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2. I make this declaration in support of Plaintiff’s Motion for Partial Summary Judgment. (Dkt.
122.)
3. During my entire time enrolled as a student at Williams College, I did not receive any detailed
training pertaining to the College’s sexual assault/harassment policies. The only instance I can recall
where the student handbook was formally addressed to me by the College was during a brief
information session conducted by a member of Campus Safety and Security during the early days of
my freshmen year in fall 2011. During the session, the security officer went over basic conduct rules
(e.g.., no hard alcohol consumption, loud music after certain hours, etc.). Moreover, they only briefly
touched upon the subject of sexual misconduct, merely noting that there was in fact a policy in place.
4. While doing Williams College policy research on April 5, 2016, I visited the College’s
Archives and Special Collections. There I met Ms. Jessika Drmacich-Flach, Records Manager and
Digital Resources Archivist. I asked if I could see the student handbooks that dated back to 2010.
Ms. Drmacich-Flach informed me that the student handbook for academic year 2011-2012 was
Case 3:16-cv-30184-MGM Document 124-3 Filed 09/30/18 Page 2 of 4
missing. She also noted that there were no hard copies of the handbook after 2013 as the policies
starting in 2013 were electronic and only on the college’s website. She affirmed that she had copies
5. At the commencement of each academic year, I enrolled in classes through the College’s portal
6. For the 2014-2015 and 2015-2016 academic years, when enrolling in classes, I was required to
sign acknowledgment of the code of conduct. However, the manner in which it was presented to read
and sign such document was obscure and misrepresentative. The PeopleSoft system did not allow
enrollment into any classes without having signed/checked an ‘I agree’ box that referred to the code
of conduct. Students including myself clicked through quickly in order to enroll as soon as possible,
in fear that there would be no spots left in the certain highly coveted classes.
7. At the beginning of the 2014-2015 academic year, the only exposure I had to the Code of
Conduct was the box check process prior to class enrollment in the PeopleSoft online system.
8. For the Fall 2014 semester, classes commenced on or around September 5, 2014 so it would
have been before then that I checked off the box Code of Conduct acknowledgment.
9. I never received an electronic copy of the Code of Conduct that went into effect October 2014.
I also never performed the box check acknowledgment of the October 2014 Code of Conduct at any
10. The last personal communication I ever had with Susan Smith was March 4, 2016.
11. During the last few minutes of my third and final interview with Allyson Kurker, she noted
that Susan accused me of sexual misconduct for engaging in nonconsensual intercourse during my
sophomore year, nearly two years earlier. Such news left me absolutely dumbfounded and, as noted
in my interview transcript, at a loss for words. Such actions on my behalf never transpired throughout
my entire relationship with Susan. Moreover, as this was at the very end of three grueling interviews
with Kurker, I was not granted the opportunity to properly respond to the outrageous allegation.
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12. At the meeting I had with College Counsel, Dean Bolton, and my attorney on March 14,
2016, to speak about my complaint against Susan Smith, my attorney expressed concern that
Williams was protecting a school official who had assaulted, abused, harassed, and used her position
because I had spurned her advances. After my attorney read our written and documented statement
of facts concerning Smith’s false accusations, Dean Bolton and College Counsel Jeff Jones
merely thanked us and walked us out of the office. Neither College Counsel nor Bolton suggested I
go to law enforcement.
13. Upon information and belief, Williams College has never made any report of sexual assault
14. My exclusive, romantic, and sexually active relationship with Susan Smith commenced in
October 2013.
15. A few months after our relationship started, Susan went on the birth control pill.
Approximately one month after Susan started using the pill, due to the changes in pH levels, Susan
began to experience intermittent scant natural lubrication. Sometimes she experienced soreness
16. In Spring 2014, we began to use synthetic lubrication to address the issue.
17. The only investigative report I received was the one dated September 13, 2016. The College
18. On June 8th, 2016, a week following my second interview with Allyson Kurker, I asked to
obtain a copy of the witness interview transcripts for review. By doing so, my intention was to grasp
what the witnesses said and to further elaborate on certain topics were needed to discuss during my
19. I have never spoken to nor engaged in any communications with Rosanna Reyes or Meg
Bossong.
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20. Throughout my time at Williams College, not including the March 14, 2016 meeting with
her, College Counsel, and my attorney, I only engaged with Dean Sarah Bolton on a few brief
occasions to discuss procedures. I have never had a substantive conversation regarding Susan Smith
with Bolton.
21. Between February 1, 2016 and February 6, 2016 the only communications I had with Susan
22. At all times, the sex Susan and I had was consensual.
Signed under the pains and penalties of perjury this 30th day of September 2018.
CERTIFICATE OF SERVICE
This document was served electronically upon all counsel of record by filing through the ECF
system on September 30, 2018.
_/s/ Stacey Elin Rossi_______
STACEY ELIN ROSSI