 126:25, 257:13 97:19, 97:24, 98:13, 98:19,
Section [4] - 40:2, 86:4, 98:22, 106:9, 106:12,
150:10, 150:14, 152:13,
87:24, 254:23 110:19, 146:14, 148:15,
154:16, 155:4, 157:7, S-A-B-A-C [1] - 124:3
sections [7] - 101:2, 101:4, 190:20, 194:19, 238:10
157:16, 160:24, 161:14, SABAC [4] - 123:24, 123:25,
125:18, 126:5, 129:25, sentences [6] - 41:23, 97:14,
162:9, 163:24, 164:9, 124:3, 124:7
130:4, 133:6 101:9, 102:16, 102:22,
164:16, 164:24, 165:12, SABACK [1] - 123:22
see [64] - 15:6, 19:15, 24:21, 103:5
165:19, 166:13, 167:13, Sager [1] - 23:13
26:8, 27:18, 28:20, 29:17, sentiment [1] - 201:10
167:21, 168:4, 168:5, sample [1] - 160:10 40:1, 45:1, 53:20, 54:15, sentiments [1] - 201:3
168:19, 169:21, 171:24, samples [1] - 160:16 54:16, 102:5, 106:2, separate [1] - 82:14
172:9, 172:13, 172:24, san [1] - 68:19 107:18, 110:17, 111:4, September [20] - 40:13,
174:21, 175:2, 175:18, sanction [6] - 41:14, 50:23, 111:8, 111:22, 111:23, 40:15, 44:6, 48:5, 48:9,
176:1, 176:2, 178:2, 178:5, 67:17, 72:12, 76:6, 216:24 111:24, 112:9, 129:11, 56:2, 59:2, 59:10, 59:19,
178:12, 190:1, 190:4, sanctioned [1] - 30:13 129:23, 144:1, 144:5, 60:18, 62:3, 62:8, 69:8,
190:6, 190:21, 191:22, sanctions [33] - 33:2, 33:9, 144:17, 146:13, 148:10, 77:7, 77:23, 81:25, 100:12,
191:23, 191:24, 192:12, 33:10, 34:23, 37:2, 37:4, 148:15, 148:16, 160:10, 239:8, 239:9
193:7, 193:9, 193:15, 41:3, 41:5, 41:8, 41:11, 164:2, 166:16, 171:13, sequence [1] - 18:11
194:11, 196:21, 197:12, 53:2, 53:19, 53:20, 54:5, 174:25, 183:14, 186:18, series [2] - 150:20, 166:16
197:23, 198:16, 199:15, 54:9, 54:13, 54:16, 54:18, 189:6, 189:23, 200:19, served [6] - 53:24, 177:7,
202:1, 209:15, 209:20, 54:19, 55:13, 55:21, 55:25, 200:21, 207:5, 207:8, 177:9, 178:11, 179:13,
210:10, 213:1, 213:10, 56:4, 66:9, 74:9, 74:10, 210:3, 214:24, 222:13, 179:21
215:2, 215:20, 215:24, 77:13, 77:19, 77:23, 222:16, 224:4, 233:3, server [1] - 229:23
216:7, 217:3, 217:9, 218:9, 136:20, 178:3 235:19, 237:17, 247:7, service [4] - 149:9, 177:11,
218:16, 219:9, 237:11, Sanders [2] - 169:2, 174:12 247:16, 248:8, 248:17, 177:13, 179:9
241:14, 242:7, 244:5, Sanders ' [1] - 169:5 252:3, 253:19, 253:25, Services [6] - 9:13, 25:7,
244:12, 244:24, 248:20, satisfy [1] - 100:17 254:5, 258:10, 258:17, 53:9, 138:14, 199:24,
249:20, 249:25, 250:20,
saw [3] - 18:4, 18:6, 51:1 258:18 219:21
250:23, 251:1, 251:12,
Sayer [1] - 23:12 seek [2] - 88:25, 89:17 services [2] - 10:1, 10:8
251:17, 252:20, 255:9,

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session [1] - 80:18 short [3] - 54:1, 54:3, 58:23 solely [2] - 9:25, 72:24 speculate [1] - 26:13
sessions [1] - 261:18 shortly [2] - 139:9, 221:14 someone [25] - 17:22, 20:8, speculating [1] - 183:22
set [6] - 89:1, 160:18, 178:9, shot [2] - 129:6, 129:8 56:14, 56:15, 71:3, 107:13, speculation [1] - 56:13
198:14, 208:19, 227:2 show [11] - 157:1, 160:2, 138:3, 150:11, 150:15, speech [5] - 93:7, 93:10,
setting [4] - 79:2, 81:8, 160:9, 160:17, 162:2, 166:19, 167:15, 173:10, 93:15, 93:25
145:4, 188:16 163:9, 235:1, 241:25, 177:17, 188:20, 190:24, spelled [1] - 233:7
settled [1] - 56:4 246:25, 257:25, 260:10 191:20, 191:25, 228:24, spelling [1] - 258:4
seven [4] - 241:2, 246:10, showed [1] - 160:15 229:2, 230:16, 241:19, spent [1] - 56:8
257:8 shows [1] - 174:13 243:14, 243:17, 244:11 spirit [4] - 89:22, 215:19,
seventeen [1] - 246:8 Shriver [1] - 18:22 sometimes [1] - 202:4 215:24, 216:1
Several [2] - 184:4, 224:11 sic [7] - 23:12, 26:9, 88:24, somewhat [2] - 53:23, 205:6 spiritual [1] - 223:19
several [10] - 18:2, 59:9, 103:3, 155:25, 164:15, somewhere [1] - 66:16 spoken [1] - 57:14
100:23, 130:15, 149:7, 193:21 soon [1] - 156:15 sports [17] - 53:11, 53:14,
207:23, 224:9, 234:6, side [1] - 138:12 sororities [29] - 126:3, 212:19, 212:22, 213:11,
247:18, 248:18 sign [9] - 65:2, 78:16, 78:21, 126:12, 127:1, 127:4, 213:25, 214:1, 214:6,
sex [20] - 71:14, 91:4, 91:5, 79:13, 89:3, 169:22, 127:12, 127:16, 127:18, 214:8, 218:5, 218:6, 218:7,
96:16, 98:3, 98:24, 101:12, 169:25, 170:1, 191:20 130:21, 176:9, 207:12, 218:22, 219:2, 219:17,
111:19, 111:20, 127:9, signature [3] - 45:2, 88:11, 207:19, 208:19, 209:21, 219:20
127:16, 127:19, 211:10, 88:16 209:24, 210:11, 210:19, sports -centered [1] - 214:1
211:18, 212:21, 213:12, signed [2] - 79:13, 185:1 210:23, 211:7, 211:10, spouse [1] - 150:18
214:9, 218:4, 219:17, significant [2] - 42:15, 211:15, 211:18, 212:7, spreadsheet [11] - 189:12,
219:23 261:17 213:24, 217:22, 235:8, 220:5, 220:7, 220:18,
sex-based [1] - 219:17 similar [7] - 29:22, 77:16, 235:13, 239:12, 242:17, 221:8, 222:1, 222:4, 222:6,
sexual [45] - 42:11, 42:23, 198:1, 222:13, 222:17, 257:18 222:13, 222:18, 224:17
43:8, 45:15, 46:25, 47:13, 232:19 sorority [3] - 176:5, 207:22, Staff [1] - 207:7
47:17, 62:20, 63:1, 63:11, simple [3] - 50:14, 50:15, 210:21 staff [29] - 13:6, 21:1, 23:13,
63:16, 63:20, 63:25, 64:4, 177:5 Sorority [3] - 209:11, 209:16, 117:13, 117:15, 132:14,
66:2, 67:2, 70:19, 70:24, simply [10] - 31:8, 32:4, 239:7 141:19, 141:21, 143:13,
71:14, 72:24, 78:7, 78:14, 35:22, 48:22, 49:5, 50:16, sorority 's [1] - 176:14 143:22, 153:7, 153:11,
78:18, 78:23, 84:20, 89:24, 57:18, 58:12, 58:19, 109:6 sorry [28] - 10:16, 64:10, 153:12, 153:21, 154:7,
90:5, 91:7, 91:19, 92:15, Sincerely [1] - 235:20 69:6, 80:2, 96:9, 98:11, 170:19, 180:15, 187:5,
92:25, 94:15, 96:6, 98:14, sinful [1] - 66:3 100:3, 107:17, 114:10, 187:10, 187:18, 194:5,
98:20, 101:2, 111:16, single [8] - 127:9, 127:16, 118:21, 131:8, 132:1, 200:7, 202:14, 205:8,
121:18, 146:15, 168:2, 154:19, 176:6, 211:10, 133:22, 144:15, 152:9, 234:21, 240:11, 241:8,
168:14, 203:22, 224:10, 214:9, 218:6, 219:23 158:17, 163:20, 172:17, 254:2, 255:1
224:14, 259:17 sins [2] - 111:17, 111:22 196:20, 202:13, 210:15, stage [7] - 33:1, 33:8, 50:18,
sexuality [4] - 69:10, 69:21, situation [13] - 30:23, 31:6, 225:18, 225:25, 254:12, 50:19, 52:1
93:13, 124:17 63:8, 108:16, 119:19, 256:15, 259:6, 262:25 stake [3] - 212:4, 212:5,
shake [1] - 12:7 134:2, 174:24, 175:1, Sorry [1] - 100:4 212:6
shall [2] - 151:17, 223:20 196:10, 205:12, 216:16, sound [3] - 114:9, 146:24, stamps [1] - 19:11
share [13] - 41:2, 59:21, 216:18, 232:19 148:12 Stand [1] - 169:2
60:13, 92:5, 163:2, 172:3, situations [2] - 29:22 sounded [1] - 153:18 standard [1] - 70:23
173:3, 173:15, 173:24, sixth [1] - 184:24 sounds [1] - 211:21 Standards [2] - 129:17,
191:14, 197:23, 197:24, skimmed [1] - 114:21 space [7] - 25:14, 138:15, 131:2
198:1 skimming [1] - 114:23 166:8, 259:2, 259:12, standards [2] - 67:23, 72:4
shared [8] - 43:14, 105:10, skipping [2] - 106:12, 258:19 259:25 Stander [1] - 169:2
183:22, 189:11, 197:20, slow [6] - 10:17, 86:9, 126:9, speaking [1] - 13:2 standing [3] - 83:13, 84:24,
206:19, 211:5, 236:16 161:9, 213:21, 225:18 specific [13] - 24:18, 68:12, 215:17
sharing [3] - 9:21, 50:9, slowly [4] - 19:22, 42:5, 68:17, 120:9, 159:17, stands [1] - 124:5
59:24 161:8, 213:20 164:23, 174:8, 190:12, start [10] - 31:12, 41:25,
sheet [3] - 185:1, 242:12, Soccer [3] - 243:11, 244:9 194:21, 227:24, 232:23, 114:23, 125:25, 139:12,
242:14 social [7] - 36:17, 126:11, 248:23 181:1, 182:18, 219:16,
shift [2] - 152:2, 204:21 127:3, 127:15, 176:15, specifically [16] - 13:8, 19:1, 247:6, 250:6
Shivers [15] - 11:6, 11:14, 207:19, 210:10 39:18, 58:16, 65:11, 67:1, started [5] - 140:15, 151:14,
151:17, 151:18, 151:21, society [1] - 89:19 136:21, 142:14, 146:15, 154:24, 166:19, 167:15
151:23, 151:25, 152:3, 146:18, 171:7, 182:15, starting [5] - 45:18, 152:2,
Society [9] - 62:18, 113:13,
152:17, 182:2, 184:17, 191:8, 221:6, 221:11, 154:25, 208:22, 262:19
113:15, 118:23, 118:24,
184:23, 204:13, 206:18, 231:9 starts [2] - 97:15, 98:19
123:14, 146:11, 208:5,
227:19 261:1 specifics [4] - 23:19, 112:23, state [9] - 8:13, 46:11, 84:23,
Shivers ' [1] - 182:5 174:6, 235:8 93:3, 93:18, 100:16,
sole [1] - 214:20

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 24

160:15, 196:14, 216:10 15:24, 58:19, 71:3, 104:1, 250:24, 252:16, 257:13, subscribe [6] - 195:3, 245:8,
State [8] - 91:4, 228:15, 111:5, 138:13, 142:6, 261:16, 261:20 245:23, 249:11, 256:21,
228:17, 228:22, 229:1, 169:17, 190:11, 215:23, Student [64] - 8:22, 8:23, 9:7, 256:22
229:3, 229:4, 229:19 239:2, 239:17, 239:23, 9:8, 9:9, 9:13, 9:24, 10:9, subscribe ' [3] - 252:8, 252:9,
State 's [1] - 229:18 241:13, 241:21, 246:16, 10:14, 11:5, 11:6, 11:8, 252:10
Statement [16] - 48:1, 78:22, 254:7, 255:13, 255:15, 13:10, 13:13, 22:8, 25:5, subscription [2] - 190:15,
86:21, 86:25, 88:4, 89:3, 257:4, 261:1 33:7, 34:16, 34:17, 36:6, 194:24
89:15, 100:19, 102:13, stood [1] - 87:6 50:9, 53:13, 82:4, 83:13, subsequent [10] - 43:15,
106:13, 135:14, 135:17, stop [6] - 96:4, 140:22, 116:2, 117:6, 117:7, 221:21, 225:5, 225:6,
173:25, 254:14, 254:17, 173:19, 180:20, 216:3, 120:15, 124:6, 125:19, 225:24, 226:19, 226:21,
255:1 225:25 129:16, 129:20, 131:1, 226:25, 235:12, 242:10
statement [47] - 27:10, 47:6, store [1] - 10:7 137:13, 137:19, 138:9, substance [7] - 60:17, 61:22,
48:4, 48:6, 48:8, 48:12, Strategic [2] - 238:2, 238:7 141:9, 141:21, 142:1, 65:16, 79:20, 86:14,
65:3, 73:4, 73:6, 78:6, strategic [1] - 183:23 151:19, 154:12, 154:20, 104:22, 108:22
79:13, 84:19, 86:24, 88:4, strongly [5] - 171:18, 173:9, 175:4, 183:25, 189:8, substantial [2] - 126:4,
88:16, 90:1, 90:4, 90:16, 176:13, 252:10, 256:22 189:23, 191:18, 199:24, 130:15
90:25, 94:7, 94:11, 94:12, strongly -held [1] - 176:13 207:6, 214:12, 219:12, substantive [1] - 105:6
96:18, 97:6, 97:8, 169:14, structured [1] - 79:6 220:11, 221:17, 227:20, sue [1] - 23:13
169:19, 169:20, 169:22, struggling [1] - 110:21 233:16, 235:21, 235:24, sufficiency [1] - 229:23
169:25, 171:15, 171:21, student [143] - 9:12, 22:10, 236:20, 247:15, 249:18, sufficient [1] - 105:14
194:16, 195:12, 196:17, 22:12, 23:6, 25:11, 25:13, 252:19, 257:1, 258:20, suggest [2] - 43:7, 163:4
197:5, 197:11, 197:13, 25:20, 26:22, 26:24, 29:16, 261:1 suggested [1] - 78:19
197:19, 198:11, 224:9, 33:21, 35:5, 36:3, 38:16, student 's [3] - 42:11, 42:22, suggesting [1] - 121:14
234:22, 249:25, 254:3, 40:4, 40:6, 40:7, 41:24, 110:5 suggests [2] - 95:21, 244:8
254:20, 260:5 42:2, 42:7, 42:10, 42:21, students [57] - 39:11, 40:20, suit [2] - 13:5, 192:22
Statements [4] - 29:16, 44:24, 45:18, 46:2, 50:11, 40:25, 41:13, 56:8, 57:20, summari ze [1] - 243:13
170:1, 173:8, 191:19 50:12, 51:8, 63:15, 64:11, 59:7, 59:15, 62:10, 69:6,
summary [1] - 83:8
statements [8] - 94:25, 64:20, 65:13, 67:10, 68:11, 76:8, 76:21, 78:6, 78:16,
summer [1] - 148:10
99:18, 172:5, 190:12, 69:24, 74:16, 75:15, 78:21, 79:12, 81:7, 81:9, 81:17,
supervisees [2] - 203:4,
194:20, 198:15, 230:12, 79:12, 84:12, 84:13, 89:20, 91:18, 91:23, 92:1, 92:4,
204:13
254:20 90:1, 90:8, 93:16, 96:12, 92:5, 92:7, 93:6, 93:10,
supervisor [6] - 13:12,
States [1] - 177:7 96:17, 98:7, 99:20, 112:14, 93:11, 93:23, 94:19, 94:25,
21:24, 22:1, 108:18, 109:3,
states [3] - 164:13, 248:5, 112:15, 112:21, 113:1, 99:3, 112:21, 123:12,
142:25
256:6 117:5, 117:10, 119:22, 124:22, 130:8, 136:23,
supervisor /supervisee [1] -
stating [6] - 45:14, 56:19, 120:12, 121:1, 121:4, 137:6, 140:11, 153:6,
108:19
69:19, 100:10, 202:14 121:11, 121:13, 122:13, 157:15, 161:19, 161:20,
supervisors [2] - 203:3,
status [36] - 62:19, 78:14, 122:15, 123:22, 124:22, 166:19, 168:11, 169:1,
204:13
92:12, 92:20, 92:21, 92:22, 124:23, 125:19, 125:21, 169:7, 176:17, 192:6,
supervisory [1] - 236:1
92:24, 121:11, 121:12, 130:2, 130:5, 131:3, 196:24, 203:15, 234:4,
supplement [2] - 15:8, 15:19
127:9, 127:17, 149:8, 135:23, 137:8, 138:5, 234:5, 237:14, 250:7,
supplemental [1] - 128:7
150:12, 150:15, 167:12, 140:12, 140:15, 141:8, 254:1, 254:25, 258:15
Supplemental [1] - 14:6
177:14, 190:21, 190:25, 142:3, 142:9, 142:13, Students [8] - 9:3, 10:13,
supplementary [1] - 35:7
192:1, 192:2, 192:17, 142:14, 144:18, 146:21, 10:15, 11:2, 39:15, 50:8,
142:12, 143:5 support [11] - 99:3, 168:11,
192:21, 193:4, 193:10, 151:1, 152:10, 153:3,
students ' [1] - 99:6 169:10, 169:18, 169:23,
193:22, 195:1, 196:22, 153:5, 153:19, 154:19,
177:6, 192:15, 202:14,
197:15, 197:17, 199:8, 157:6, 158:1, 159:2, style [1] - 109:2
203:14, 203:15, 259:3
204:20, 214:15, 215:5, 162:19, 162:22, 162:23, subject [6] - 61:12, 63:3,
supported [1] - 169:5
216:4, 230:1, 240:17 163:4, 172:4, 174:1, 175:9, 112:4, 219:8, 233:10,
supporter [1] - 174:15
status -based [9] - 190:21, 175:12, 175:21, 175:22, 239:18
submission [3] - 86:20, supporting [1] - 169:1
192:17, 192:21, 193:10, 182:12, 182:13, 183:2,
241:5, 241:6 supports [1] - 174:12
193:22, 196:22, 199:8, 183:5, 183:7, 184:21,
submissions [1] - 158:21 suppress [4] - 93:10, 93:15,
215:5, 216:4 185:10, 192:6, 197:2,
199:24, 200:1, 200:13, submit [9] - 73:4, 73:12, 93:25, 94:7
staying [2] - 262:20, 262:21
207:8, 213:24, 214:10, 74:12, 83:22, 117:11, surprise [1] - 110:1
stem [2] - 101:24, 102:2
219:17, 220:18, 220:21, 117:13, 154:13, 156:12, surprised [1] - 109:20
step [5] - 24:2, 50:20, 56:16,
228:2, 233:8, 233:22, 188:2 surrounding [3] - 182:12,
196:8, 196:10
235:7, 237:19, 239:12, Submit [1] - 84:17 183:23
Stevenson [2] - 170:20,
241:12, 241:16, 242:13, submitted [8] - 48:4, 48:7, Susan [1] - 23:12
171:2
243:18, 244:4, 244:9, 85:11, 88:14, 184:6, 185:1, suspended [2] - 28:19, 29:3
sticker [1] - 183:9
244:18, 244:22, 250:12, 237:15, 248:7 suspicion [1] - 106:6
still [23] - 11:11, 15:19,
sweating [1] - 107:16

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 25

switch [1] - 16:22 thinking [5] - 54:11, 69:4, 77:7, 107:9, 113:2 14:1, 41:23, 48:3, 52:18,
sworn [1] - 8:6 69:5, 160:3, 217:16 tool [1] - 232:25 52:22, 53:25, 62:10, 83:22,
system [8] - 154:3, 171:16, thinks [1] - 43:11 top [14] - 24:21, 57:5, 85:2, 101:21, 114:24, 126:15,
176:13, 180:7, 180:9, third [7] - 84:16, 97:24, 85:22, 148:7, 148:15, 126:16, 129:14, 143:9,
180:11, 234:4, 261:17 98:22, 143:10, 146:14, 155:18, 189:21, 200:4, 156:3, 156:4, 156:5, 183:4,
210:13, 223:11 234:13, 236:11, 238:17, 204:6, 204:7, 218:25,
T Thompson [4] - 18:21, 19:2, 238:19, 256:19 222:15, 222:17, 224:16,
45:6, 45:17 topic [6] - 116:5, 116:8, 225:9, 258:19, 260:10,
thorough [1] - 69:25 116:12, 118:6, 176:2, 261:18
Tab [18] - 12:15, 14:3, 16:18, 261:22 two-page [1] - 183:4
thoughts [2] - 30:5, 30:11
18:9, 18:10, 19:5, 23:20, topics [4] - 12:20, 12:24, two-week [1] - 156:3
three [28] - 26:9, 36:7, 36:10,
23:22, 29:5, 34:8, 35:17, 115:21, 117:1 type [2] - 163:13, 165:18
36:15, 39:24, 75:1, 75:2,
43:19, 50:5, 56:20, 56:23, touch [1] - 176:2 types [3] - 142:18, 159:15,
75:6, 75:13, 75:20, 76:1,
85:2, 85:6, 181:10 215:22
77:22, 97:14, 99:18, track [2] - 145:19, 145:20
tab [1] - 258:22
102:16, 102:22, 103:4, tracked [2] - 222:3, 222:4
tabbed [1] - 245:4
tabs [3] - 16:11, 18:15,
103:9, 103:21, 111:4, traditions [1] - 215:17 U
125:18, 126:5, 129:25, trailed [1] - 138:25
181:16 130:4, 130:19, 143:8, training [2] - 171:6, 171:9
teaches [1] - 112:3 U.I [2] - 243:11, 244:8
143:9, 210:2 transform [1] - 111:23
team [21] - 138:18, 138:19, U.S [8] - 149:8, 149:9,
Tiffany [2] - 247:17, 247:22 transgender [3] - 192:6,
143:17, 149:25, 152:8, 177:11, 177:13, 178:10,
Tiffini [3] - 170:16, 170:20, 192:14
166:7, 186:6, 188:15, 178:12, 178:19, 179:13
171:2 transgenderism [2] - 192:8,
188:20, 188:24, 189:2, UI [3] - 36:9, 75:22, 81:17
timeline [1] - 167:8 192:16
206:6, 212:20, 214:3, UISG [1] - 236:20
timing [2] - 154:8, 227:5 transition [1] - 25:9
214:5, 214:9, 218:13, ultimately [2] - 150:23
timing -wise [1] - 154:8 transitioned [3] - 25:8, 188:6
219:7, 244:15, 247:23, umm [2] - 170:10, 214:19
Timmons [5] - 53:5, 53:7, trick [1] - 32:8
252:2 unclear [2] - 159:23, 159:25
53:8, 53:14, 53:16 tried [4] - 93:15, 164:10,
teams [6] - 212:19, 212:20, unconsti [1] - 91:25
tinier [1] - 224:4 196:1, 216:19
213:12, 218:5, 218:23, under [25] - 19:5, 34:1, 34:5,
Tippie [3] - 199:23, 199:25, trigger [4] - 26:12, 30:11,
219:1 50:12, 82:3, 82:7, 89:17,
200:10 153:7, 168:4
tease [1] - 190:19 91:17, 103:13, 127:20,
tired [1] - 251:5 triggered [3] - 21:8, 140:18,
technically [3] - 175:18, 148:21, 149:7, 179:2,
title [3] - 8:23, 72:2, 86:24 167:13
213:1, 213:14 193:7, 211:22, 233:4,
Title [10] - 95:21, 127:7, true [8] - 30:4, 46:16, 47:6,
template [1] - 131:4 244:24, 248:5, 253:25,
127:13, 127:20, 209:22, 50:24, 110:25, 198:3,
ten [5] - 12:21, 100:11, 254:7, 254:23, 255:10,
211:2, 211:3, 211:16, 198:5, 208:1
107:9, 143:20 255:15, 257:12, 260:13
211:22, 212:12 truly [1] - 134:19
tenure [1] - 54:2 Undergrad [1] - 260:12
titled [1] - 253:14 Trump [2] - 174:15, 175:15
term [1] - 198:25 underlined [1] - 164:5
today [10] - 10:22, 11:23, Trump 's [1] - 174:16
terms [13] - 37:20, 81:1, underlining [1] - 163:14
12:20, 27:14, 116:6, 118:6, trusting [1] - 166:4
112:20, 119:22, 128:10, underlying [1] - 76:6
119:23, 121:7, 256:24, truth [7] - 8:6, 8:7, 103:8,
136:22, 185:8, 185:17, understood [6] - 46:17,
257:16 103:17
209:19, 220:12, 237:10, 47:21, 48:19, 111:5,
together [7] - 93:24, 188:25, try [8] - 12:5, 12:9, 12:11,
244:2, 244:3 119:11, 201:20
195:17, 207:3, 214:21, 32:10, 46:4, 124:19,
terrible [1] - 236:24 unfold [1] - 33:19
228:12, 236:17 226:12, 244:14
testified [1] - 8:8 unilaterally [1] - 169:20
Tom [42] - 14:18, 27:19, 28:4, trying [12] - 44:16, 45:13,
testify [3] - 8:6, 12:1, 12:20 Union [18] - 8:25, 9:1, 9:2,
28:5, 39:5, 39:8, 39:9, 46:9, 46:11, 46:21, 47:25,
Tevin [2] - 200:6, 200:7 9:4, 9:19, 9:21, 10:2, 10:5,
39:14, 39:15, 42:14, 43:6, 159:18, 159:23, 197:7,
theirs [1] - 245:20 25:8, 25:15, 32:25, 36:9,
52:12, 59:20, 60:1, 61:3, 206:12, 211:13, 228:11
themselves [2] - 211:15, 75:23, 117:8, 137:11,
61:19, 62:10, 62:17, 62:23, tryouts [1] - 244:16
227:9 63:7, 63:12, 63:14, 64:7, 137:12, 137:23, 138:13
turn [13] - 18:8, 29:9, 85:1,
then -Dean [1] - 50:8 64:10, 64:14, 73:2, 77:10, United [1] - 177:7
88:20, 115:16, 129:21,
then -Director [1] - 9:22 79:18, 79:24, 80:21, 85:16, universal [1] - 90:13
131:14, 131:20, 170:13,
then -president [3] - 44:22, 108:19, 113:12, 117:24, universally [1] - 64:2
218:15, 230:7, 235:15,
44:24, 49:1 119:16, 146:12, 201:21, Universities [1] - 211:12
245:3
then -Vice [1] - 122:12 201:22, 201:23, 201:25 University [128] - 8:16, 8:17,
turned [2] - 81:12, 219:15
theory [1] - 255:10 Tom's [4] - 60:14, 60:24, 8:20, 8:21, 10:7, 12:2,
twenty [1] - 239:25
thereafter [1] - 221:14 77:15, 108:20 13:18, 14:11, 15:18, 15:19,
Twenty [1] - 240:2
thereof [1] - 259:3 tomorrow [2] - 262:2, 262:7 15:23, 17:21, 17:22, 17:23,
Twenty -five [1] - 240:2
they've [5] - 241:13, 241:17, took [10] - 41:24, 42:9, 49:9, 20:1, 20:3, 20:18, 25:3,
Two [1] - 10:16
246:2, 257:5, 257:11 59:2, 62:8, 63:7, 68:12, 26:18, 27:13, 28:19, 38:4,
two [31] - 11:7, 12:21, 13:25,

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48:5, 59:24, 64:8, 64:10, 248:7 101:9, 112:7, 112:15, 41:11

64:21, 66:11, 70:10, 71:23, updates [4] - 128:9, 238:24 125:7, 146:20, 165:18, wave [1] - 152:24
73:5, 82:23, 83:16, 85:17, upgraded [1] - 180:8 169:20, 172:8, 174:21, ways [1] - 175:25
93:10, 93:14, 93:25, 96:19, upload [2] - 153:3, 153:13 174:23, 191:23, 191:24, wear [1] - 226:5
96:23, 101:25, 102:3, uploaded [2] - 153:12, 154:2 217:2, 217:5, 250:22, website [3] - 82:5, 258:3
116:1, 116:6, 116:10, uploading [1] - 153:19 255:9, 259:16 Wednesday [2] - 52:11,
118:6, 118:17, 119:25, uploads [1] - 153:11 violated [12] - 32:24, 33:1, 52:18
120:7, 120:12, 122:17, urgency [1] - 51:21 33:10, 40:6, 40:18, 41:10, week [3] - 156:3, 162:12,
123:16, 124:25, 125:1, useful [1] - 70:15 46:16, 47:9, 48:19, 49:7, 237:18
127:8, 128:8, 134:14, usual [1] - 39:23 82:23, 113:2 weeks [1] - 156:4
135:18, 135:20, 136:1, violates [9] - 92:18, 98:7, welcome [3] - 10:10, 45:20,
138:23, 138:24, 139:11, 101:1, 118:13, 172:24,
140:15, 141:12, 142:7,
V 261:5
175:18, 213:1, 244:5, welcome -back [1] - 261:5
142:19, 144:2, 148:4, 251:16 whole [6] - 8:7, 54:6, 103:17,
154:15, 169:21, 171:22, vacation [1] - 237:6 violating [5] - 66:13, 94:1, 174:24, 202:11, 203:1
172:8, 175:7, 178:2, 178:5, valid [1] - 69:16 167:20, 172:15, 231:12 wide [1] - 111:17
189:24, 191:6, 194:2, value [1] - 217:22 violation [64] - 17:12, 20:1, wife [9] - 90:6, 90:11, 91:3,
196:24, 198:8, 201:2, values [1] - 176:13 22:13, 28:20, 30:15, 30:17, 91:8, 91:20, 92:16, 98:15,
201:9, 201:18, 202:1, variables [2] - 174:25, 37:17, 37:20, 38:4, 39:6, 101:11, 139:6
202:6, 202:17, 202:18, 177:25 40:10, 41:10, 47:20, 48:24, WILLIAM [1] - 8:5
202:21, 203:24, 212:20, variety [1] - 111:17 48:25, 61:18, 67:21, 68:2, William [2] - 8:14, 28:5
213:5, 213:11, 214:4, verbal [1] - 12:6 72:17, 77:17, 90:12, 90:17, willing [1] - 58:5
215:12, 217:3, 217:13, verify [3] - 160:3, 160:19, 91:22, 91:25, 92:4, 92:7, willingness [1] - 223:23
219:9, 228:6, 228:15, 207:1 92:10, 93:9, 94:16, 95:10, wise [1] - 154:8
228:22, 228:25, 229:1, verses [3] - 224:8, 224:10, 97:8, 98:4, 99:10, 99:13,
wish [1] - 249:16
229:3, 230:16, 234:19, 224:12 102:3, 102:18, 109:13,
WITNESS [27] - 10:19, 10:24,
236:19, 237:19, 238:4, version [2] - 132:12, 144:18 110:12, 110:25, 111:3,
19:23, 62:5, 86:10, 95:16,
238:6, 242:6, 246:19, versions [4] - 134:15, 112:19, 114:6, 125:5,
95:19, 96:22, 104:2,
249:19, 250:19, 250:23, 134:21, 147:6, 224:17 142:21, 165:12, 166:2,
113:15, 131:12, 132:18,
252:18, 252:23, 253:6, versus [5] - 25:22, 65:15, 168:5, 172:13, 173:12,
132:20, 133:22, 137:19,
254:2, 256:1, 256:11, 205:10, 206:14, 228:3 177:19, 177:21, 178:1,
147:24, 161:10, 166:25,
256:16, 258:16, 260:3, Verve [1] - 111:10 178:4, 178:12, 191:22,
225:21, 226:10, 226:12,
260:21, 261:4 veteran [1] - 149:9 199:14, 201:25, 213:14,
232:6, 238:6, 238:12,
University 's [19] - 21:20, veterans [1] - 177:6 216:22, 218:8, 218:16,
262:9, 262:12, 262:15
27:2, 64:17, 100:20, VI [3] - 88:15, 88:21 250:19, 251:1, 259:7
witness [6] - 8:6, 19:21,
106:14, 191:13, 201:14, Violation [1] - 67:15
via [2] - 49:19, 60:4 42:4, 95:17, 161:7, 238:9
204:8, 213:10, 216:3, violations [6] - 37:23, 82:10,
Vice [16] - 11:6, 50:8, 119:16, witness 's [1] - 137:18
231:4, 231:6, 233:15, 142:19, 173:20, 192:12,
119:17, 122:12, 151:2, woman [7] - 63:21, 66:3,
243:19, 250:11, 251:22, 220:14
151:19, 151:24, 152:2, 67:3, 78:8, 93:13, 139:6,
257:22, 258:3, 262:6 vision [3] - 84:19, 86:24,
152:17, 182:5, 184:16, 169:15
unless [3] - 18:10, 37:20, 88:4
207:4, 227:19, 230:6, women [5] - 26:21, 26:22,
257:4 visual [1] - 142:4
230:7 176:10, 176:15, 215:7
up [33] - 9:14, 9:15, 10:17, voice [1] - 247:19
vice [4] - 42:3, 42:8, 49:2, women 's [4] - 214:3, 214:14,
10:23, 58:9, 58:12, 63:9, volleyball [1] - 214:9
89:24 214:20, 216:13
66:13, 67:25, 74:13, 77:22, volume [1] - 141:20
victim [1] - 150:16 wonder [2] - 197:14, 197:16
112:22, 117:8, 123:7, voting [1] - 223:13
victims [3] - 168:2, 168:12, wondering [2] - 86:6, 87:20
137:25, 141:14, 146:6,
168:14 word [8] - 111:16, 224:5,
152:6, 159:9, 159:12,
166:5, 174:13, 187:8,
view [3] - 250:11, 250:12, W 241:13, 252:15, 253:7,
251:20 256:1, 256:2, 256:3
189:9, 193:14, 202:22,
viewing /addiction [1] - words [3] - 71:13, 86:13,
203:25, 206:8, 240:8, wait [3] - 55:18, 122:2, 160:2
111:18 224:5
247:18, 247:21, 261:15, Waited [2] - 54:16, 54:18
views [22] - 49:5, 60:25, workers [1] - 254:21
262:19 waiting [4] - 54:19, 180:12,
61:1, 61:2, 61:5, 61:8, works [8] - 25:13, 117:8,
update [6] - 109:2, 147:12, 193:13, 194:9
61:9, 61:11, 61:14, 61:15, 137:15, 138:14, 141:23,
206:4, 228:1, 235:5, 237:4 walk [2] - 86:5, 247:7
61:16, 94:20, 94:22, 95:1, 142:12, 143:4, 170:15
updated [15] - 48:6, 85:3, wall [1] - 167:16
99:7, 99:9, 99:12, 101:25, worry [1] - 145:21
85:9, 127:23, 127:24, Wanda [1] - 75:24
197:12, 234:11 wrestle [1] - 112:2
131:17, 133:3, 133:15, Wanda 's [1] - 75:24
VII [1] - 95:22 write [2] - 132:18, 181:21
134:15, 144:2, 144:17, wants [1] - 214:20
violate [23] - 27:7, 66:10, Writing [1] - 181:23
153:12, 154:15, 155:4, warranted [3] - 33:2, 33:11,
93:16, 93:18, 93:20, 94:8, writing [12] - 119:17, 134:17,

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 27

134:24, 146:1, 146:4,

159:21, 183:19, 187:6,
187:8, 195:22, 235:17
written [15] - 32:5, 37:3,
64:24, 66:16, 74:15, 106:4,
135:23, 145:9, 159:5,
159:7, 186:21, 188:11,
205:24, 213:9, 241:17
wrote [8] - 30:2, 43:10, 46:7,
54:7, 59:7, 65:16, 123:16,
146:12

yawning [1] - 100:6

year [3] - 8:18, 261:14,
261:16
years [5] - 53:25, 75:1,
164:15, 184:6, 219:16
yesterday [2] - 260:15,
260:17
yielded [1] - 178:4
yourself [5] - 44:11, 87:12,
104:14, 107:13, 247:2

93 of 93 sheets EDWARDS REPORTING SERVICE 319-338-3776 or 319-465-3654 Page 27 to 27 of 27