In a civil lawsuit against Stanford filed on Monday, a female graduate student alleges that the University’s lenient responses to complaints of abuse allowed the same man to sexually and physically assault at least four women, including herself.

The lawsuit, which refers to the plaintiff as Jane Doe, asserts that the University violated California’s Gender-Motivated Violence Act, California’s Equity in Higher Education Act and its “duties of care” obligation for Doe. The suit charges that Stanford was “deliberately indifferent” to the women’s reports of sexual misconduct, and that authority figures on campus discouraged her and others from reporting.

“Women will not have an equal opportunity to succeed academically until the epidemic of sexual violence on campus ends,” said Rebecca Peterson-Fisher, an attorney for Equal Rights Advocates, to the Mercury News. “Institutions like Stanford need to be held accountable for their failure to recognize the severity of these crimes and to comply with Title IX.”

Stanford spokeswoman Lisa Lapin expressed “sympathy” for Doe on behalf of the University, but clarified that Stanford will fight the lawsuit, as the University believes that it handled complaints appropriately.

“In our response to these cases, we aim to work in a sensitive and compassionate manner with those who have experienced trauma, to investigate every dimension of the facts as we are able, to ensure the fair treatment of everyone involved, and to take the actions necessary to protect the safety of individuals and the campus community as a whole,” Lapin wrote in an email to The Palo Alto Weekly. “We believe our Title IX process is effective and fair.”

Lapin wrote that Stanford would file a response to the charges in court. The University’s answer to the lawsuit can be found in its entirety here.

“We cannot comment on specific facts of this lawsuit due to privacy laws. We have sympathy for the plaintiff in this case, but we will be vigorously defending the lawsuit as we believe that Stanford has acted with appropriate diligence and compassion within the constraints of privacy laws,” a University statement read.

The complaint, which seeks damages through a jury trial, alleges that in February 2014, Doe reported to the University that her previous boyfriend, identified in the lawsuit as “Mr. X,” twisted her arm and told her to kill herself when she did not want to have sex with him.

The suit says that, prior to Doe’s sexual assault, Mr. X assaulted another Stanford woman, identified as “Ms. A,” on campus in 2011. Ms. A, who formerly dated Mr. X, reported to Stanford in 2012 that Mr. X choked and raped her in her dorm room.

Upon reporting her alleged assault, Ms. A was encouraged by one of her advisors to drive to the beach for the sake of her mental health. One of Ms. A’s residential staff members pledged in an email to tell Mr. X that sexual assaults “were not okay and that he has a very serious problem with anger.”

A third female Stanford student reported in June 2014 that Mr. X became “violently angry” after she refused to have intercourse with him. She said he “threw a table at her and punched her in the face while holding a shampoo bottle, splitting her lip.” Following her alleged assault, she took a leave of absence from the University.

The lawsuit mentions an incident involving Mr. X and another unnamed woman; however, no details were provided regarding this fourth case.

The University found Mr. X guilty of “serious sexual misconduct” and banned him from campus in July of 2014, although he had already graduated by then. In February 2016, however, the plaintiff saw Mr. X on campus. “Alarmed and traumatized, Ms. Doe sought assistance from Stanford public safety officers,” the complaint says. “The officers told her that there was no official record of the ban and they could neither arrest Mr. X nor remove him from campus.”

Equal Rights Advocates (ERA), a nonprofit women’s rights organization based in San Francisco, San Francisco’s The Liu Law Firm and the Colorado-based Hutchinson, Black and Cook, filed Doe’s complaint with the U.S. District Court of Northern California’s San Francisco division.

The University’s statement on the lawsuit is shown below:

STATEMENT ON JANE DOE LAWSUIT (LW)

We have great sympathy for this student and any student who may have experienced sexual assault. Stanford has tremendous compassion for sexual assault victims and we have a confidential support team to support survivors of sexual assault and relationship violence. This should not happen at Stanford or anywhere else. Sexual assault and sexual misconduct are abhorrent and antithetical to the values of our campus–we take these matters very seriously and have zero tolerance for such violence. Stanford’s top priority is always the well-being and safety of all of our students. Consistent with that principle, we have acted in this case and in all matters to protect our students.

We want to support every student and ask all victims of sexual assault who come forward to report their experience to the police and to go through the student discipline process if the alleged assailant is a student. Similarly, when we hear reports that a member of our community may have been victimized, we affirmatively reach out to them for more information and encourage them to participate in an investigation. Sometimes sexual assault survivors are unwilling to do so, and they have the right not to bring charges or participate in an investigation. While we respect that our students have agency in determining if they want to pursue action, we urge them to come forward so that we can better protect other members of our community. If the university is aware of a second report relating to an alleged assailant, the university returns to the person who made the original report and again asks them to participate in an investigation. Without the cooperation of victims, regrettably the university is very limited in what it can do.  Nonetheless, we provide support to sexual assault survivors and will investigate and adjudicate cases if survivors later change their mind.

Stanford has devoted enormous attention to its sexual assault processes under Title IX. Any case that involves allegations of violations of Title IX demands and receives the university’s serious attention, and the attention of our deeply dedicated professionals who respond to these cases. In our response to these cases, we aim to work in a sensitive and compassionate manner with those who have experienced trauma, to investigate every dimension of the facts as we are able, to ensure the fair treatment of everyone involved, and to take the actions necessary to protect the safety of individuals and the campus community as a whole. We believe our Title IX process is effective and fair.

We cannot comment on specific facts of this lawsuit due to privacy laws. We have sympathy for the plaintiff in this case, but we will be vigorously defending the lawsuit as we believe that Stanford has acted with appropriate diligence and compassion within the constraints of privacy laws. We will be filing a response in court shortly.

Contact Courtney Douglas at ccd4 ‘at’ stanford.edu.