1. Vamsidhar Vurimindi
1782 Frankford Ave, Unit 1, Philadelphia, PA 19125
1. Barns Barton
6219 Lymbar Dr. Houston, TX 77096, USA
2. Robert Ball
3227 Harris Mill LN, Charlotte, NC 28262
3. Nathaniel Hawkins
5123 White Horse Dr. Greensboro, NC
4. Robert Ross
117 Homegate Circle, Apex, NC 27502
5. Peter Walton
1299 Sandy Bottom Drive, NW Concord, NC 28027
6. Dan Paschke
4420 Overglen Ave, Wake Forest, NC 27587, USA
7. Brooke Balcom
3355 Greenfield Lane, Cincinnati, OH 4524
8. Moira Ringo
7730 Cape Charles Dr, Raleigh, NC 27617
9. Shana Keating
3028 Sawyers Mill Drive, Apex, NC 27539
10. Anna Gonowon
101 Glenlake Commons, Decatur, GA 30030
United States District Court for the
Middle District of North Carolina
Complaint for Libel
Complaint for Slander
Complaint for Civil Conspiracy
Complaint for Negligent Infliction of Emotional
Complaint for Intentional Infliction of Emotional
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 1 of 125
Page - 2 - of 125
Diversity of Citizenship, 28 U.S.C. § 1332
(II) THE PARTIES:
01. Plaintiff Vamsidhar Vurimindi is a resident of 1782 Frankford Ave, Unit # 1, Philadelphia, PA
19125. Hereafter Plaintiff Vamsidhar Vurimindi referred as Plaintiff.
02. Defendant Barnes Barton, is a resident of 6219 Lymbar Dr. Houston, TX 77096, USA
03. Defendant Robert Ball, is a resident of 3227 Harris Mill LN, Charlotte, NC 28262
04. Defendant Nathaniel Hawkins, is a resident of 5123 White Horse Dr. Greensboro, NC 27410
05. Defendant Robert Ross is a resident of 117 Homegate Circle, Apex, NC 27502.
06. Defendant Peter Walton is a resident of 1299 Sandy Bottom Drive, NW Concord, NC 28027.
07. Defendant Dan Paschke, 4420 Overglen Ave, Wake Forest, NC 27587, USA
08. Defendant Brooke Balcom, is a resident of 3355 Greenfield Lane, Cincinnati, OH 45245, USA
09. Defendant Moira Ringo is a resident of 7730 Cape Charles Dr, Raleigh, NC 27617.
10. Defendant Shana Keating is a resident of 3028 Sawyers Mill Drive, Apex, NC 27539.
11. Defendant Anna Gonowon is a resident of 101 Glenlake Commons, Decatur, GA 30030
(III) STATEMENT OF CLAIM:
12. In February 2008, prior to applying for an admission into Weekend Executive MBA program
(“WEMBA”), Plaintiff had a meeting with Duke’ Assistant Director for Admissions in Duke
13. At that time, Plaintiff bargained for business writing and real estate finance courses; and
assist Plaintiff to prepare a detailed business plan to develop vacant lots owned by City of
Philadelphia, which are scattered in the city.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 2 of 125
Page - 3 - of 125
14. In response, Duke’ Assistant Director for Admissions made a specific promise to Plaintiff that
Duke will offer business writing and real estate finance courses; and assist Plaintiff to
prepare a detailed business plan to develop vacant lots owned by City of Philadelphia,
through its Center for Entrepreneurship and Innovation (CEI) or Center for the Advancement
of Social Entrepreneurship (CASE).
15. After, Duke’ Assistant Director for Admissions made specific promises, Plaintiff without
ambiguity paraphrased those specific promises in writing as to why Plaintiff wanted to earn
an MBA and what curriculum Plaintiff is expecting that Duke must offer and submitted along
with his admission application.
16. After that, a high level Duke’ Admissions committee reviewed Plaintiff’ application along
with Plaintiff’ written statements and accepted Plaintiff’ application and immediately
thereafter, Plaintiff paid the tuition fee.
17. Duke offered WEMBA course over a span of 19 months between March 2008 and November
2009, in six terms.
18. Plaintiff deliberately chooses a WEMBA program over online format is to have one-on-one
in-person direct contact with the student body, because face-to-face meetings are essential
to cultivate new relationships in many business interactions.
19. Plaintiff self financed WEMBA program cost paid all expenses on his own, but not limited to
the school tuition fee, travel expenses and time to attend the classes.
20. WEMBA program started with one (1) week on-campus orientation program and subsequent
classes are held on alternating weekends on Fridays and Saturdays.
21. Duke provided accommodation on Friday nights and at an extra cost Duke provided
accommodation on Thursday nights.
22. Plaintiff stayed at the R. David Thomas Center on Thursday and Friday nights, where Duke
provided accommodation to WEMBA students.
23. In between the weekend classes, to continue the collaborative interaction between the
students and professors, Duke provided software application l called “CentraOne”, having
capabilities for live interaction with professors and other students. Many WEMBA students
extensively used CentraOne to interact with other students as well as with Professors.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 3 of 125
Page - 4 - of 125
24. In March 2008, Duke commenced WEMBA class of 2009 program with one (1) week
25. In March 2008, on the 1st day of the orientation session, Defendant Moira Ringo told to
many of the Plaintiff’ classmates that, Plaintiff lacks academic integrity and had a history of
academic dishonesty; and indulged in adultery.
26. In March 2008, on the 2nd day of the orientation session during a breakfast at R. David
Thomas Center, Defendant Moira Ringo gathered Plaintiff’ classmates Jason Link and David
Mitchell around Plaintiff and Defendant Moira Ringo prodded Jason Link to start a pre-
meditated conversation in a mocking fashion. At that time, Jason Link looking towards
Plaintiff and said that, “it appears that cheaters are in the class”. At that time, immediately
Plaintiff asked Jason Link, “What do you mean by that?” At that time Jason Link response
27. Nevertheless, Plaintiff attempted to pursue Jason Link for an explanation, but at that time,
Duke Administrators rushed Plaintiff and other WEMBA students to get into a bus to go to
Triangle Training Center for team building exercises, which are part of the orientation
session and Plaintiff, Defendant Moira Ringo and Jason Link departed.
28. Plaintiff and David Mitchell happen to belongs to a team, Plaintiff stayed with David Mitchell
and get into the bus. For the first few minutes of the bus travel, Plaintiff and David Mitchell
had decent conversation and after that, suddenly David Mitchell suggested to Plaintiff to
read a book about, “how to lie without getting caught by the lie detector”. Immediately,
Plaintiff asked David Mitchell, “Why do you think that I should read that book?” In response,
David Mitchell told to Plaintiff, that “it may be helpful for you to continue in the program”.
At that time, Plaintiff asked David Mitchell, “Why do you think that I am lying?” At that time,
David Mitchell response was vague and dismissive.
29. Jason Link and David Mitchell both in their responses were evasive and vague to Plaintiff and
this lead Plaintiff to confusion over the matter at hand, as well as made the Plaintiff
disinclined to pursue further conversations on the topic with Defendant Moira Ringo and as
well as with both Jason Link and David Mitchell.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 4 of 125
Page - 5 - of 125
30. Plaintiff believes that Defendant Moira Ringo resorted to psychological manipulation to gain
power and control over Plaintiff, by throwing Plaintiff on the defensive by using subtle,
indirect, or implied threats.
31. Because, Defendant Moira Ringo’ false accusations attributing to Plaintiff are almost
impossible to be seen as aggressive on the surface, and visibly at the unconscious level,
Plaintiff is confused over the matter at hand, Jason Link and David Mitchell both believed
Defendant Moira Ringo’ false accusations attributing to Plaintiff, and further blamed,
condemned, defamed, denigrated, denounced, disparaged, humiliated, maligned, pilloried,
sullied, tarnished Plaintiff’ reputation among the Plaintiff’ classmates by attributing Plaintiff
lacks academic integrity and had a history of academic dishonesty; and indulged in adultery.
along with other Plaintiff’ classmates2
haunted and jog the Plaintiff’ memory
about Defendant Moira Ringo’ statements about Plaintiff’ lacking academic integrity and had
a history of academic dishonesty; and indulged in adultery and covertly and overtly made
several preparatory acts to compel Duke to expel Plaintiff throughout the WEMBA program
by schemingly using Duke’ professors, Duke’ policies and procedures.
33. Within a week, by the end of the orientation session, along with other Defendants and
Plaintiff’ classmates, Defendant Moira Ringo organized a smear campaign against Plaintiff by
propagating Plaintiff’ lacking academic integrity and had a history of academic dishonesty;
and indulged in adultery and not as a person was properly grounded with a decent set of
values and turned Duke Campus into a hostile environment to Plaintiff.
34. Defendant Moira Ringo along with other Plaintiff’ classmates told to Professor Jill Stowe that
Plaintiff’ lacking academic integrity and had a history of academic dishonesty; and indulged
Barnes Barton, Robert Ball, Nathaniel Hawkins, Robert Ross, Peter Walton, Dan Paschke, Brooke Balcom, Moira
Ringo and Shana Keating.
Jason Link, Kristofer Singleton, David Mitchell, Douglas Bashar, Johnny Williams, John Dohnal, Alissandro Castillo,
Sudheer Dharanikota, Sunil Balasaheb Patil, Amit Khare, Eugene White, Rajiv Prasad Kolagani, Pratibhash
Chattopadhyay, Jennifer Erickson, Seth Gillespie, Gregory Valentine, Pradeep Rajagopal, Rajiv Patnaik, Lei Zhu,
John Espey, Sanjay Mishra, Sankar Ramesh, Kevin Giusti, and Sreedhar Manjigani
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 5 of 125
Page - 6 - of 125
35. Defendants smear campaign was so intense, powerful, persuasory, actuating, convincing,
and provocative enough to sway the learned professors felt that Plaintiff’ lacking academic
integrity and had a history of academic dishonesty; and indulged in adultery, so Plaintiff
shouldn’t be allowed to continue in the WEMBA program.
36. Plaintiff was agitated and discomposed with the Defendants intense smear campaign against
Plaintiff, on 13th March 2008, at 8:00 AM attended his first class at Duke.
37. Fortunately or unfortunately, Professor Jill Stowe’ Probability and Statistics course is the first
38. As soon as class started Professor Jill Stowe told to the class that she is using a
randomization tool to pick a student and ask a question from the class reading material.
39. Immediately Professor Jill Stowe called on Plaintiff and asked a question from the class
reading material and Plaintiff answered her question. Nevertheless, Professor Jill Stowe was
predetermined to prove that Defendants claim that, Plaintiff came to Duke, by indulging
through academic dishonesty and not by his intelligence and continue to ask ancillary
questions from outside of the class reading material to a point where, Plaintiff could not
answer her question.
40. At a point in time, when Plaintiff could not answer Professor Jill Stowe’ question from
outside of the class reading material, Plaintiff’ classmates Jason Link, Rajiv Prasad Kolagani,
David Mitchell, Sunil Balasaheb, and Sanjay Mishra conveyed to other students with their
facial and hand gestures, “see we told you”, implying that Plaintiff came to Duke, by
indulging through academic dishonesty and not by his intelligence.
41. Surprisingly, next day on 14th March 2008, Professor Jill Stowe told to the class that her
randomizing tool is not working; hence she will call the students directly.
42. Plaintiff believe that Professor Jill Stowe told to the class that she is using a randomization
tool to pick the students, but in reality there is no true functioning randomization tool at her
disposal to select the students.
43. In fact and indeed, Professor Jill Stowe used the name of the randomization tool as a smoke
screen to purposefully pick Plaintiff as soon first class was started, because she is
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 6 of 125
Page - 7 - of 125
predetermined to prove that Defendants claim that, Plaintiff came to Duke, by indulging
through academic dishonesty and not by his intelligence.
44. On 14th March 2008, while Plaintiff is sitting in the Managerial Effectiveness class, Plaintiff
classmate Rajiv Patnaik leaned towards Plaintiff and said that, “they came to know about
you”. At that time, Plaintiff asked Rajiv Patnaik we can talk about this during class break.
Right after that, during class break Plaintiff asked Rajiv Patnaik, “What are you saying during
the class?” At that time, Rajiv Patnaik’ response was dismissive and abruptly ended his
conversation with Plaintiff.
45. On 29th March 2008, sometime during afternoon class session break, Plaintiff classmate
Rajiv Prasad Kolagani approached Plaintiff and said that, “they came to know about you”. In
response, Plaintiff told to Rajiv Prasad Kolagani that, “during the last class session, Rajiv
Patnaik also told to me the same thing and when asked to explain, he abruptly ended the
conversation and can you please explain me?”. At that time, Rajiv Prasad Kolagani response
was dismissive and ended the conversation with the Plaintiff abruptly.
46. Plaintiff believes that Defendant Moira Ringo’ false accusations attributing to Plaintiff lead
Rajiv Patnaik and Rajiv Prasad Kolagani to further vilify Plaintiff, by putting Plaintiff on the
defensive while masking their aggressive intention of gain power and control over Plaintiff
through subtle, indirect and implied threats.
47. On 10th April 2008, Plaintiff’ classmates Tina Hong, Sanjay Mishra, Sreeedhar Manjigani3
John Dohnal and Seth Gillespie invited Plaintiff to join then for casual conversations. At that
time, John Dohnal enquired Plaintiff’ marital status and Plaintiff told to John Dohnal that he
48. Then, immediately John Dohnal asked, “What is your wife do for living?” In response Plaintiff
told to John Dohnal that, “My wife is a COO of a fast growing life sciences company in
Philadelphia region”. Then, John Dohnal asked, “what is the annual sales volume of your
Sridhar Manjigani and Plaintiff belongs to same hometown back home in India; Sridhar Manjigani’ father is an
acquaintance to Plaintiff’ father. Plaintiff and Sridhar Manjigani didn’t attend together the same school or college
back home in India.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 7 of 125
Page - 8 - of 125
wife’ company?”. Then Plaintiff told to John Dohnal that, “her company is a private company
and the information about the company is revealed only on a need to know basis. If you
have any business proposal, I am happy to give my wife’ contact information, so that you can
find directly from her”.
49. Immediately, John Dohnal and Sanjay Mishra asked Plaintiff, “What is that you really do for
living?”. In response, Plaintiff told, “I am working as a consultant at Wyeth Pharmaceuticals
and started a real estate development company and am pursuing few construction projects
50. Immediately, John Dohnal asked Plaintiff, “What do you do at Wyeth”. Then Plaintiff
explained his nature of work. At that time, John Dohnal in a mocking fashion way asked
Plaintiff about his ongoing issue with Accenture and Wyeth employees at his work.
51. Plaintiff paused 15 seconds of silence to understand the mockery about Plaintiff’ work
situation at Wyeth Pharmaceuticals, and while Plaintiff was pausing, Seth Gillespie told to
Tina Hong, Sanjay Mishra, Sridhar Manjigani and John Dohnal that “he is having rough time
at Wyeth Pharmaceuticals, and he has been demoted, because he is messing with
52. Immediately, Plaintiff responded to Seth Gillespie that, “I am not messing with Accenture at
Wyeth, but it is true that my initial contract has been cancelled and that contract has been
awarded to Accenture”. At that time, Seth Gillespie accused Plaintiff that “he is lying and
that is why his lips are trembling”.
53. Then, Plaintiff realized that Tina Hong, Sanjay Mishra, Sridhar Manjigani, John Dohnal and
Seth Gillespie are somehow in direct contact with Plaintiff’ managers at Wyeth
54. Plaintiff realized that Defendant Moira Ringo’ statements about Plaintiff lacking academic
integrity and having history of academic dishonesty; and alleged adultery along with
Plaintiff’ managers intimidation, Defendants and Plaintiffs’ classmates are doubting Plaintiff’
academic integrity and marital honesty and not knowing as to how educate Tina Hong,
Sanjay Mishra, Sridhar Manjigani, John Dohnal and Seth Gillespie, Plaintiff left them and
went back to his room.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 8 of 125
Page - 9 - of 125
55. On 11th April 2008, during morning breakfast at R. David Thomas Center, Plaintiff, Aparna
Batra and Sreedhar Manjigani are taking breakfast at one table. At that time, while Sreedhar
Manjigani prodding Aparna Batra with facial suggestions, Aparna Batra told to Sreedhar
Manjigani that , “Vamsidhar eyes are telling the story that he is guilty”.
56. At that time, Plaintiff asked Sreedhar Manjigani, “what did you tell her and what is she
talking?” Right after that, Sreedhar Manjigani quickly left the table and when Plaintiff
attempted to ask the same question, Sreedhar Manjigani’ answer was vague, abrupt and
57. On 11th April 2008, sometime after the afternoon class session, while Plaintiff is walking
back to his room, Tina Hong, Sanjay Mishra, and Sreedhar Manjigani called Plaintiff to join
them for a conversation and Plaintiff reluctantly joined them.
58. At that time, Sanjay Mishra asked Plaintiff to tell about Plaintiff’ family history and Plaintiff’
work before migrating to United States. At that time, Plaintiff felt uncomfortable and
attempted to divert the conversation. Nevertheless, Sanjay Mishra insisted to respond to his
question. At that time, Plaintiff was annoyed by Sanjay Mishra’ persistence and told them
Plaintiff don’t want to talk about that issue.
59. At that time, Sanjay Mishra looked at Plaintiff and said that that “why are you getting
uneasy, it seems that you are trying to hide something”. At that time, Plaintiff left the group
and went back to his room.
60. Plaintiff believe that Defendant Moira Ringo’ statements about Plaintiff lacking academic
integrity and having history of academic dishonesty; and alleged adultery lead the Plaintiff’
classmates to enquire into Plaintiff’ private life.
61. On 11th April 2008, in the evening Duke organized a networking opportunity with Global
Executive MBA students and Plaintiff participated in this event. At that time, Sarah Rosen
Shah, Duke’ Weekend Executive MBA Admissions Counselor also present in that event.
62. On 11th April 2008, while Plaintiff standing along with several other classmates, Sarah Rosen
Shah approached Plaintiff and asked Plaintiff as “how the things are at Wharton and what
happened to your admission at Wharton”. Then Plaintiff replied as “Wharton denied the
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 9 of 125
Page - 10 - of 125
63. Immediately, Sarah Rosen Shah responded back to Plaintiff that, “it seems that they came
know that you don’t have what you claim that you have”. Then Plaintiff asked Sarah Rosen
Shah as “what do you mean by that?” However, Sarah Rosen Shah response was vague and
64. Plaintiff believe that Defendant Moira Ringo’ statements about Plaintiff lacking academic
integrity and having history of academic dishonesty; and alleged adultery lead Sarah Rosen
Shah to doubtful about Plaintiff’ integrity and that doubt leads Sarah Rosen Shah to
65. After that, Sarah Rosen Shah made hand and facial gestures to Plaintiff’ classmates, while
several attendees are watching them by conveying a meaning that not to talk to Plaintiff,
and as result Plaintiff couldn’t able to network with the participants.
66. On 11th April 2008, evening after dinner, Tina Hong gathered Sanjay Mishra, Sreedhar
Manjigani, Sankar Ramesh, Pratibhash Chattopadhyay and Eugene White at the Bar at R.
David Thomas Center.
67. While Plaintiff having dinner at R. David Thomas Center, Pratibhash Chattopadhyay
approached Plaintiff and asked “What are you doing after dinner?” Plaintiff responded to
him that “due to the course work load, I didn’t have time respond to my general contractor
questions, so, I want to respond to his questions tonight”. At that time, Pratibhash
Chattopadhyay suggested the Plaintiff, just come to the bar for few minutes to meet other
68. After his dinner, Plaintiff went to the bar at R. David Thomas Center and as soon, Plaintiff go
to the bar, Sanjay Mishra asked other students to stand in front of the Plaintiff. As soon,
Plaintiff classmates stand in front of Plaintiff, Sanjay Mishra said to the Plaintiff, “you are
standing in the line behind us and you will be waiting in the line behind us”. At that time,
Plaintiff asked Sanjay Mishra, “What is this all about?” At that time, Sanjay Mishra,
responded to the Plaintiff that, “don’t you understand? You are supposed to be the last
person in the queue”.
69. Plaintiff believe that Defendant Moira Ringo’ statements about Plaintiff lacking academic
integrity and having history of academic dishonesty lead his classmates believe that Plaintiff
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 10 of 125
Page - 11 - of 125
came to Duke, by indulging through academic dishonesty and not by his intelligence, they
are ranking Plaintiff with lowest possible rank.
70. Immediately, next day, on 12th April 2008, Plaintiff contacted Duke Administration and
explained the harassment that he is subjected by his classmates and demanded to enforce
Duke’ anti-harassment policies, before the defendants permanently and irrevocably damage
Plaintiff’ image and reputation in the student community.
71. After few days, Duke Administration without enforcing Duke’ anti-harassment policies to
restrain students from harassing Plaintiff, simply recommended some books4
to read as to
how to deal with burden of being an object of ridicule and harassment.
72. While, defendants continue to damage Plaintiff’ image and reputation in the student
community, as per Duke specific promise, Plaintiff enquired Duke for Business Writing
courses; In response, Duke Administration told to Plaintiff, that Duke don’t offer Business
Writing Course for WEMBA students and suggested to read some books from Duke library.
73. At the same time, as per Duke’ specific promise, Plaintiff asked Duke Administration and
Duke’ CEI and CASE to assist Plaintiff in the preparation of business plan to develop vacant
lots owned by City of Philadelphia.
74. None from Duke’ CEI and CASE respond to Plaintiff and in April 2008 Duke Administration
told to Plaintiff that Duke will offer some assistance if Plaintiff enrolled into entrepreneurial
courses in the Term 5 and 6.
75. Nevertheless, in May 2008, Duke Administration categorically told to Plaintiff that they don’t
offer any assistance to Plaintiff to prepare a business plan to develop vacant lots owned by
City of Philadelphia and suggested to hire a real estate attorney.
76. By this time in May 2008, Duke breached its two promises that it made to Plaintiff (1)
offering Business Writing Course (2) assist Plaintiff in the preparation of business plan to
develop vacant lots owned by City of Philadelphia.
Vamsi, I enjoyed our talk yesterday. There are some things we can discuss about the soft skill issues. I
recommend that you look carefully at the MET! and TKI feedback, and we can also discuss the Difficult
Conversations resources I alluded to yesterday. It would be interesting to see how your culture active results also
shed light on some of the issues we discussed, since I believe the cultural background you came from may have
influenced you greatly in your current style of communication.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 11 of 125
Page - 12 - of 125
77. In addition, by this time in May 2008, Duke failed to enforce anti-harassment policies.
78. While, Plaintiff struggling to understand as to why his classmates organized a smear
campaign against Plaintiff, Professor Jill Stowe, between, May 2008 and June 2008
conducted three short exams.
79. Professor Jill Stowe, purposefully and continually targeted Plaintiff by incorrectly evaluating
Plaintiff’ exam answers and prominently placed Plaintiff’ score cards to the public eye, in
violation to the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR
80. Plaintiff believes that Jill Stowe prominently placed Plaintiff’ score cards to the public eye to
lower Plaintiff’ image among his classmates, because Plaintiff didn’t get high scores and the
general perception that exam scores are proxy to estimate one’ intelligence.
81. Plaintiff was confused, distracted and under severe mental distress due to the ongoing
harassment by his classmates, Plaintiff couldn’t able to contact Professor Jill Stowe to ask to
reevaluate Plaintiff answers.
82. By the end of the Term-1, Defendants and Professor Jill Stowe created an impression among
the WEMBA students that Plaintiff will be detained and will not be promoted to Term-2 and
accordingly, Plaintiff’ classmates directly accused Plaintiff in front of Professor Jill Stowe.
83. In June 2008, on the last minute of the final exam of Professor Jill Stowe’ Probability and
Statistics course, when Plaintiff is handing his answer sheet to Professor Jill Stowe, at the
instigation of Pratibhash Chattopadhyay, Jennifer Erickson told to Professor Jill Stowe
attributing to Plaintiff as “he is a criminal”.
84. At that time, immediately, Plaintiff asked Pratibhash Chattopadhyay and Jennifer Erickson,
“Why would you call me a criminal”. At that time, Pratibhash Chattopadhyay and Jennifer
Erickson didn’t respond to Plaintiff, and Professor Jill Stowe was mere spectator during that
85. In June 2008, after final exam of Professor Jill Stowe’ Probability and Statistics course, when
Plaintiff leaving the Duke’ Campus to airport, Defendant Moira Ringo purposefully
approached Plaintiff and told to Plaintiff “this is the last trip for you to Durham, NC”. At that
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 12 of 125
Page - 13 - of 125
time, Plaintiff asked Defendant Moira Ringo, “What do you mean?” At that time, Defendant
Moira Ringo response was vague, abrupt, and dismissive.
86. Later, it turn out that Professor Jill Stowe awarded a failing grade to Plaintiff, despite there
is no Duke policy is required or expected to fail a student.
87. It is evident that, Professor Jill Stowe revealed Plaintiff’ failing grade to Plaintiff’ classmates,
prior to evaluating Plaintiff’ final exam answers and prior to informing Plaintiff about his own
grades is in violation to Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g;
34 CFR Part 99).
88. After, Plaintiff was informed by Duke Administration, that Professor Jill Stowe awarded a
failing grade and that would detain Plaintiff to progress into Term-2, Plaintiff compared his
all three short exam answer sheets; and his final exam answers with the Professor Jill Stowe’
answer keys and found that Professor Jill Stowe made blatant errors in evaluating Plaintiff’
89. As soon, Plaintiff observe the blatant errors in evaluating Plaintiff’ answers and subsequent
award of a failing grade, Plaintiff challenged his grade, because Plaintiff believe that
Professor Jill Stowe unfairly evaluated Plaintiff’ performance.
90. In his appeal, Plaintiff demanded Duke to review all WEMBA students answer sheets,
whether Professor Jill Stowe used the same ‘yard stick’ to evaluate Plaintiff’ answer sheets.
91. Professor Jill Stowe without getting into reviewing WEMBA students answer sheets, and
Plaintiff’ answer sheets, Professor Jill Stowe adjusted Plaintiff’ grade from fail to low pass.
92. Plaintiff believes that Duke and Professor Jill Stowe pre-empt a detailed enquiry into the
review of WEMBA students answer sheets, by adjusting Plaintiff’ grade from fail to low pass
to hide the fact that Professor Jill Stowe targeting Plaintiff by awarding a failing grade.
93. In fact and indeed Duke and Professor Jill Stowe foreclosed an enquiry into the review of all
WEMBA students answer sheets and this is confirmed by the email5
between Duke Administrators Mark Miller and Dean Gallagher.
Regarding grade appeal, in an email that Mark Miller wrote to Dean Gallagher, that, “Good point. I think what he
is looking for is ammunition to say that Jill did something inappropriate. My belief is that if we tell him that Jill
chose to fail him but was in no way required or expected to do so, that will reinforce his believe that Jill is unfairly
singling him out for a bad grade”.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 13 of 125
Page - 14 - of 125
94. In 2nd Week of June 2008, Duke announced WEMBA student’s partners’ weekend program
and Plaintiff informed Duke Administration that his wife will attend WEMBA students
95. As soon Plaintiff informed Duke Administration that his wife will attend WEMBA students
partners’ weekend, Sanjay Mishra and Sreedhar Manjigani along with Tina Hong approached
Plaintiff and asked “is that really your wife you are bringing to the partners weekend?”
96. Plaintiff was humiliated and embraced and don’t know how to respond to the vulgar,
indecent, obscene, lewd and offensive question and left them.
97. Plaintiff believe that, Plaintiff’ classmates asked this vulgar and offensive question because,
Plaintiff’ classmates believe Defendant Moira Ringo’ statements about Plaintiff’ alleged
adultery and Plaintiff is bringing someone else as his wife, despite few times Plaintiff told to
these same classmates that he is married and living with his wife in Philadelphia.
98. In 2nd Week of June 2008, during the WEMBA students’ partners’ weekend, Plaintiff
introduced his wife to several of his classmates, including spouses of the Sanjay Mishra and
Sreedhar Manjigani along with Tina Hong.
99. Later, in the evening, Plaintiff introduced his wife to Rajiv Prasad Kolagani and Anj Balusu
and to their spouses and sit together at the same dinner table. While, everyone at the table
having dinner, Rajiv Prasad Kolagani told to Anj Balusu and to his spouse that Plaintiff is
staying “illegal” in this country.
100. After the dinner, Plaintiff called on Rajiv Prasad Kolagani, and asked him what made him to
believe that Plaintiff is “illegal” in this country and asked his explanation. At that time,
Defendant Rajiv Prasad Kolagani’ answer was abrupt and dismissive.
101. Plaintiff believe that, Rajiv Prasad Kolagani speculated and prejudiced Plaintiff because of
his marital status and “age difference between him and his wife” as a proxy to his
“illusionary” defect on part of Plaintiff as an “illegal alien”.
102. Plaintiff believe that Defendant Moira Ringo’ statements about Plaintiff’ alleged adultery
established some preconceived notions about Plaintiff in the minds of his classmates, and
after Plaintiff introduced his wife, Plaintiff’ classmates draw their own conclusions and one
of the conclusion is Plaintiff as an “illegal alien”.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 14 of 125
Page - 15 - of 125
103. In July 2008, Duke conducted an on campus recruitment event. Plaintiff along with his
classmates attended that event. At that campus recruitment event, Plaintiff classmates Rick
Weiss and Suhash Bhavsar followed Plaintiff and made several hand and facial gestures to
recruiters, while several recruiters are watching them by conveying a meaning that Plaintiff
is not a good candidate.
104. On 28th July 2008, Plaintiff contacted Rick Weiss via email as follows: “Rick, It looks like you
have an issue with me. I did observe that you are trying to ridicule or undermine me. I
would like to make some things clear with you. Let me know when would be good time for
you to talk to me?”
105. On 29th July 2008, Rick Weiss responded to Plaintiff as follows: “Vamsi, I'm not sure where
you got that idea from, but maybe that's part of the problem. I'll be around Fuqua all day
today and I'll be more than happy to talk to you. Rick”
106. Immediately, Plaintiff in a gentle manner spoke with Rick Weiss and explained his hand and
facial gestures putting down the Plaintiff in front of recruiters along with Suhash Bhavsar and
asked him to explain what message he is getting from those hand and facial gestures. Rick
Weiss response was vague and abrupt.
107. Rick Weiss’ hand and facial gestures putting down the Plaintiff by using another classmate as
his/her sidekick and made non-aural insinuating remarks against Plaintiff in a mocking
108. Then immediately, Plaintiff enquired Duke Administration, whether Rick Weiss along with
Suhash Bhavsar’ hand and facial gestures putting down the Plaintiff in front of recruiters at
the recruitment events were allowed as per Duke’ anti-harassment policy. At that time, Duke
Administration told to Plaintiff that Duke Policy doesn’t allow such kind of behavior.
109. At that time, Plaintiff told to Duke Administration about Rick Weiss and Suhash Bhavsar’
behavior and how it affected him, because recruiters didn’t pay attention to Plaintiff’
resume and asked Duke Administration to take an action. Nevertheless, Duke Administration
didn’t take any action against Rick Weiss and Suhash Bhavsar.
110. Plaintiff believe that Defendant Moira Ringo’ statements about Plaintiff lacking academic
integrity and alleged past academic dishonesty established preconceived notions about
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 15 of 125
Page - 16 - of 125
Plaintiff in the minds of Rick Weiss and Suhash Bhavsar, and with that preconceived notions,
Rick Weiss and Suhash Bhavsar draw their own conclusions and with that backdrop Rick
Weiss and Suhash Bhavsar told to recruiters not to hire Plaintiff.
111. While Plaintiff struggling to understand the reason for WEMBA students hostility towards
Plaintiff, in July 2008, Sarah Rosen Shah, Duke’ admissions councilor relocated from Durham,
NC to Philadelphia, PA and specifically purchased a condo in the building in which Plaintiff
was residing for over three years.
112. In fact and indeed, after Sarah Rosen Shaw relocated from Durham, NC to Philadelphia, PA
and moved into building in which Plaintiff was residing, conducted psychological operation
and induced the behavior of other residents in and around building favorable to Duke
professors and Plaintiff classmates objectives, by undermine Plaintiff’ professional status and
personal standing by way of isolation and destabilization.
113. As soon, Sarah Rosen Shaw relocated to Philadelphia, PA, told to Plaintiff’ neighbors about
Plaintiff’ private and confidential information, such as his past academic record; his current
and future career plans embedded in the admission essays; recommenders’ opinions about
Plaintiff which was expressed in recommendation letters; Plaintiff’ own opinions about
Plaintiff which he expressed in his admission essays in violation to the Family Educational
Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99).
114. In addition, Sarah Rosen Shah, after relocating from Durham, NC to Philadelphia, PA
maintained constant contact with the Defendants trough various channels such as email,
social networking sites, telephone and through travel.
115. Since, July 2008 and until Plaintiff completes his MBA at Duke, Sarah Rosen Shah and
Defendants, in real-time exchange details of the Defendants repeated, ongoing and
objectionable egregious verbal attacks against Plaintiff at Duke.
116. In real-time Sarah Rosen Shah relayed Defendants egregious verbal attacks6
to Plaintiffs’ neighbors.
Since, July 2008 until Plaintiff completes his MBA program at Duke, Sarah Rosen Shah relayed the statements
made by Plaintiff’ classmates to Plaintiff neighbors as “Vamsi is a criminal”; “Vamsi was implicated in murder
cases”; “Vamsi was a Juvenile”; “Vamsi is having rough time at School”, “Vamsi is getting failing grades” and
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 16 of 125
Page - 17 - of 125
117. After, Plaintiff challenged Professor Jill Stowe’ blatant errors and due to subsequent changes
to Plaintiff’ letter grade, Duke allowed Plaintiff to continue in the WEMBA program.
118. Despite, Duke allowed Plaintiff to continue in the WEMBA program, Defendants along with
Plaintiff’ class representatives7
obstructed Plaintiff from freely participating in the class
discussions by asking Duke Professors to prevent Plaintiff from asking questions in the class.
This is in violation to Duke Policy.
119. Since, Defendants along with Plaintiff’ class representatives blocked Plaintiff from seeking
clarifications from professors, and interfering with Plaintiffs’ learning process and learning
ability, Plaintiff begins to post his questions in the Duke’ course on-line portal.
120. As soon Plaintiff begins to post his questions in the Duke’ course on-line portal, since 1st
week of August 2008, Sanjay Mishra, Sreedhar Manjigani, Guru Sarma, Rick Weiss, Douglas
Bashar and Amit Khare begins to ask Plaintiff not to post his questions in the Duke’ course
121. In response to Sanjay Mishra, Sreedhar Manjigani, Guru Sarma, Rick Weiss, Douglas Bashar
and Amit Khare’ demand, Plaintiff told to them because Defendants along with Plaintiff’
class representatives blocked Plaintiff from seeking clarifications from professors, and
interfering with Plaintiffs’ learning process and learning ability, Plaintiff has to seek his
clarifications by posting his questions in the Duke’ course on-line portal.
122. Despite, Plaintiffs’ reasonable explanation, Sanjay Mishra, Sreedhar Manjigani, Guru Sarma,
Rick Weiss, Douglas Bashar and Amit Khare insisted upon Plaintiff not to post any questions
or responses in the Duke’ course on-line portal.
123. Plaintiff believe that because, Defendant Moira Ringo told to Plaintiffs’ classmates that
Plaintiff lacks academic integrity and alleged past academic dishonesty, Sanjay Mishra,
Sreedhar Manjigani, Guru Sarma, Rick Weiss, Douglas Bashar and Amit Khare established
negative perception about Plaintiff, and with that perception, Plaintiff’ classmates shut-out
“Vamsi is illegal in this country”. “Vamsi engaged in money laundering business”; “Vamsi plagiarized during the
course”, “Vamsi is carrying a gun in the campus”; “Vamsi is a ‘B’ student”; “Vamsi is 3rd class student”; “Vamsi
is pimp”; and “Vamsi is gay”; “Vamsi, is using psycho stimulants”;
Dan Paschke, John D. Cooper, Kristofer Singleton, and Tim Barry
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 17 of 125
Page - 18 - of 125
Plaintiff from being visible to professors, because as per Duke’ policy being active in the on-
line in the Duke’ course on-line web portal, is also counts towards class participation, and
class participation get certain points towards final course score and Defendants don’t want
Plaintiff to get higher scores, hence blocked Plaintiff from participating in the course
124. On 15th September 2008, Plaintiff contacted Defendant Moira Ringo via email8
her as to why she is propagating negative information about Plaintiff. Nevertheless,
Defendant Moira Ringo didn’t respond to Plaintiff.
125. On 15th September 2008, Plaintiff contacted Rajiv Patnaik via email9
and asked him why he
is shutting-out Plaintiff. However, Rajiv Patnaik denied10
Plaintiff’ findings about him
shutting-out Plaintiff by telling that his comments are not directed towards Plaintiff, but
directed towards another Plaintiff’ classmate Uday Kumar.
126. Rajiv Patnaik’ verbal abuse is a classic example as to how Plaintiff’ classmates use another
classmate as his/her sidekick made verbal assaults and made insinuating verbal remarks
against Plaintiff in a mocking fashion way.
127. On 15th September 2008, Plaintiff contacted Guru Sarma via email11
and asked him why he is
shutting-out Plaintiff from participating in the class discussions. However, Guru Sarma
“Moira Ringo, throughout the 1st & 2nd semesters you have propagated negative information, with an intention
to afflict pain to me. Why did you do that? Who provided you that information? What is your source of
information? Do you want me to remind you about where, how and what did you say? I need a straight answer”.
“Rajiv Patnaik, Why are you trying to pass insulting comments? You know that "Chup Bhe" is a derogatory word.
Why should I shut my mouth? Who are you to ask me? You passed similar kind of comments in the first term and
you know that. What made you think that I will keep quiet?”
Hi Vamshi, that was supposed to be a joke and I was actually telling that to Uday and was not really directed at
you. Uday and I have a very informal relationship and we pass comments at each other all the time for fun. "Chup
be" is not always a derogatory comment and is a very commonly used term - especially between friends. Words
like "Chup be" and "Sala" are used very informally and very commonly and not always meant to insult people. They
of course can be used as an insult depending on the context and depends on the tone of the person. I apologize if
it was insulting to you because that was defintely not my intention. You are absolutely correct that I am no one to
tell you to shut up and I definitely did not say it to you. Honestly, I don't even remmber saying that to you earlier
and again it was never my intension to insult you. So hopefully you are able to put this behind you and do not take
this personally. Rajiv.”
“Guru Sarma, You have asked me not to post any comments on the bulletin boards. Do you know that it is
offensive? It is my right to express and communicate with fellow students. This is not the first time you passed
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 18 of 125
Page - 19 - of 125
by saying that he never said don’t post any discussions, but said spare him
and other students from the ton of messages.
128. It is self evident from the both Rajiv Patnaik and Guru Sarma’ responses, that they both
attempted to block Plaintiff from participating in the class discussions.
129. But by the end of September 2008, there were numerous false stories floating around Duke,
which severely impacted Plaintiff’ reputation. Among the rumors, the notable ones are
“Plaintiff is a Juvenile Delinquent”, “Plaintiff was implicated in murder cases” and “Plaintiff
engaged in money laundering business”.
130. By the end of September 2008, defendants’ psychological manipulation of Plaintiff through
subtle, indirect, or implied threats, lead the Plaintiff to hesitate to mingle with WEMBA
131. Right around that time, in September 2008, Defendant Brooke Balcom, several times, walk-
past Plaintiff and inappropriately hit Plaintiff with her hip or her upper body portion, when
Plaintiff standing in the line for the food or move in and out of the classroom during the class
132. Because there is so much hostility towards Plaintiff in the Duke Campus, Plaintiff didn’t say a
word to either Defendant Brooke Balcom or to Duke Administration, but took extraordinary
measure to avoid Defendant Brooke Balcom.
comments at me (and you know that). Alternatively, do you want me to remind you the situations? Why did you do
“Vamsi, I am totally sorry. I never said don’t post any. I said spare us from the ton of messages. C’mon man,
there was a period earlier this term, when the # of messages just went up sky rocketing and it was not possible to
follow the various posts. I am sorry that it was sounding offensive. But it almost came across as if you had all the
time to post, while many or at least I found it even difficult to read post (forget about writing any). It would have
been easy from your perspective when you get involved with the posts, but it becomes difficult to follow every
message on the boards amidst of the crunching assignments and exams. We may very well be partners in the next
term. You never know. But I should have been more clear and not jovial about it. Where else did I say this apart
from this weekend? I did mention in the computing lounge if there is a way to rank the various messages so that I
could make use of the ranking done by a majority of the classmates, rather than just by the # of posts in a thread.
But that was a constructive tool addition for everyone. It is not singled out against you. Okay if there has been any
other comments made by me let me know. It takes a strong character to come out and open up with me directly. I
am sorry and would like to maintain good terms with you. Guru.”
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 19 of 125
Page - 20 - of 125
133. While, Plaintiff took extraordinary measure to avoid Defendant Brooke Balcom, sometime in
October 2008, approached Plaintiff, when Plaintiff is waiting to catch a bus to go to airport,
in front of other students said that “you are full off it….”.
134. At that-time Plaintiff didn’t fully understand Defendant Brooke Balcom’ expression, but
guessed that she isn’t saying anything nice, and Plaintiff moved away from Defendant
135. When Plaintiff fly back to Philadelphia, PA, when he relayed it to his wife about Defendant
Brooke Balcom’ expression, and she explained it to him and Plaintiff understood that
Defendant Brook Balcom spreading slanderous messages about him in the student
136. Since October 2008, Defendant Brooke Balcom, has been proliferating among Plaintiff’
classmates about Plaintiff saying that, “he was an angry and unhappy person”, which made
other students to outcast Plaintiff.
137. While, Plaintiff is an outcast among the students, in the beginning of October 2008, Duke
assigned Plaintiff into a new team; and Plaintiff’ new team member are Navaneeth Latawa
and Defendants Robert Ball, Robert Ross and Shana Keating.
138. Plaintiff heard a rumor that Defendants Robert Ball, Robert Ross and Shana Keating, scuttle
Plaintiff and compel Duke to expel Plaintiff.
139. As soon new team is formed, Plaintiff’ new teammates Defendants Robert Ball, Robert Ross
and Shana Keating proposed to use new software applications that aren’t authorized by
140. Plaintiff objected to use software applications that aren’t authorized by Duke, because
Plaintiff purchased infrastructure to use Duke’ authorized software.
141. In addition, the software applications proposed by Defendants Robert Ball, Robert Ross and
Shana Keating don’t allow Plaintiff to know who are all present during a virtual team
meeting and any person sitting beside Defendants Robert Ball, Robert Ross and Shana
Keating can listen discussions.
142. In addition Plaintiff was worried that Defendants Robert Ball, Robert Ross and Shana Keating
covertly record Plaintiffs conversations and later use those conversations against Plaintiff.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 20 of 125
Page - 21 - of 125
143. Despite, Plaintiff raised his objections to use the software applications that aren’t authorized
by Duke, Defendants Robert Ball, Robert Ross and Shana Keating as majority dictated,
mandated and imposed their unilateral decision to use non authorized software upon
Plaintiff. Since then, Plaintiff was a reluctant participant in the team meetings.
144. In addition, Defendants Robert Ball, Robert Ross and Shana Keating shut-out Plaintiff’
reasonable suggestions as to how to tackle team projects.
145. In addition, Defendants Robert Ball, Robert Ross and Shana Keating’ body language and non
verbal gestures clearly suggests Plaintiff, that they are undermining Plaintiff’ credibility.
146. Plaintiff believe that Defendants Moira Ringo and Brook Balcom’ proliferation that Plaintiff
as an angry and unhappy person; lacks academic integrity and alleged adultery lead
Defendants Robert Ball, Robert Ross and Shana Keating to undermine Plaintiff’ credibility.
147. While this is going on, Sanjay Mishra made devious, deceitful and insinuating remarks about
Plaintiff’ academic integrity, so on 18th October 2008 Plaintiff contacted Sanjay Mishra and
asked him as to why he is making insinuating remarks about Plaintiff’ academic integrity. In
response, Sanjay Mishra denied13
that he ever made any insinuating remarks about Plaintiff’
148. Nevertheless, because Plaintiff unequivocally told to Sanjay Mishra about his insinuating
remarks about Plaintiff’ academic integrity, on 20th October 2009, Plaintiff and responded14
to Sanjay Mishra by saying that Plaintiff will do will do whatever is necessary to protect his
dignity and freedom.
“Hi Vamsi, I have no political profess like you so I will be direct. I am flabbergasted with your false confusing and
accusing phone call. I am feeling bit harassed. I have a great respect for your bold unique thinking style and your
entrepreneurship energy. If you like, similar to other people perception issues you have shared with our previous
team and me in the past, we can talk face-to-face next time we meet. Once I understand your concerns properly, I
promise work with you to resolve them. I am confident we can keep our friendship intact. As I also mentioned
during your phone call, you can take this matter to the Fuqua body, for proper due diligence. Your call. Thanks
“Thank you for your email. I sincerely believe that I have been harassed by the fellow students and you are one
of them. I am surprised by your response that I am harassing you. I will do whatever is necessary to protect my
dignity and freedom. Thank You, Vamsidhar”
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 21 of 125
Page - 22 - of 125
149. As soon as Plaintiff made it clear that he will do whatever is necessary to protect his dignity
and freedom, next day, on 21st October 2008, Jason Link started an on-line discussion about
on Duke’ web portal and personally enticed Plaintiff to respond to his posting about
150. Plaintiff was suspicious about Jason Link’ approach, and didn’t respond to Jason Link’
prodding to participate in his on-line discussion about guns on Duke’ web portal.
151. Nevertheless, there are very many Plaintiff’ classmates16
participated in the discussion and declared as to how many guns that they own and the size
of the bullets that they use and how recently that they fired those guns.
152. Because, Plaintiff didn’t participate in Jason Link’ on-line discussion about guns on Duke’
web portal, Jason Link along with Defendant Pete Walton, Kristopher Singleton, Doug
Basher, Amit Khare, John Dohnal and Greg Valentine personally approached Plaintiff and
asked Plaintiff to come to a firing range. But Plaintiff told to Jason Link that he isn’t
interested to go a firing range.
153. Because, there are very many classmates through their behavior, verbal assaults, and non-
verbal gestures made it known to Plaintiff that, they are committed to make Plaintiff’ life in
and out of Duke miserable, Plaintiff believed that Defendant Pete Walton along with Jason
Link, Kristopher Singleton, Doug Basher, Amit Khare, John Dohnal and Greg Valentine had
personal animosity, hatred and anger against Plaintiff and suspected about the motives
behind the on-line discussion about guns and avoided on-line discussion about guns and
refused to go to shooting range along with Plaintiff’ classmates.
154. Plaintiff and suspected the motives behind the on-line discussion about guns, is because as
to how the on-line discussion about guns were initiated and the online comments made by
several of his classmates, indirectly referring to Plaintiff’ casual comments about his liking
towards gold wrist watches made by renowned watch makers like ‘Patek Philippe’ and
Subject: I keep my hand on my gun, cuz they got me on the run Don't think I've seen this discussed
yet...politics aside...if you were looking for a first firearm, what would be your choice? Basically, I'm looking for a
gun to keep around the house and take to the range (mainly for the range)...Opinions?
John Espey, James Morgan, Kristofer Singleton, Dan Paschke, Tim Barry, Nat Hawkins, John Cooper, Jason
Sundberg, John H. Dohnal
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 22 of 125
Page - 23 - of 125
‘Audemars Piguet’ and sarcastically asking Plaintiff to wear those watches and come to
155. Few days later, in October 2008, Duke organized a Halloween party for WEMBA students
and Plaintiff was reluctant to participate in the class functions, due to his classmates’
personal animosity, hatred, anger and slanderous verbal assaults against Plaintiff.
156. However, Duke Administration organized the Halloween party in the R. David Thomas center
at the dinner hall, when dinner is served for the WEMBA students and it was inevitable to
Plaintiff to come across his classmates’ at Halloween party.
157. While, Plaintiff was alone, sitting quietly and taking his dinner and at that time Jason
Sundberg dressed like a “pimp” approached Plaintiff along with other students and told to
Plaintiff that his dress is suitable for “Vamsi’ real life”.
158. Then, Plaintiff make it known to Jason Sundberg that it isn’t right to make a parallel to his
party dress and to Plaintiff real life, because throughout the world pimp17
draw a seriously
negative attention in the society and moved away from Jason Sundberg along with dinner
plate and sit at a different location in the diner hall to complete his dinner.
159. As soon, Plaintiff relocated to a different seat, Pradeep Rajagopal gathered few students
around Plaintiff and instigated another student Ashish Chhabra to call the Plaintiff
something like “Madar Chod” or “Mai Chod” in Hindi. Plaintiff didn’t understand the
meaning of Ashish Chhabra’ comment, but had a feeling that it must mean something
terrible, so Plaintiff asked Ashish Chhabra the meaning of his Hindi comment. At that time,
Pradeep Rajagopal interjected and told the meaning of that Hindi comment is “mother
fucker” in English.
160. Right after that, Gregory Valentine gathered few students around Plaintiff and started
talking about Plaintiff’ performance in Probability and Statistics examination and told to the
Plaintiff that he knew that “Vamsi is a ‘B’ student”. Then, Plaintiff enquired Gregory
A pimp is an agent for prostitutes who collects part of their earnings. This act is called procuring. The pimp may
receive this money in return for advertising services, physical protection, or for providing, and possibly
monopolizing, a location where she may engage clients.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 23 of 125
Page - 24 - of 125
Valentine as, “what made you to talk like that?”. Then Gregory Valentine told to Plaintiff
that, “I knew your grades”. Then, Plaintiff enquired Gregory Valentine as, “how did you
come to know my grades?”. But Gregory Valentine’ response was vague and abrupt.
161. Gregory Valentine knowing about Plaintiff’ grades is in violation to the Family Educational
Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), because he don’t have
any need to know about Plaintiff’ grades.
162. Right after that, Plaintiff moved his seat and went outside of the R. David Thomas Center
dinner hall to complete his dinner. At that time, Defendant Peter Walton gathered few
students around Plaintiff and started reiterating Jason Sundberg, Pradeep Rajagopal and
Ashish Chhabra’ derogatory remarks.
163. Then, Plaintiff told to Defendant Peter Walton “leave me alone” and in response, Defendant
Peter Walton said to Plaintiff, “You are a 3rd class student” in front of other students.
164. Plaintiff immediately reported to Duke Administration about obscene language and conduct
of Jason Sundberg, Pradeep Rajagopal and Ashish Chhabra. Nevertheless, Duke
Administration didn’t even respond to Plaintiff.
165. While Plaintiff has been shut-out in the class and outside the class by the defendants,
throughout November 2008 and December 2008, Defendants Robert Ball, Robert Ross and
Shana Keating shut-out Plaintiff within the Duke’ learning team and discarded every
contribution made by Plaintiff towards Duke course work and refused to include Plaintiff’
contribution in the class project, without providing any reason.
166. On 9th January 2009, Plaintiff questioned the reason for not including Plaintiff’ contribution
in the class project, Defendant Robert Ross told to Plaintiff in front of Defendants Robert Ball
and Robert Ross that, “you dug a hole for yourself to get buried”, while very many students
prominently looking at Defendant Robert Ross and Plaintiff.
167. Immediately Plaintiff became alarmed because just a day before, on 8th January 2009,
Plaintiff’ manager at Wyeth used the exact same phrase said the same phrase “you dug a
hole for yourself to get buried” against Plaintiff.
168. So at that time, Plaintiff asked the Defendant Robert Ross, “What made you to talk like
that?” Instead answering Plaintiff’ question, Defendant Robert Ross further accused Plaintiff,
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 24 of 125
Page - 25 - of 125
that “you have plagiarized during your undergraduate program and probably you plagiarize
now”; in response, Plaintiff asked Defendant Robert Ross, “why do you say that, I have
plagiarized and who told you that I have plagiarized in my undergraduate program?”
Defendant Robert Ross response was dismissive, vague and abrupt.
169. At the same time, Defendant Shana Keating made several hand and facial gestures in a
mocking fashion-way along with Defendant Robert Ball, while several classmates are
watching her by conveying a meaning that Plaintiff is not intelligent.
170. Immediately after the conversation, Defendant Robert Ross discarded all of Plaintiff’
contributions to the Managerial Accounting course work and submitted final paper as per
Defendants Robert Ball, Robert Ross and Shana Keating’ agenda and didn’t event explain to
Plaintiff, as to why they are discarding Plaintiff’ contributions.
171. On 9th January 2009, evening, Plaintiff tried to make peace with other students, so Plaintiff
along with other students Anj Balusu and Rajiv Kolagani went outside the Duke to have their
172. By the time Plaintiff, Anj Balusu and Rajiv Kolagani went to the restaurant, Jamie Thompson
and Defendant Brooke Balcom having dinner at that restaurant; restaurant asked Plaintiff,
Anj Balusu and Rajiv Kolagani to sit at an adjoin table to Jamie Thompson and Defendant
173. Rajiv Kolagani and Anj Balusu having conversations with Jamie Thompson and Defendant
Brooke Balcom and during those conversations, Rajiv Kolagani made accusatory style verbal
remarks against Plaintiff, that he had a police “Rap Sheet”. Immediately, Plaintiff denied
Rajiv Kolagani’ statement and left the dinner table.
174. After, returning from the restaurant, while Plaintiff quietly sitting in the R. David Thomas
Center’ lounge area, Amit Khare gathered several classmates and started asking questions
about Plaintiff’ business.
175. In response, Plaintiff told to Amit Khare, that he don’t want to answer his questions. In
response, Amit Khare made accusatory style verbal remarks against Plaintiff, that “none of
the classmates believe you”. While Plaintiff is dismayed with Amit Khare’ accusation,
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 25 of 125
Page - 26 - of 125
Pratibhash Chattopadhyay made a depreciatory verbal remark attributing to Plaintiff, that
“he is low self esteemed person”.
176. Plaintiff doesn’t know how to respond and tackle the defendants and his classmates verbal
mauling and left to his room without responding to Amit Khare and Pratibhash
177. Next day, on 10th January 2009, Plaintiff tried to make peace with Defendants Robert Ball,
Robert Ross and Shana Keating, and met them during coffee break. At that time, Defendant
Robert Ross made accusatory style verbal remarks against Plaintiff that “you are a load on
the team and not contributed as much I contributed”. At that time, Plaintiff responded to
Defendant Robert Ross that “it is not a fact, it is your opinion and you are entitled to have an
opinion” and Plaintiff left to classroom without waiting for Defendant Robert Ross response.
178. On 10th January 2009, after noon, when Plaintiff coming back from break-room into the
class, Defendant Brooke Balcom, inappropriately hit Plaintiff with her hip and immediately
Plaintiff was upset with Defendant Brooke Balcom and asked, “why did you say to me ‘you
are full of it’”. Defendant Brooke Balcom without responding to Plaintiff walks past Plaintiff
and showing an upbeat gave a high five to Defendant Daniel Paschke.
179. On 10th January 2009, after classes are over, Defendants Brooke Balcom, Daniel Bennion,
John Cooper, Daniel Paschke, Robert Ross, Robert Ball, Nathaniel Hawkins, Peter Walton,
Moira Ringo and Shana Keating in an organized fashion fabricated and unveiled a dramatic,
exaggerated and sensationalized story against Plaintiff to get an immediate attention from
Duke Administration and to compel Duke Administration to expel Plaintiff from Duke.
180. On 10th January 2009, Defendant Daniel Paschke made a oral complaint against Plaintiff to
and wrote an email complaint to John Gallagher19
and Alaina Filkin20
exaggerating Plaintiff’ casual enquiry with Defendant Brooke Balcom as a verbal
Assistant Dean, Executive MBA Programs, The Fuqua School of Business, Duke University
Associate Dean, Executive MBA Programs, The Fuqua School of Business, Duke University.
Assistant Director, Executive MBA Programs, The Fuqua School of Business, Duke University
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 26 of 125
Page - 27 - of 125
; and dramatized Defendant Brooke Balcom’ reactions to Plaintiff’ casual
181. In addition, Defendant Daniel Paschke made a big deal out of simple Plaintiff’ enquiry and
catastrophized simple event of Plaintiff’ gentle enquiry to Defendant Brooke Balcom as to
why she is spreading accusatory style remarks against Plaintiff.
182. In fact, when Plaintiff attempted to enquire Defendant Brooke Balcom, she simply ignored
and walk past Plaintiff and in an upbeat gave a high five to Defendant Daniel Paschke. But
Defendant Daniel Paschke dramatized, exaggerated and sensationalized by lying that
Defendant Brooke Balcom is visibly upset to a point of crying and shaking.
183. On 11th January 2009, Defendant Daniel Paschke wrote another email22
to John Gallagher
and Alaina Filkin by exaggerating a single verbal enquiry of Defendant Moira Ringo as a
never-ending pattern of Plaintiff’ ‘run-in’ behavior.
“John & Alaina, It was brought to the class reps attention at the end of this weekend that one of our classmates
has had an altercation with more than one student and some folks are beginning to feel uncomfortable with this
particular student. I have firsthand knowledge from one student for sure that there was an incident towards the
end of the day that left a student visibly upset to the point of crying and shaking a little bit. Cleary this is not
acceptable and violates the learning environment we are all interested in having while at Fuqua. Several other
students approached me today with some other anecdotal stories regarding this same person. Obviously this needs
to be addressed but is something the class reps feel strongly we need input/action/guidance from the
administration on. I have left a message on the WEMBA voicemail hotline (I believe it was Catherina Amatto's
voicemail) regarding this matter as well. We are requesting a conference call as soon as possible to discuss possible
next steps. I can be reached at 919.740.4449 if needed and waiting until Monday is not necessary if see fit. I am
happy to discuss over the phone tonight or Sunday if this is received. Thank you for your prompt attention in this
“John and Alaina, upon beginning to ask questions in regards to Vamisdhar, students who I spoke with
mentioned other students who the knew had negative encounters with Vamisdhar. Followed up with as many of
those students as I could in a vague way to give them a chance to talk about their encounter. Moira Ringo is one of
those students who called me this evening and was very glad to know we have involved you both to look into his
behavior. She forwarded me the below email that was sent to her from Vamisdhar a few months ago that she
originally choose to ignore but did save a copy of. She also was confronted by him this past weekend and witnessed
the confrontation with Greg Valentine. - Both her account of what happened and the original email are below in
this string of emails. Please include her in your list of potential students to talk with regarding his behavior. l She
told me she would be more than happy to discuss her interactions with either of you but is very glad that some
action has been taken as she is not comfortable with his behavior right now. I believe there is a bit of a cry for help
here from the pattern I am seeing develop. Again, thank you to you both for taking this seriously as I believe we
have a fellow classmate who is in need of some help. Please let me know if you need anything else from me”
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 27 of 125
Page - 28 - of 125
184. It is evident that Defendant Daniel Paschke attempted to manipulate John Gallagher and
Alaina Filkin’ perception about Plaintiff through deception, by dramatizing, exaggerating,
sensationalizing and fabricating facts.
185. In addition, on 10th January 2009 when John Gallagher called Defendant Daniel Paschke to
find more information about his alleged verbal confrontation, Defendant Daniel Paschke
didn’t say single fact that as to how he himself harassed Plaintiff by out-casting and shut-out
Plaintiff in the class.
186. In addition, Defendant Daniel Paschke lied to John Gallagher that he had seen Defendant
Brooke Balcom return to class where she appeared shaken up and emotional following the
last class break of the day, when in fact Defendant Brooke Balcom was in upbeat and gave a
high five immediately after Plaintiff asked why she said that ‘you are full of it’.
187. In addition, Defendant Daniel Paschke lied to John Gallagher that Defendant Brooke Balcom
reported to him that she had a verbal confrontation with Plaintiff during the break and it left
her shaken and crying.
188. In addition, Defendant Daniel Paschke lied to John Gallagher, that Defendant Brooke Balcom
was confused and unsure what it was that Plaintiff was accusing her of, when in fact
Defendant Brooke Balcom was in upbeat and gave a high five immediately after Plaintiff
asked why she said that ‘you are full of it’.
189. In addition, Defendant Daniel Paschke told to John Gallagher, when Defendant Daniel
Paschke shared Defendant Brooke Balcom’ reported incident with other class
representatives, some of them reported having heard comments about Plaintiff’ behavior in
190. On 11th January 2009, Defendant Daniel Paschke wrote another email to John Gallagher
after he spoke with John Gallagher and added even more dramatic, exaggerated and
sensationalized information by dubbing Plaintiff’ simple enquiry as overly aggressive23
“John, Thank you for calling me today to discuss the incidents with a few students this weekend. Per our
conversation, the student who was overly aggressive with others was Vamsidhar Vurimindi. The other students we
discussed you speaking with are:
1) Brooke Balcom - female student who I spoke with first hand and was crying/shaking after the
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 28 of 125
Page - 29 - of 125
191. In addition, on 11th January 2009, Defendant Daniel Paschke wrote an email24
to other Class
in a tone and manner that Duke Administration affirmed his
catastrophization of simple Plaintiff’ enquiry and suggested to other Class representatives to
continue to shut-out Plaintiff in the Duke Campus.
193. On 11th January 2009, Defendant Moira Ringo ruthlessly is having no qualms about causing
harm to Plaintiff, lied26
about Plaintiff’ interactions with her.
2) Greg Valentine - student who I also spoke with first hand who had a less aggressive encounter but one
none the less during the same break
3) Daniel Bennion - student who said 4 or 6 people at his lunch table had received confrontational emails
from the same individual
4) Nat Hawkins - student who first shared the Brooke story and other details with me and asked that I involve
the class reps and/or administration
Per our discussion, I will give Brooke and Greg a heads up you them but will let your discussions lead you from there
regarding other names. I just wanted you to have them in writing in case you felt you needed them. Thanks again
for your attention to this matter and please let us know how we can help going forward.
Class reps, John has asked that we keep our eyes and ears open for more information around this topic and share
anything we hear about. Other than that, he plans to make contact with Brooke and maybe Greg and decide were
to go from there. His discussions with those 2 will be what helps him decide if/when he contacts Vamisdhar directly
or what the next steps are. Let me know if you have any questions. DP”
John D. Cooper, Kristofer Singleton, and Tim Barry
Here is the e-mail I got from Vamsi back in September. At this point in time, I had spoken to him about 10
minutes total and even had to look him up in the directory to figure out who he was. I wrote back and asked him to
explain this e-mail, and he never responded. After the e-mail, I avoided speaking to him because he seemed to
make poorly informed and disrespectful statements with others in public forums. On Saturday, he approached me
in the break room and stated that in was applying my ethical standard at work; he was concerned about the future
of my company because he 'had skin in the game.' I responded that health care was pretty unique in terms of
ethical standard, to which he responded with a very energetic list of his qualifications to make the statement that
he had. He appeared to be picking a fight with me, so I walked away and went to class. A few hours later I saw him
talking to Greg in the hallway in a raised tone. When Greg and Derek came into the classroom later, they were both
stunned and Greg was upset. Greg was on-deck to present in Econ class, and I did not want this to shake him. I
assured Greg that Vamsi had picked a fight with me earlier that day and that was just how he was. Robert Ross
came over and told Greg that Vamsi had another interaction with a student as well. The e-mail that he sent me and
the argument he had with Greg are not within normal behavior. Picking two tights with different students within a
few hours is also not typical. Be careful how you approach this because I think there is more going on here than a
difficult person, and I do not want you or the student reps to chew up unnecessary energy on something that may
not be able to be reasoned out. If I were in your shoes, I would want to see an option where he's given the feedback
and advised to get some counseling/evaluation. He asked to speak with me after class on Friday, and I refused. I
plan to simply avoid him. I will keep you updated if he e-mails me or tries to pick another fight with me, but I do not
expect it to be a problem. Moira”
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 29 of 125
Page - 30 - of 125
194. On 12th January 2009, when John Gallagher called Defendant Brooke Balcom, she lied,
exaggerated and sensationalized27
Plaintiff’ simple casual enquiry as an angry conversation.
195. In addition Defendant Brooke Balcom lied28
to John Gallagher that she is trying to
communicate with Plaintiff in a friendly manner, when in fact Defendant Brooke Balcom
disregarded and ignored Plaintiff’ enquiry and walk past Plaintiff.
196. In addition Defendant Brooke Balcom lied29
exaggerated and sensationalized to John
Gallagher that she was shaken and cried, when in fact she gave a high five to class
representative, for successfully upsetting the Plaintiff.
197. In addition Defendant Brooke Balcom malign and smear Plaintiff’ reputation by attributing a
by Plaintiff to John Gallagher.
198. On 12th January 2009, when John Gallagher called Defendant Nathaniel Hawkins malign and
Plaintiff’ reputation by attributing simple and casual Plaintiff’ email enquiry to other
students as “run-ins” to John Gallagher.
199. On 12th January 2009, when John Gallagher called Defendant Nathaniel Hawkins unveiled a
sensational fabricated story32
against Plaintiff that, Plaintiff himself told to other students
that he carry a gun at all times in the Duke Campus.
“Vamsi had come up to me during the last break of the day on Saturday and confronted me with an accusation
that I had called him "full of it" in some context in the previous term. I thought he was joking with me and
responded accordingly - laughing and chatting. I did not fully understand what Vamsi was saying, but I tried to joke
and treat it as a light conversation of some kind. But Vamsi remained very focused, had a clear angry tone, and
"looked right through me and past me" with his gaze”.
“Vamsi did not pick up on my body language or facial expression through which I am trying to communicate a
friendly and casual tone, and a confusion about what he was referring to. As the conversation moved on and Vamsi
remained in his posture, she became more and more unsettled. Vamsi retained an angry tone and demanding
attitude. Vamsi was clearly upset with me and I did not understand why. I told him that he should not speak to her
this way, and that she did not want him to speak with her again”.
“I felt shaken and upset, and cried while returning to class.
On some level I am concerned that Vamsi was an angry and unhappy person who had now focused on me”.
“I never engaged with Vamsi, nor witnessed any interactions personally. But, I heard that other students had
found him difficult. Vamsi seems to be somewhat of an outcast in the class, there had been other reports of "run
ins" with Vamsi”
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 30 of 125
Page - 31 - of 125
200. Simultaneously, Defendants Robert Ross, Robert Ball and Shana Keating intensified their
malign and smear campaign against by fabricating fictitious stories which directly affect
Plaintiff’ reputation by saying that Plaintiff’ daily business conduct is "hanky panky" implying
that Plaintiff’ business conduct is dubious and suspicious.
201. In addition, Defendants Robert Ross, Robert Ball and Shana Keating malign and smeared
Plaintiff’ reputation by fabricating fictitious stories by saying that Plaintiff’ daily business
conduct is "bribing city hall" implying that Plaintiff engaged in corrupt business practice.
202. In addition, Defendants Robert Ross, Robert Ball and Shana Keating malign and smeared
Plaintiff’ reputation by fabricating fictitious stories that Plaintiff’ daily business practice
involve with employing “goons” implying that Plaintiff engaged goons in his daily business
203. In fact and indeed Defendants Robert Ross, Robert Ball and Shana Keating’ all fabricated
fictitious Plaintiff’ daily business conduct is a big lie, and Plaintiff believe that Defendants
Robert Ross, Robert Ball and Shana Keating along with other defendants fabricated fictitious
stories against Plaintiff to rationalize their tortious and abusive conduct against Plaintiff.
204. In addition, between 11th January 2009 and 14th January 2009, Defendants Robert Ross,
Robert Ball and Shana Keating filed a Duke Honor code violation against Plaintiff with
Defendant Barnes baron and Harold Hong, despite it is clear to them that Plaintiff didn’t
plagiarize his work.
205. After Defendants Robert Ross, Robert Ball and Shana Keating filed an honor code violation
against Plaintiff and found by themselves that Plaintiff didn’t plagiarize his work, and drop
the idea to initiate a formal Duke Honor code violation against Plaintiff, discarded all
Plaintiff’ contributions into team course work project and when Plaintiff asked as to why
they have discarded Plaintiff contributions, Defendants Robert Ross, Robert Ball and Shana
Keating falsely accused Plaintiff has ‘plagiarized’ his course work.
206. On 14th January 2009, with the backdrop of the foregoing baseless allegations and
accusations against Plaintiff by the defendants, John Gallagher initiated a telephone
conversation with Plaintiff and enquired about Plaintiffs interactions with defendants.
“Defendant Peter Walton reported that Vamsi had told other students that he carried a weapon at all times”.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 31 of 125
Page - 32 - of 125
207. John Gallagher questioned Plaintiff about the alleged ‘verbal assault’ against Defendant
Brooke Balcom and Plaintiff told to John Gallagher, that Defendant Brooke Balcom verbally
assaulted Plaintiff by saying “you are full of it” in front of several people and to that effect
Plaintiff casually enquired why she is verbally assaulting him.
208. On 14th January 2009, after enquiring about Defendant Brooke Balcom’ baseless and false
accusation about Plaintiff’ verbal assault, John Gallagher asked Plaintiff “Did you carry a gun
on the campus?” Plaintiff was shocked for that question and replied that, “I didn’t carry a
gun on the campus”. In addition, Plaintiff reminded John Gallagher that, “I travel to Duke by
flying through the commercial airline and passing security checks and it is impossible to carry
a gun in the luggage”.
209. In addition, Plaintiff told to John Gallagher that, “on 23rd and 24th January 2009, I need to
write Term 3 final exams and whoever complained that I am carrying a gun on the campus is
a deliberate attempt to distract me from preparing my examinations”
210. Despite Plaintiff told numerous times to Duke Administration that Defendants are harassing
Plaintiff and demanded to impose Duke’ Anti-Harassment Policy and create a congenial
atmosphere to Plaintiff, Duke Administration never impose Duke’ Anti-Harassment Policy,
but after Defendants Brooke Balcom, Daniel Bennion, John Cooper, Daniel Paschke, Robert
Ross, Robert Ball, Nathaniel Hawkins, Peter Walton, Moira Ringo and Shana Keating
collectively filed fabricated baseless complaints, Duke Administration compelled Plaintiff to
attend for an interrogation before Bill Boulding33
on 23rd January 2009.
211. Based on the discovery documentation, it is clear that Defendants Brooke Balcom, Daniel
Bennion, John Cooper, Daniel Paschke, Robert Ross, Robert Ball, Nathaniel Hawkins, Peter
Walton, Moira Ringo and Shana Keating black-mailed Duke Administration by rising public
dissention by sending bulk emails and publically posting in the Duke’ online portal, where
Plaintiff don’t have access to compel Duke Administration to expel Plaintiff from Duke; and
in order to appease the defendants, Duke Administration visibly interrogated Plaintiff
before the defendants and thereby implying that Duke Administration affirming defendants
Senior Associate Dean, Executive MBA Programs, The Fuqua School of Business, Duke University
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 32 of 125
Page - 33 - of 125
abusive conduct against Plaintiff and give a free hand to defendants to continue the same
abusive conduct and harassment against Plaintiff.
212. Despite, on 14th January 2009, Plaintiff assured John Gallagher that he didn’t carry a gun on
the campus, on 15th January 2009, Katherine Amato on behalf of Duke, filed a police
complaint against Plaintiff bearing report # 2009-0019534
by falsely accusing Plaintiff is
confronting with defendants apparently for no reason and further made false accusation
against Plaintiff based on a fabricated allegation by the Defendants Peter Walton and
Nathaniel Hawkins that Plaintiff told to Defendant Peter Walton that he carries a gun in the
213. After Katherine Amato filed a police complaint against Plaintiff, on 15th January 2009,
Katherine Amato contacted wrote an email to Mark Brown35
and enquired him about
Plaintiff’ interactions with him and about his concerns with the defendants.
214. In response, Mark Brown told36
to Katherine Amato that Plaintiff told him that he has a
problem with just going along with ideas that he does not believe in and he has not learned
the skill of the "social white lie".
“On 01/15/09 at 1625 hours I responded to speak with Ms. Amato in person. Ms. Amato is the Assistant Dean to
Fuqua's Executive MBA Program. She wanted to report suspicious activity about one of the executive students. Ms,
Vurimindi or "Vamsy" as he is called commutes to Duke on select weekends and stays at the R David Thomas
Center and attends classes at Fuqua. Vamsy has been confronting classmates for apparently no reason confronting
them saying, “you don't like me" or "Why are you talking about me or "Do you have a problem with me”. He has
locked several students into these confrontations until they become visibly upset. These types of confrontations
have also been occurring via emails. Most of the students Ms. Amato has talked to stated that because Vamsy is
native born in India that most of these problems have been cultural misunderstandings. But on the same note the
students are concerned and the behavior has begun to interrupt their ability to participate in the program.
Another concern is one of the rumors that have been passed among some of the students about Vamsy telling
someone that he carries a gun. When Ms. Amato attempts to identify who heard him say this and what was said
the students all say that they heard it from some one else. She has yet to identify if this is a legitimate concern or
just rumor. I gave Ms. Amato some guidance on the law and general crime prevention. I also offered our assistance
with any administrative decision they make regarding Mr. Vurimindi to include officer presence, directed patrols,
and trespass. She said she needed to talk to her senior administrator and would contact us back. I gave her a
contact card. I checked for active warrants for Mr. Vurimindi and found negative results”.
Director, Management Communications Ctr, The Fuqua School of Business, Duke University
“Kathie, I'm in the lounge in London, and I am about to be called to board in a few minutes. I had quite a bit of
contact with Vamsi as the program began for him. He spoke with me about help with English pronunciation, and he
seemed to have quite a few issues with people skills. He said that in this country and even now , he has a problem
with just going along with ideas that he does not believe in. He has not learned the skill of the "social white lie," he
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 33 of 125
Page - 34 - of 125
215. After Katherine Amato filed a police complaint against Plaintiff, on 19th January 2009,
Katherine Amato called Defendant Peter Walton and enquired him about him saying to
Defendant Nathaniel Hawkins that Plaintiff brought a gun onto Duke Campus.
216. On 19th January 2009, Defendant Peter Walton further lied and sensationalized his
fabricated story and further implicated Plaintiff by false statements that Plaintiff told him
that he is carrying a pistol in his coat37
; Plaintiff told him that he don’t believe in US law;
Plaintiff told him that Plaintiff thinks that he is above law, because he belongs to a high level
social and political structure.
says, and he has very frequent conflict with people in his family, in his business dealings, and perhaps on his team,
though that aspect of this has not come up. I have not spoken with him in any substantial way in months. He
seemed to think that the school should be a resource for him as an advisor for his real estate business dealings. I
tried to make clear to him that such services were not part of the program. I gave him readings and offered
counseling on the interpersonal skills, but I think he just got too busy. The last email I got from him was in April. I
did not see any issues on his team (at least on the surface), but I would not be surprised if he had some. He seems
to be under a lot of pressure to succeed in his business, and the stress gets to him. He is not that easy to
understand, and he oscillates between blaming himself for his shortcomings and blaming others. That's what I
know. I would be happy to reach out to him if there are issues. Regards, Mark”
“I spoke with Pete Walton today to try and learn more about whether or not Vamsi may have been bringing a
weapon onto campus. Pete related an incident which occurred in either late September or October. Pete said he
was walking outside and ran into Vamsi speaking with Eugene White. Pete said it was a very warm evening and
Vamsi was wearing a very heavy coat, like a trench coat. Pete said he stopped to speak with Vamsi and Eugene and
during the course of the conversation he asked Vamsi why he had on a heavy coat on such a warm evening. Vamsi
responded that he was carrying a pistol in his coat. When Pete asked why he was carrying a pistol, Vamsi explained
("gave him a history lesson" was the phrase Pete used) that in India only individuals at a certain high level within
the political and social structure were allowed to carry weapons and that he, Vamsi, fell into that group. He
indicated he had carried a pistol when he was in India and was continuing to do so in the United States. When Pete
asked him further if he was aware of US laws about carrying a concealed weapon, Vamsi indicated it did not matter
and he was not concerned about those laws as he did not believe they applied to him. Pete and Vamsi engaged in a
bit more conversation about weapons and how Vamsi needed to be obeying US laws as well as safety procedures
with a weapon. Pete felt in this exchange Vamsi indicated an arrogance or air of superiority relative to US laws, as
well as a relatively low knowledge about firearms and firearm safety. At this juncture, Pete ended the conversation
and walked away. Pete did not actually see the pistol. Pete began the conversation with me by indicating that he is
a "firearms enthusiast," who knows a great deal about weapons, the laws governing their use in the US, and the
dangers of carrying a loaded weapon. Pete was dismayed by Vamsi's attitude about carrying a weapon, particularly
when he is assuming it is loaded. I have sent an email to Eugene White to see if I can speak with him. Bill, based on
what you heard from the Duke police, should I contact them and add this information to their report on file?
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 34 of 125
Page - 35 - of 125
217. As soon, Katherine Amato called Defendant Peter Walton to gather more information about
Plaintiff bringing a gun onto campus, Defendant Peter Walton and John Espey restarted
discussion about guns and shooting range and encouraged Plaintiff to participate in the
218. Defendant Peter Walton without informing Plaintiff that Duke Administration called him and
enquired him the alleged Plaintiff bringing a gun onto Duke campus, and restarted another
discussion about guns and shooting range on 19th January 2009, by saying “Dave, Pete, and
I went to the range this weekend. Let me just warn you ahead of time, if you are thinking of
breaking into a house in the Charlotte area, I would recommend avoiding Pete's. The best
shot of the day came when he put the gun in his non-shooting hand, moved the target 50
feet away, and in one shot put one right between the eyes.”; “Don’t let Espey fool you. His
bullets are twice the size of mine and he uses hollow points; might have a problem finding
your entire mid-section when he pulls the trigger.....lol. And, your right Scott, I have never
219. After the fact, Plaintiff believe that the timing of Defendant Peter Walton starting original
discussion about guns in October 2008 and restating discussion about the Guns in January
2009, is to create an impetus and alibi to file a complaint against Plaintiff with an intention
to compel Duke to expel Plaintiff.
220. After, Defendant Peter Walton ended his encrypted message and after Plaintiff didn’t
responded to Defendant Peter Walton’ discussion about guns and shooting range, on 21st
January 2009, Katherine Amato called Eugene White and enquired him about the alleged
complaint that Plaintiff bringing a weapon onto campus.
221. After the fact, Plaintiff suspicious about the timing of Katherine Amato calling Eugene White;
Katherine Amato called Eugene White after Plaintiff didn’t respond to Defendant Peter
Walton’ discussion about guns and shooting range. Katherine Amato could have spoke with
Eugene White on 19th January 2009, that same day that she spoke with Defendant Peter
Walton, but she waited until 21st January 2009.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 35 of 125
Page - 36 - of 125
222. Plaintiff believes that Katherine Amato waited till the time that Duke Administration that
Plaintiff wouldn’t respond to Defendant Peter Walton’ discussion about guns and shooting
223. On 21st January 2009, in response to Katherine Amato’ enquiry, Eugene White recollected
that the incident occurred in November 200838
and when Plaintiff and Eugene White are
talking in the Duke Campus, Defendant Peter Walton joined them and asked Plaintiff that
“Vamsi, you look like a hit man in that coat. Are you carrying a concealed weapon?". “In
response, what appeared to be teasing comments started by Pete Walton, Vamsi in a very
joking manner told to Peter Walton that he was carrying a concealed weapon inside the
224. Interestingly, Eugene White also didn’t disclose to Plaintiff that Katherine Amato called her
and enquired about alleged complaint that Plaintiff bringing a weapon onto campus.
225. On 23rd January 2009, Plaintiff was interrogated by Bill Boulding, and during the
interrogation, Bill Boulding characterized Plaintiff as a “as a risk” and compared Plaintiff with
the Virginia Tech shooter that killed 32 people.
226. On 23rd January 2009, Plaintiff asked Bill Boulding why he is conveniently ignoring the fact
that Plaintiff has been a target for the harassment by the defendants and ignoring the
defendants who publicly discussed about the guns that they own and the size of the bullets
“I spoke with Eugene on Tuesday, about the conversation he participated in where Vamsi and Pete Walton
discussed Vamsi carrying a pistol. Eugene's recollection was that the incident occurred in November, the weekend
of Global graduation. The majority of the Weekend students were staying at the Washington Duke, but a small
number of students (part of the Thursday night stay group) were staying in the Thomas Center. It was a per diem
night and Eugene said he and Vamsi had just returned from eating at the noodle restaurant and were standing
outside in the breezeway talking. While it was warm, it had been raining/threatening rain, so Vamsi had on a
trench coat. When Pete came up to speak to them, he commented on Vamsi's coat, saying something along the
lines of "Vamsi, you look like a hit man in that coat. Are you carrying a concealed weapon?" Vamsi responded, in
what Eugene took to be a very joking manner, that he was carrying a concealed weapon inside the coat. Vamsi
then went on to elaborate that he used to carry a pistol when he was in India. Eugene said that Vamsi repeated this
statement on Saturday, still in a joking manner, that he was carrying a gun. Eugene feels very strongly that Vamsi
was joking, in response to what appeared to be teasing comments started by Pete Walton. Eugene evidently knows
Vamsi fairly well and indicated that because of the language and cultural differences between Vamsi and some of
his classmates, he could he could see where someone would not understand that Vamsi was joking”.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 36 of 125
Page - 37 - of 125
that they like to use and how recently that they fired the guns; and could potentially pose
more risk than Plaintiff. Nevertheless, Bill Boulding answer was vague and abrupt.
227. On 24th January 2009, the last day of the Term 3 and after Plaintiff has been interrogated by
Bill Boulding, when Plaintiff walking towards the shuttle bus to airport, Defendant Moira
Ringo purposefully approached Plaintiff and said that “this is the last trip for you to Durham,
NC”. At that time, Plaintiff asked the Defendant Moira Ringo, “What you mean?” At that
time, Defendant Moira Ringo response was vague, abrupt, and dismissive.
228. On 24th January 2009, to avoid Defendant Moira Ringo, Plaintiff jumped into Eugene White
car and he took Plaintiff to a local Bar & Restaurant, where Plaintiff’ classmates usually hang-
out. As soon, Plaintiff entering into the bar, Kevin Guisti approached Plaintiff and pulled off
Plaintiff’ blazer and searched Plaintiff’ coat pockets and Kevin Guisti didn’t find a gun in
Plaintiff’ coat pockets.
229. Immediately right at that moment, Douglas Bashar looking at Plaintiff and said that “He is
lying” in front of the other classmates. At that time, Plaintiff stepped out of the Bar &
Restaurant and called Douglas Bashar over phone and asked him, “Why do you think that I
am lying?” However, Douglas Bashar was evasive and did not answer the Plaintiff’ question.
230. As soon as Term 3 final exams are over, In the first week of February 2009, Plaintiff asked
Defendants Robert Ball, Robert Ross and Shana Keating to use Duke’ authorized software,
because Defendants Robert Ball, Robert Ross and Shana Keating discarded all of the Plaintiff’
contributions by accusing Plaintiff plagiarized the course work and abused the non Duke
software to record Plaintiff’ conversations.
231. Nevertheless, Defendants Robert Ball, Robert Ross and Shana Keating disregarded Plaintiff’
request and continue to discard Plaintiff’ contributions. At that time, Plaintiff suggested to
discuss the team dynamics and to arrive an amicable solution to divide the work among the
team members in the presence of Mark Brown.
232. Defendants Robert Ball, Robert Ross and Shana Keating refused to discuss with Mark Brown
and continued to trash Plaintiff’ contributions.
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 37 of 125
Page - 38 - of 125
233. On 22nd February 2009, Plaintiff contacted Mark Brown via email39
and copied his email to
Defendants Robert Ball, Robert Ross and Shana Keating. In his email Plaintiff clearly told to
Mark Brown he failed to resolve logistic and administrative issues through consensus within
his team and need his intervention.
234. On 23rd February 2009, Defendant Shana Keating contacted Mark Brown without copying to
Plaintiff and told him that she begun documenting her concerns along with Defendants
Robert Ball and Robert Ross concerns, about Plaintiff’ contributions and performance and
will send him a document after Defendants Robert Ball and Robert Ross agrees with her.
235. On 23rd February 2009, Defendant Shana Keating, Robert Ball and Robert Ross prepared six
pages of atrocious lies with hatred abhorrence and abomination against Plaintiff saying that
they don’t feel comfortable with Plaintiff’ quality of work and cited frivolous reasons for
attitude towards Plaintiff and send to Mark Brown without copying
“Dear Mark Brown, This is further to our last meeting during the beginning of Term #02, I am writing this email to
setup some time to talk to you tomorrow (Monday, 22nd February 2008) or any other time convenient for you. Now
I am in Term # 04 and in a different team. I could not able to resolve logistic and administrative issues through
consensus within my team. The issues are: (1) Using Fuqua's platform and online team boards for communication
(email and team meeting telephone calls) and storage of the documents. (2) Work division between the team
members and leading the team assignments. (3) Communication process and approach for tackling each
assignment. When it would be possible for you to have an initial conversation?”
“Hi Mark, This letter is being submitted to you by Robert Ross, Bobby Ball, and Shan a Keating. We are in Section
1, Team 2 of the 2009 Weekend EMBA program. Our team also includes Navneet Latawa and Vamsi Vurimindi; we
do not speak on behalf of Navneet or Vamsi in this letter. We are writing to address some concerns we are having
with our team dynamics. There is a disconnect between Vamsi Vurimindi and the rest of the team. We tried solving
our issues by adhering to our initial team charter (attached). When that failed, we made some compromises and
agreed upon a revised team charter (also attached). This did not work and now we are soliciting your help. The
main points of conflict for Vamsi are (1) using Centra voice, (2) work roles/responsibilities of team members, and (3)
date/time of team calls. However, we believe that these are minor issues on which we can compromise (and have
done so in the revised team charter). However, the real underlying issues for the rest of the team are Vamsi's
punctuality, work ethic, quality of work, and moral character. …. (4) Vamsi wants a team lead for each
assignment … Bottom line: in our opinions, Vamsi as not a good team lead. This is not a judgment, but rather an
observation. As a result, we decided to work together in a manner that draws upon our strengths, so we returned
to the routine that worked before and that made the best use of everyone's skills. (1) As just discussed, Vamsi is
inflexible and unwilling to compromise. If we do not proceed in the manner he desires, he complains or refuses to
participate. At the beginning of Term 2, we established a loose team charter that has been reviewed at least two
times since. We have met as a team to discuss these issues; we leave these meetings with a sense of consensus
(usually with compromise) and Vamsi brings up issues again at a later date. He continues to re-open resolved issues
Case 1:12-cv-01223 Document 1 Filed 11/15/12 Page 38 of 125