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Factual Allegations Made in Carpenter Family Suit

The following is the Carpenters’ factual narrative, verbatim from their complaint in Carpenter v. Massachusetts Institute of Technology, No. SUCV2003-2660 (Suffolk Superior Court filed June 4, 2003):

* Julia Miles Carpenter [Julie] enrolled at MIT as a freshman in August of 1999 and was a member of MIT’s class of 2003.

* Julie chose to reside in Random Hall, a residence hall owned, operated and controlled by MIT for which monies were paid to MIT as rent and/or room and board.

* For each year of enrollment, MIT was paid in excess of $30,000.00 for tuition, room, board and other services on behalf of Julie.

* As set forth in marketing materials, advertisements, internet documents, student registration materials, the MIT Student Handbook, and other verbal assurances, in exchange for the sums noted above, MIT promised to provide Julie with an appropriate and safe living environment in which she would be provided adequate, reasonable and necessary supports including, but not limited to,

a. appropriately administered and coordinated medical, psychiatric and emergency services through the MIT Health Services and MIT Police Department;

b. a safe and appropriately administered residence hall; and,

c. an effective and appropriately administered student disciplinary program.

* Julie returned to MIT and Random Hall in August of 2000 as a sophomore.

* At all times relevant, MIT had the responsibility to, and in fact, employed faculty and staff employees to ensure the academic and social well-being of MIT students, including residents of Random Hall.

* During the fall semester of 2000, Julie first encountered the Defendant, Charvak Karpe [Karpe].

* Karpe was a freshman MIT student who rapidly became infatuated with Julie.

* In addition to being an MIT student and resident of Random Hall, Karpe was an agent, servant and/or employee of MIT in that he did paid work, specifically desk duty at Random Hall, a position of trust because of the access it provided to a master key to all Random Hall rooms, including Julie’s room.

* Karpe’s infatuation with Julie rapidly turned to obsession despite Julie’s efforts to dissuade Karpe.

* By late October 2000, Karpe had twice violated Julie’s privacy by accessing her private computer files without her permission.

* During this activity, Karpe downloaded information that allowed him to spy on Julie’s computer activities and communications and he further copied video of Julie and her boyfriend engaged in sexual activity.

* Karpe proceeded to show this video to other students in Random Hall.

* Additionally, for months beginning in the fall of 2000, Karpe slept outside of Julie’s room, which was on a women’s floor, on a couch in a lounge thus forcing Julie to keep her dorm room door closed and effectively isolating her from contact with other dorm residents.

* As a result of Karpe’s conduct, Julie was forced to change her email accounts to stop Karpe from sending her screen messages.

* Further, Julie took her computer to MIT experts to have them increase her level of security and ascertain what information was being sent to Karpe from a program he had loaded on her computer to track her every key stroke.

* During this time, Julie became increasingly concerned with Karpe’s activity and both she and her friends told him to leave her alone, sometimes when Resident Advisors were present.

* Indeed, there was at least one instance of Karpe grabbing onto Julie and refusing to let go until a Resident Advisor was able to pry her free.

* The Defendant, Nina J. Davis-Millis, the Housemaster of Random Hall, was well-aware that Karpe was stalking Julie, and mentioned the problem to Random Hall staff during a house meeting as early as the late fall.

* Despite this knowledge, there is no indication of any efforts by MIT or its employees, including Resident Advisors, to effectively address Karpe’s aberrant behavior and provide Julie a safe place in which to live and pursue her studies.

* In January of 2001, Julie returned to Random Hall for the spring semester of her sophomore year at MIT.

* Karpe told Julie at this time that he had stolen the videos and downloaded computer communications between her and her boyfriend.

* Julie learned that other residents of the dorm had seen the videos.

* Julie further became increasingly concerned about her own safety and that of her boyfriend during his visit in January, 2001.

* Accordingly, Julie sought help from the Random Hall Judicial Committee (Judcomm).

* On February 9, 2001, Julie filed a complaint with Judcomm charging Karpe with harassment, invasion of privacy and improper conduct.

* On February 19, 2001, a hearing was held at which Karpe did not dispute the charges.

* Julie was extremely distraught by Karpe’s conduct, a point that was not lost on the Judcomm members.

* As such, there can be little doubt that as of this time MIT and many of its agents were well-aware of the seriousness of the situation.

* It was only following this hearing that Karpe decided himself, and not at the direction of MIT, to remove his belongings from the lounge where he had been living and return to the floor where his room was located.

* On February 24, 2001, Julie was verbally advised by a member of Judcomm that the committee had decided that Karpe’s conduct warranted removal from the dorm, but the decision to be issued imposed a number of conditions on Karpe which, if met, would allow him to remain in Random Hall.

* Specifically, Karpe was required to: (1) stay away from Julie; (2) surrender his computer; (3) attend weekly counseling; (4) agree not to consume alcohol; and, (5) to surrender his desk job.

* Julie was devastated by the decision not to remove Karpe from Random Hall.

* Due to Nina J. Davis-Millis’ knowledge of both Karpe’s conduct and the profound impact it and the inadequate Judcomm procedure was having on Julie, Julie was referred to the Defendant, Robert M. Randolph.

* . As of this time, Randolph had reportedly been specifically advised by Davis-Millis that Karpe had to be removed from the dorm.

* Further, given the severity of Julie’s reaction to the draft Judcomm decision, the committee decided not to issue the decision having concluded that they were in over their head, a conclusion that should have been obvious to all concerned well in advance of this point in time.

* Later on February 24, 2001, Julie contacted her boyfriend and told him that she wanted to check into a hotel and slash her wrists.

* Julie’s boyfriend contacted a number of her friends at MIT and they took Julie away from MIT to the home of one of the friends.

* While at the friend’s house, Julie and her friends told the friend’s mother, Lynn Josephson, M.D., about the problems that Julie was having.

* When she became aware of the seriousness of the situation, Dr. Josephson sought and obtained Julie’s permission to advise administrators at MIT of the seriousness of the situation.

* Dr. Josephson communicated the information to the Defendant, Robert M. Randolph, and the Defendant, Charles Vest, by an email dated February 25, 2001. See Ex. B.

* Dr. Josephson’s correspondence proceeds to detail with extraordinary clarity the issues that were confronting Julie and the Doctor’s grave concerns about Julie.

* Dr. Josephson’s plea for help noted that Randolph was to meet with Julie the next day and ended with the following language:

I chose to write to you to be certain that this problem would not be kept from your attention. We’ve lost too many MIT kids to suicide. Please help.

* On February 26, 2001, Randolph, a Senior Associate Dean at MIT, responded to Dr. Josephson’s letter. See Ex. C.

* As of this point, the Defendants knew, or should have known, of Julie’s suicide threat, the issues she was confronting and the 11 previous MIT students whose death had been classified as a suicide during the proceeding 11 years.

* In particular, the Defendants knew, or should have known, of the burning death of Elizabeth Shin in Random Hall a year earlier.

* Moreover, the Defendants knew, or should have known, that MIT’s rate of student suicide is approximately twice the national average of a comparative population and that respected educators and mental health professionals had voiced their opinion that MIT was in the grip of a suicide contagion.

* Despite their knowledge of these facts and the foreseeability of student suicide among the MIT student population and Julie in particular, the Defendants were inadequately trained and supervised and MIT’s policies and procedures were deficient while its Mental Health Services lacked proper staffing, coordination of care, clear treatment protocols and there was no effective mechanism within MIT which ensured that necessary information was conveyed to the appropriate professionals within MIT.

* Dean Randolph’s meeting with Julie was immediately preceded by Randolph’s receipt and response to Dr. Josephson’s email.

* At this meeting, Julie advised Randolph that she wanted Karpe removed from the dorm.

* Randolph, who was unqualified to make such a determination, opined that Julie’s concerns were less about the stalking or harassment, and more about her embarrassment concerning the publication of the materials from her computer.

* Further, during the meeting, Randolph, who was apparently fixated on the issue of substance and alcohol abuse that gripped the MIT community in the wake of the alcohol-induced death of Scott Kruger, referred Julie to a substance abuse counselor in MIT’s medical department.

* This substance abuse counselor, Adam Silk, M.D., was not advised by the Defendants, Randolph, Vest, Benedict, Orme-Johnson or Davis-Millis, of either the stalking issues, Julie’s earlier suicide threat or Dr. Josephson’s warning letter.

* Moreover, while Randolph indicated during this meeting that Karpe would be removed from the dorm immediately, it in fact took 10 days, until March 7, 2001, for Karpe to be moved and this occurred only after Julie was again forced to inquire why Karpe continued to reside at Random Hall.

* At no time were Julie’s parents advised by MIT or any of its agents, servants and/or employees of the problems Julie was having or her suicide threat despite assurances provided to parents, including the Carpenters on which they and Julie relied, that in the event of an emergency or life-threatening situation parents would be the “first to know.”

* In particular, Julie’s parents were never advised by Defendants, Randolph, Vest, Benedict, Orme-Johnson or Davis-Millis of the life-threatening risk to Julie of which they were well-aware.

* It was not until March 22, 2001, that Julie was finally able to meet with Dr. Silk, the substance abuse counselor to whom Dean Randolph referred Julie.

* This delay reflects a number of relevant deficiencies in MIT’s Mental Health Department as further discussed in the reports of MIT’s Mental Health Task Force. See, e.g., Ex. D.

* Many of these acknowledged deficiencies should have been addressed prior to Julie’s death in a manner that would have more likely than not prevented her death.

* Further, the delay evidences Randolph’s negligent and/or reckless handling of the known risk of Julie’s suicide.

* On the referral of the Karpe complaint from Judcomm to Dean Randolph, Randolph referred the matter to the Office of Student Conflict Resolution and Discipline.

* A decision was made to pursue the Administrative Review process.

* On March 2, 2001, Julie filed her complaint against Karpe with the Administrative Review panel.

* The Administrative Review panel was comprised of a faculty member and a student.

* By his own admission, the faculty member who served on this Panel was no expert on any of the issues this case presented.

* Julie requested that Dr. Josephson be allowed to be present as a damages witness and for support during the hearing, but Dr. Josephson was not allowed to be present because Dr. Josephson was not a “member of the MIT community.”

* Further, no effort was made to have someone from MIT’s own medical community provide similar testimony, support or follow up with Julie.

* Karpe again took no issue with the charges Julie raised other than to advise the Panel that he was not trying to destroy Julie, only scare her.

* The Panel displayed a disturbing concern for ensuring Karpe’s well-being and the appropriateness of his punishment, while marginalizing the severity of his admitted conduct and its impact on Julie.

* After hearing, the Panel was of the view that Karpe needed to be removed from Random Hall for the immediate future.

* On April 20, 2001, the Panel submitted its final decision.

* Karpe accepted the charges of harassment, invasion of privacy and improper conduct.

* His sanctions were: (1) attend a minimum of three sessions at EMERGE; and, (2) write a paper about what it feels like to be a victim of harassment and invasion of privacy. Further, the Panel recommended that Karpe read a few books and continue counseling into the fall. The decision allowed for Karpe’s return to Random Hall the following fall if he complied with these minimal sanctions.

* On April 25, 2001, at the direction of Defendant, Orme-Johnson, Julie picked up a copy of the Panel’s decision left in an unattended room and signed for it.

* No one from MIT spoke with Julie concerning the contents of the decision or monitored her reaction to it.

* Given the impending end of the semester, the Panel’s decision was tantamount to banishing Karpe from Random Hall for approximately one month.

* On investigation following her death by the Middlesex County District Attorney’s Office, Julie’s laptop computer revealed that after picking up the decision on April 25, 2001, Julie logged onto at least one website from which she sought to obtain sodium cyanide, a highly controlled poisonous chemical.

* On information and belief, two days later, on April 27, 2001, Julie received cyanide that had been shipped to her at Random Hall.

* Three days later, on April 30, 2001, Julie was found dead in her room due to her ingestion of cyanide.

* While no cyanide was found in Julie’s room at the time her body was found, on June 6, 2001, approximately five weeks after Julie’s death, MIT Police Chief Driscoll turned over a package containing a white crystal powder, later identified to be cyanide, to the investigating officer of the Massachusetts State Police.

* According to the State Police, MIT Police Chief Driscoll claimed that this package had “suddenly appeared.”

* The whereabouts of the cyanide between the date of Julie’s death and its “sudden[] appear[ance]” remain unknown to the Plaintiff at this time.

* At all times relevant, the Defendants, Vest, Randolph, Benedict, Orme-Johnson and Davis-Millis knew, or should have known, of Julie’s fear and victimization, difficulties with the Judcomm and Administrative Review process, and her resultant suicidal ideation and threats such that they could reasonably foresee that they would be expected to take affirmative action to protect Julie.

* At all times relevant, the Defendants, Vest, Randolph, Benedict, Orme-Johnson and Davis-Millis knew, or should have known, that harm to Julie including her resultant suicide was a foreseeable consequence of their failure to take appropriate action in light of the known risk. Related stories: