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Baylor Lawsuit3.pdf


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Case 6:16-cv-00180-RP-JCM Document 1 Filed 06/20/16 Page 1 of 17

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UNITED STATES DIsTRIcT COURT
WESTERN DISTRICT OF TEXAS
WACO DIVISION
JANE DOE;

F

>rURT
EXAS

§
PLAINTIFF,
§

BAYLOR UNIVERSITY; BAYLOR UNIVERSITY
PATTY
AND
REGENTS;
BOARD
OF
CRAWFORD, IN HER OFFICIAL CAPACITY AS
TITLE IX COORDINATOR;

CASE No.:

,1

1

6 c P 1 80

§

§
§
§
§

DEFENDANTS.

§

COMPLAINT AND JURY DEMAND

Plaintiff Jane Doe, by and through her attorneys, submits this Complaint and states the
following:
I.
PARTIES, JURISDICTION & VENUE

I.

Jane Doe ("Doe") was, at all times relevant, a student at Baylor University.1

2.

Defendant Baylor University ("Baylor") is an educational institution and is a private

university located in Waco, Texas.
3.

Defendant Baylor University Board of Regents ("Baylor Regents") is the official

governing body of Baylor University ("Baylor") and is charged with operating and governing
Baylor.
4.

Defendant Patty Crawford ("Crawford") is, and was at all times relevant, the Title IX

Coordinator at Baylor. Crawford is responsible for overseeing all Title IX complaints and
investigations. As Title IX Coordinator, Crawford is an agent of Baylor.

"Jane Doe" has been substituted for the name of the Plaintiff for all causes of action brought
by and through this Complaint in order to protect her privacy. Plaintiff plans to file a Motion to
Proceed With Fictitious Name.
1

Complaint

Page

1