Burden of proof: UVA’s sexual assault policy under fire

Boston attorney Wendy Murphy filed a complaint against UVA with the Department of Educations Office of Civil Rights in June, claiming the school isn’t following its own sexual misconduct policy. The agency was already conducting its own investigation of UVA’s policy. Photo by Elise Amendola. Boston attorney Wendy Murphy filed a complaint against UVA with the Department of Educations Office of Civil Rights in June, claiming the school isn’t following its own sexual misconduct policy. The agency was already conducting its own investigation of UVA’s policy. Photo by Elise Amendola.

On September 23, a UVA student was forced into a bathroom at an off-campus party and raped. Five days later, a second student was shoved against a wall near Monroe Hall and sexually assaulted. Last week came details of a violent attempted abduction and rape on Stadium Road. Each incident drew attention: brief reports in the papers; heightened vigilance.

But rape at UVA was already under scrutiny at the start of the semester. It’s easier to deal with the outside menace than it is to confront the murkier and far more common problem of sexual assault between people who know each other, and that’s where a prominent women’s rights attorney says the University is falling short. The fact that UVA’s sexual misconduct policy is under investigation by the Department of Education indicates she’s not the only one.

Wendy Murphy, an adjunct professor at the New England School of Law and a frequent media commentator on issues of women’s rights, has a reputation as a firebrand. “I’m an activist with my feet in the courts,” she said. Her battle cry is blunt: “The law is designed to facilitate and perpetuate violence against women and children,” she said.

Murphy has been using litigation to push schools to take a tougher stance on sexual violence for years. Now, she says, federal guidelines are catching up.

On April 4, 2011, the U.S. Department of Education’s Office of Civil Rights (OCR) issued a “Dear Colleague” letter, a 19-page policy memo that landed on the desks of deans and administrators across the country and laid out colleges’ responsibilities when it comes to preventing and addressing sexual harassment and assault under Title IX, the 1972 gender equity law.

Most notable was a clear directive about the standard of proof for sexual misconduct. For decades, many schools—UVA included—had used a “clear and convincing” standard, requiring a panel to find it “highly probable or reasonably certain” that harassment or violence occurred before ruling in favor of a victim. But the government requires only a preponderance of evidence in a civil rights dispute—that is, it must simply be more likely than not that the act took place. Schools must do the same, the letter said, regardless of what a police investigation might turn up.

Some felt it was an overstep. The Foundation for Individual Rights in Education, a nonprofit that primarily advocates for free speech rights on college campuses, said the lower standard threatened accused students’ rights to due process, and joined the National Association of Scholars and the American Association of University Professors in a formal objection.

Still, the preponderance standard was becoming the norm. About 80 percent of colleges had already adopted it when the letter was issued. Murphy has gone after several who hadn’t, including UVA. OCR declined jurisdiction on a 2010 complaint she filed against the University, but the agency was already preparing to tackle the holdout schools head-on. In addition to the Dear Colleague letter, OCR initiated compliance reviews at several colleges, a step reserved for “problems that appear particularly acute,” according to the agency’s website.

In May 2011, a few weeks after getting OCR’s letter, UVA announced major revisions to its sexual misconduct policy. Among the changes: A shift to the preponderance standard when adjudicating cases.

That wasn’t enough to satisfy OCR, which placed UVA under review the following month. Almost a year and a half later, the investigation is still going on, a Department of Education spokesman confirmed. And while the University announced its 2011 policy changes and accompanying two-week public comment period with great fanfare, the compliance review has received barely a mention, apart from an e-mail to students, faculty, and staff last month informing them that the University had been “chosen” for review and offering OCR’s contact information so they could weigh in. No mention of the investigation appears on UVA’s Sexual Violence Education and Resources website.

Murphy filed another complaint against the University in June of this year, claiming that the school violated its own policy in the case of her client, a student who said she was raped in an off-Grounds apartment in December 2011 after being drugged at a club function. Despite finding the student “credible and compelling,” a panel ruled in favor of the accused, said Murphy. And that’s a problem.

“The preponderance standard is simple,” Murphy said. “When her accusations are deemed credible, and his denials are not described with the same glowing terminology, she wins.”

The student at the center of the case shared her story last month, authoring an emotionally charged post on Murphy’s Facebook page that was widely circulated among students. Murphy’s client asked C-VILLE to allow her to remain anonymous, but confirmed she wrote the piece. It detailed her rape and the University-led investigation that followed, a process she said violated her rights by letting her rapist go unpunished. When an official read the verdict, “I ran out of the room, sobbing uncontrollably like never before, and hid under a desk, wishing I could just die there,” she wrote. “My own school, that I loved so much, failed to protect me.”

UVA’s response to the post was a lengthy statement defending its policy and saying that while privacy laws mandate that the school not discuss the details, the post contained “multiple misstatements and omissions of facts that are material to that case.” The statement said UVA faithfully followed its own rigorous guidelines.

“We welcome constructive dialogue on this issue,” read the statement.

But UVA has since been silent. A request for comment on OCR’s compliance review was denied, as were requests for interviews with Dean of Students Allen Groves and Associate Dean and Chair of UVA’s Sexual Misconduct Board Nicole Eramo.

Meanwhile, others are taking interest. The ACLU of Virginia is conducting an investigation of Virginia schools’ sexual assault policies, including UVA’s.

“We want to make sure the process is fair,” said Katherine Greenier, a women’s rights expert at the ACLU. “But the process should not be a barrier that prevents victims of sexual assault from coming forward.”

Murphy contends UVA and other schools have hedged on adopting the lower standard because they fear it will require not just a cultural shift in how the school views sexual assault, but the refocusing of vast resources to prevention.

Holding victims to a stricter standard in policy or practice allows schools to have their cake and eat it, too, she said. “They can say to the victim, ‘We care about you. We want you to get better. But at the hearing we’re going to rule in his favor, because while we believe you’re telling the truth, we don’t believe you that much that we want to punish him.’”—Allie Cooper and Graelyn Brashear

  • yourmom

    got to put out more often

  • Katelyn Sack

    I am so thankful for Wendy Murphy’s work.

    Here is her brave client’s account, and a link to one of Prof. Murphy’s recent articles on this issue more broadly:



    • Bethany Baby

      Murphy is a rabid dog and this lawsuit is absurd.

      The argument being put forth here is essentially that any failure to rule against an accused student automatically amounts to an OCR violation. If that’s true then why have a hearing process at all? Why not just automatically sanction any accused student without even a pretext of a hearing?

      This is just a case of am embittered complainant who’s angry that a conduct board ruled against her. If the hearing process is to mean anything, then there will occasionally be times that they rule in favor of a defendant. Grow up.

      • Anonymous Sleuth

        Please educate us. Occasionally be times! It’s ALWAYS in favor of the defendants! LOL. You must be another member of the Akin family! or perhaps someone on the inside trying to protect the misogynists!

        • Bethany Baby


          8 out of 11 cases resulted in conviction last year, but I guess that’s not enough. Anything less than 11 out of 11 means that clearly the University is protecting rapists and must be in violation of Title IX.

          Because we only pay lip service to due process. We don’t actually believe in it.

          • Anonymous Sleuth

            Actually you are WRONG!!!!

            Bethany you’ve been drinking too much of that Cville kool aid! Convictions? Definition please? Who are you fooling?

            You’re doing the same jig as your friends in Peabody. Parsing words and facts to support a make believe narrative.

            This is how punishment is meted out by the honorable Chair:

            We found the accused guilty of a much lesser charge under our fantastic and incorruptible sexual misconduct policies that only we understand and hence the punishment is we recommend counseling and a suspension of the next summer semester. ROLOL…….

            FACT #1 Not one single conviction of “RAPE”.

            FACT #2 Not one single case of an SMB expelling a student.

            The two above facts speak to the truth of UVa’s policy. It’s that simple.

          • bamf

            This is an incoherent thought. You are stupid. Learn to structure an argument.

          • UVAcoverups

            How about arguing the facts. Calling people stupid and incoherent is hardly intellectual. You’re probably one of those Associate Deans with a UVA donated PhD. LOL.

      • An observer

        So correct on Wendy Murphy. During the Duke fiasco she was repeatedly shown to be a lier. That she promotes herself as a “professor” is a total joke. She may be listed as an “adjunct” at a low-tier law school, but the school cannot point to a single regular class Murphy has taught. She is more akin to Nancy Grace than a legal scholar. And like Grace she is a creature created by either overworked or lazy talk show producers, not sure which, but the point is she made her name by always being “available” when a show needed someone to take the “bash the male” side in a debate, no matter how ridiculous the set of facts. I have no idea of the facts of the case that led to this story, but the fact that Wendy Murphy is involved is not favorable to the accuser given Murphy’s general lack of credibility in the real world (as opposed to her fantasy world as a TV pundit).

  • J.

    Another fact: Nicole Eramo is the only forensic nurse to which UVa survivors are referred. Not only has she frequently falsified evidence, but also has a clear and unacceptable conflict of interest.

  • Wahoo Spirit

    Nicole Eramo is the Chair of the Sexual Misconduct Board, she isn’t a nurse. The nurse is someone else.
    Also, the assault mentioned in the article happened in December 2011, not 2010, so it was under the new “preponderance of evidence” standard.

  • Anonymous Sleuth

    Graelyn you have done a super job in articulating the debate, the politics and the duplicity. I’ve heard that UVA hasn’t expelled any student for sexual assault in over 10 years and some have asserted on Facebook that UVa has never expelled anyone. That is an alarming statistic if true and it seems to be so, as UVA’s underhand and unofficial response to the latest victim’s account did not address this atrocious record in any way, which only served to undermine the little credibility they have left on this issue.

    If I recall correctly (see http://news.virginia.edu/content/uva-revises-sexual-misconduct-policy-goal-become-national-model ), when UVA first made their announcement of the new revised policy both Patricia Lampkin and Susan Davis held a press conference to publicize it as a national model and perhaps disingenuously inferred that UVa would lead by example. It was self serving at
    best. How do they now explain and expect anyone to believe them when the result is more of the same? Contemporaneously Teresa Sullivan, UVA’s first woman president, apologized to Susan Russell for what UVA did to her daughter and now upon reflection I have to ask, were all these just mere PR stunts? Who does this to young women? and how do they sleep at night? I wish I could say we are being unfair but just ask any of the victims how they must feel about
    the way these trusted members of our community violate them after they barely survive their respective ordeals.Take a few minutes and walk in the shoes of a victim and try and imagine the unimaginable nightmare and betrayal. You get raped and they protect the rapist!!!!

    As we have recently learned Penn State officials had no problem in hiding and covering up the Sandusky scandal and that story did not end well for anyone. So it’s not like these trusted officials don’t lie and cover up. How much longer can all these US colleges continue churning victim after victim through their misogynistic policies, protect the perpetrators in an effort to make people believe these things don’t happen? It seems few of these elite colleges want to be the first to change as it will probably affect their rankings in the short run. They’re hedging on being followers rather than leaders.

    It’s time President Sullivan step up, own this issue and clean house. There’s absolutely no point in revising the procedures if the people in charge have no intention in applying them, it’s the people and the actual policy that has to be changed and she knows who and what they are. Then she can give the go-head and allow the Commonwealth Attorney to actually prosecute cases of student on student sexual assaults, something that hasn’t happened in years, for a myriad of reasons and excuses, so that the school can really brag that they are a model to be followed. Unfortunately, unless the administration sees the abyss, such as a scandal the magnitude of Penn State, we will see more of the same with more PR and the tossing of verbal tokens from the untouchables as we saw earlier this year, yes I refer to the “June Spring”. The irony of ironies is when President Sullivan stated “I must set a tone that says bad news can rise to the top of this organization without any messenger being shot for bearing it,” in reference to the Penn State scandal ( http://www.washingtonpost.com/local/education/penn-state-scandal-provides-lessons-to-university-presidents/2011/11/15/gIQALElGYN_story.html). One way or another change is coming……..

    More stories for those interested:








  • hm

    UVA is definitely looking bad internationally at this point for not addressing this problem. http://www.guardian.co.uk/commentisfree/2012/nov/18/reform-campus-rape-second-assault

  • http://www.facebook.com/bill.marshall.7796 Bill Marshall

    Perhaps UVA is fighting the lower standard in order to protect the Constitutional rights of those who are falsely accused. UVA says there were material errors and misstatments made by the accuser. Why are these not addressed in this article to show how difficult it is to get to the truth.?
    If a girl gets drugged and raped then the law needs to be used to its fullest power to bring the perpetrator to justice, but there are plenty of girls every week at UVA who overindulge and do regrettable things with guys as drunk or more drunk than they are. Just because a guy doesn’t “regret” having sex and the girl does doesn’t make it rape or even assualt.
    If you really want UVA to change then sue them for negligence for not protecting the student as they proclaim repeatedly that they do. when they have to cough up 20 million bucks from a c-ville jury things will change quick.

  • ronchris

    Accusation must equal conviction.

    Isn’t that how the witches were burnt in Salem?

  • http://rhymeswithright.mu.nu RhymesWithRight

    If we are truly dealing with sexual assault cases, why is the university even involved. The proper procedure is to require the accuser to file a police report and for the case to be investigated by law enforcement, with a decision on whether there is sufficient evidence to move forward made by local prosecutors. After that, the case goes to a jury — where the US Constitution applies.

    But then again, the US Constitution is supposed to apply anytime a state actor — in this case a public university — is at work.

  • JetsFan1984

    It should never remain on campus – it should go to the police and district attorney. The police will investigate and find out, with DNA and evidence, if a crime was committed. UVA should respect the criminal process, and not go around the law. We learned that with Penn State. Wendy Murphy was on the wrong side of history with the Duke Lacrosse Players and she supported the DA who was ultimately convicted of violating the male students civil rights. She is not a reasonable person. We should all want only the guilty punished. Most women have fathers, brothers, male friends, boyfriends, husbands, and sons. We don’t want any man accused and convicted without evidence. We want the guilty to be prosecuted and jailed.

  • Anonymous Sleuth

    You are all right, this is a criminal matter and logically it should be handled by law enforcement. However, I have a challenge for all the experts here. It’s a very simple question. When was the last time a “UVA student”, self confessed Beebe notwithstanding, was ever prosecuted for rape of a UVA student? or any form of sexual assault? Just prosecuted, not even convicted. So your theory of a UVA victim raped by a UVA fellow student getting justice in UVA or Charlottesville is just that, a theory. From this victim’s account I gather there was a corrupt nurse who changed her findings and a neanderthal prosecutor. So your theory is just that and doesn’t work in the real world. The cover up is always worse than the crime just ask Penn State’s Spanier, Curly and Schultz. UVA is a very special place, it must be that honor code they have because there are no rapists at UVA, ever, except for that statistical anomaly, Beebe, who was accidentally released within a few months due to a paperwork error. If anybody thinks there’s nothing wrong with this picture then the koolaid must be damn good in Charlottesville!

    • ronchris

      “UVA is a very special place, it must be that honor code they have because there are no rapists at UVA, ever”
      Ooh, look, I can make a straw-woman argument, too!
      – And hence there’s also no one who’s made a false accusation of rape, ever.

      What coverup is there here? Do you think inventing conspiracy theories about ‘the establishment’ makes your argument for making men “guilty until proven innocent” more persuasive?

      • Anonymous Sleuth

        Are you related to Akin by any chance? Your point of you is very well represented, “making men guilty until proven innocent” has never been an issue, not at UVA. Actually, the opposite is true, “every victim is believable but there’s never enough evidence to find the men guilty.” I’m presuming you think that using a preponderance standard in adjudicating a rape case in UVA is unfair to men? Well then you must have a problem with the entire civil system, as this would be the same standard if a victim sued the rapist in a court of law. The punishment in a civil suit would be money damages, the punishment at UVA should be expulsion, hardly the same if it was a criminal case, where the perp would go to jail and be on a sex offenders list for life. That is why the standard of proof is higher in a criminal matter. Your narrative is very distorted as is your mind.

        As for inventing so called “conspiracy theories” about the establishment, well I put it to you that they have put themselves out there. Let’s face it Sullivan’s resignation and re-hiring was less than transparent and confirmed that your establishment is hardly the bastion of truth and integrity. As for the way this school treats victims of sexual assault, I have no doubt, yes no doubt whatsoever, that the process has any integrity and is self serving at the detriment of every victim that has the courage to come forward. The people that run the SMB have no intention in discovering the truth and that’s where the cover up is centered. Now that every girl in UVA knows what happens to victims, I wonder how the next case will be handled? I wonder if the SMB panels will look at the people running the SMB in the same light? I wonder when the truth of how they rig their investigations and hearings will come to light? It’s now just a matter of time before something changes.

        • ronchris

          Are you related to Pol Pot by any chance? Or just the Red Queen?

          If the preponderance standard is so simple and has been met here, why hasn’t the victim in this case sued the alleged perpetrator? Is it because discovery and evidence and actually going to a civil court and testifying might not give the ‘right answer’?

          Every statement by Ms. Murphy in the article and you indicates you are simply trying to turn the SMB into a rubber stamp that says “guilty” 100% of the time.

          • Anonymous Sleuth

            Yes you are right, in your world no man can be found guilty, period! We get it. You work for FIRE and we understand your agenda. You have been very successful in protecting the rights of men. Your position is absurd, no one is suggesting that an accused doesn’t have the right to a thorough investigation nor the right to a fair hearing but if after all that he is found to be less credible than the victim that is the “preponderance standard”. Why is that so difficult for you to understand? You have been fighting the Dept of Education’s “Dear Colleague Letter” and you are on weak ground because your argument is flawed. Why should the standard at colleges be as high as a criminal court and not that of a civil court? Instead of being truthful about your objective you create your own narrative that someone is guilty and must prove their innocence and that the SMB becomes a rubber stamp. Well in reality you are right, the SMB is a rubber stamp that says “not guilty” 100% of the time since the school has never expelled anyone for sexual assault. There were 5 cases, investigations and hearings under the “preponderance standard” in 2011 at UVA. All 5 victims must have imagined it and the perps must have been falsely accused according to your narrative. Oh you forgot to address the nurse in your response and the fact that the perp’s attorney was monitoring the investigation as the “lying” victim stated. You’re good at protecting the rights of men who rape but who is looking after the rights of women? No one as the stats show!

          • Cara

            Are you kidding me? “Who is looking after the rights of women?” EVERYONE. If you think that that the “preponderance standard” is a reasonable manner by which to convict someone of rape, can you explain to me why it is NOT a reasonable manner by which to convict others of any other crime? Why would the standard of evidence be less and the punishment be just as great?? This is an absurd argument – what you are saying is that if the jury likes the accuser more than the accused, the accused will be found guilty. Then, a 20-year prison sentence and lifetime registration as a sex offender. Do you really understand what you are supporting? What if your husband or son were falsely accused and all that was necessary was an accusation and a cute, credible accuser to put them in jail for decades. And back to my original question – you have to be kidding me. Here are all the people “looking out for women”: judges, juries, victim advocate centers, victim advocates, politicians, feminists, hundreds of sexual assault organizations, liberals, professors, administrators, consultants, prosecutors, local and state police officers, doctors, NCIS agents, all other women, most men, etc, etc etc. These are people looking out for the accused (who, by the way [at this point] has not been convicted of anything): the accused and his costly defense attorney. Think about what you are saying.

          • kate

            When have you ever heard of someone falsely accused of rape?

  • Daris Darrison

    I went to Harvard Law School and Wendy Murphy was a guest lecturer for ONE DAY in my Evidence class. Suffice to say, people still talk about this class. This woman believes, and stated to a class of 200 students, that there has NEVER been a case of a woman falsely accusing a man of rape or sexual assault.

    At that point, Murphy’s credibility dropped to zero. I mean, it was Harvard, full of liberal bleeding hearts, but even bleeding hearts have their threshold of reality. She was booed during class.

    How a “civil standard” of preponderence of the evidence would apply to an accusation that can deprive one of life, liberty, or pursuit of happiness is beyond me. Heck, the clear and convincing standard isn’t even enough to do that. So since we war talking about “college attendance” I suppose…one is still depriving a student of an education, and permanently defaming him, based on a POE standard? Not.

    And BTW, Ms. Murphy, she of Suffolk County or Joe’s Law School faculty: you complain about the FACT FINDERS conclusion in your client’s case. Welcome to the USA. The FACT FINDER, be it a jury, judge, or administrative body, always determines…the facts. You lost. If you want to complain in retrospect about biased administrative panels…you were the one stupid enough to agree to try your facts in front of that body.

    Also, the other stories here about rapes…and those rapes being successfully prosecuted, belies the “crisis” that all men go free.

    BTW, I say “men” and “man” in this post despite the fact that men can be raped as well. But Wendy Murphy denied that, too, at her joke of a lecture.

    • UVAcoverups

      Your argument is totally flawed. The preponderance standard is the one used in civil cases and goes back to the very beginning of common law. If found guilty at a university hearing no one is going to jail or losing their liberty. At worst they would be expelled as are thieves and cheats. For a Harvard law student you sound very confused? UVA has a horrific record on protecting all rapists, even repeat offenders. What about the victims rights?

      • Esteban

        Dumbing down the standard to POE is, I suppose, your goal. The job of protecting society against rapist is the state’s police power…criminal standard. I suppose you want to ruin someone’s life based on POE, and if UVA wants to do that, I suppose students beware.

        Do you believe that someone acquitted of murder should then undergo a civil trial on the POE standard? Happens all the time, but do you agree with it?

        • UVAcoverups

          Do you mean like OJ Simpson? Oops, that wasn’t fair that he lost the civil case.

          • Esteban

            Ahhh, you were on the jury…and you picked that case. How about the homeless guy aquitted in criminal court? Answer my question…do you agree that murder should be retried in civil court. Try to avoid the outlier

    • a.tassin

      Highly unlikely that really happened. You don’t need to lie just to get your point a crossed

      • Daris Darrison

        You’ve got to be kidding me. You are going to challenge my education and Evidence class with Dr. Nesson? What is “highly unlikely” is your education is close to mine…did I get my point “a crossed” (sic) I mean “across (correct choice of word)?”

        And it did indeed happen. Winter term of 2006. Now, try hollering back at me after another six months goes by from my last post, like you did this morning.

        Oh, and giving a “like” to yourself doesn’t really count except for insecurity, a. tassin.

        • payLeoDyeIt

          Daris, I liked the previous poster just because he/she is so much more likable than a pretentious a-hole like you with your- “What is “highly unlikely” is your education is close to mine…did I get my point “a crossed” (sic) I mean “across (correct choice of word)?”” comment.

          • Daris Darrison

            So I’m the ahole because I am offended at being called a liar about my experience sitting in a class with Wendy Murphy pontificating? OK.

          • payLeoDyeIt

            How did you make it through that superior schooling with such limited skills in reading comprehension?

            I didn’t write a thing about your experience or your semi-justifiable offense at having your story questioned. I said that you demonstrated that you are a pretentious a-hole by writing “What is “highly unlikely” is your education is close to mine…did I get my point “a crossed” (sic) I mean “across (correct choice of word)?””

            I’ll now add myself to those who might question your story. Not only do you seem to have trouble reading, you don’t write like any Harvard or other law school grad I’ve ever met.

          • Daris Darrison

            Try again, Leo. You said that you “liked the previous poster just because he is so much more likable….” My response to you was, to paraphrase, “really, so that guy is so much more likable, and I’m the ahole, because his post was so much less pretentious insofar as it basically called me a liar without any facts to back that up?” Said differently: I am surprised that you think that someone who baselessly calls another a liar, about Harvard, is “more likable” than a guy who slaps him down. That’s fine…have your opinion, Leo. But I paid for my own education at that school, and I’m going to slap around some jibbering moron who’s only retort to my post is “highly unlikely” and “you don’t have to lie.”

            Do you get that now, Mr, “Reading Comprehension?” So what if I fired off a smug correction to a douche that calls me out on my education. Like he would know about it, or about the Wendy Murphy incident.

            What other Harvard Law grads have you “met” and how often are you pouring over their writings? Rest assured that most of us do not post law review briefs in these commentary sections.

            Now, if you want to fall back on “my opinion is that one should never pull a superiority comment in these posts” again, that’s fine, and as you say “semi-justifiable.” But then you add the “and now I’ll add myself” and implication that my education is a lie. Well, how about if I just tell you that it is not a lie, and then you two can both say it is, and then major progress on that dispute will be made…not. Good luck and talk about being smug.

  • patricia gala

    2014 same thing. The animal that raped my daughter raped her friend too. He is a big man on the campus, worth a bunch to UVA, engaged in sports and campus politics, so whats a few sacrifices for UVA? If I had known about this last year I would not be on this site right now.

    • UVAcoverups

      This is their official unwritten policy.

  • patricia gala

    There goes UVrApe’s nice ranking! Transfer now before this, you are paying too much for what you will get in the end!


  • patricia gala
  • Walt

    The story has it wrong: the AAUP did not sign on to FIRE’s objection to the preponderance standard, Cary Nelson, a former president signed not in his official capacity but as an individual. This is noted on the objection letter from FIRE. The story should be changed to reflect that.

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