APPENDIX

A) University Audit Results

1. E-mail from Chris Roby, Director of Office of Student Activities and Facilities
2. E-mail from Max Tabachnik, Chair of SOFC
3. E-mail from Trent Serwertz, former Treasurer of DCR

B) Robinette’s discreet “coming out”

1. E-mail from Janie Long, LGBT Director (subject line of E-mail was Duke College
Republicans)

C) E-mails sent by Defendant Carter Boyle (current DCR Chair)

1. Message with only “SonDs” in subject line and link to explanation of “butt sex” sent on
Valentine’s Day
2. Message including a derogatory and offensive image of homosexuality, referring to a student
3. Message with “Enius” in subject line; “Enius” is a derogatory substitute for “penis”
4. Message with link to unsolicited heterosexual pornography
5. 2nd message with link to unsolicited heterosexual pornography
6. Racist message referring to “naggers”
7. Racist message referring to slavery
8. Racist message referring to President Obama as “President Wheat and Rice”
9. Racist message mocking African Americans
10. Racist message mocking African American culture
11. Anti-Semitic message referring to the President of Duke Democrats
12. Offensive message referring to Rwandan Genocide and Lesbians in Hell
13. Offensive message regarding “A Giant Cock in His Face Saying: “WE’RE THE COLLEGE
REPUBLICANS, BITCH!”
14. Offensive message including vulgarity and profanity

D) E-mails from Defendants expressing support for Plaintiff’s decisions as President

1. Message from Defendant Tasher supporting Plaintiff’s letters to the editor of the Chronicle;
Defendants listed such letters to the editor as just cause for impeaching Robinette
2. Message from Defendant Tasher supporting and encouraging Robinette’s position and actions
relating to the resignations of several DCR members in February, 2010
3. Message from Defendant Provost adamantly defending Robinette regarding same resignations
4. Message from Defendant Boyle stating that he “stand[s]…firmly” with Robinette’s actions
5. Message from Defendant Provost explaining DSG endorsement procedure; states that club
could potentially endorse multiple candidates for one office
a. Letter to the Editor containing DCR’s 2010 DSG endorsements

E) E-mails from Defendants attempting to “fix” club elections

 1. Message from Tasher instructing Robinette whom to push into which club elections;
Defendants listed, rather, that Robinette fixed elections. Defendants fully participated and
encouraged placing certain club members into certain club offices.
2. Message from Defendant Tasher instructing Robinette to “make sure [club members] know
whom to support”
3. Message from Defendant Tasher attempting to premeditate and fix club elections
4. Message from Defendant Provost stating that she, and only she, was nominated and confirmed
as responsible for club elections
5. Message from Defendant Provost attempting to fix club elections

F) E-mails from Defendants regarding club membership

1. Defendants requested Robinette add members to listserv, then later impeached him for it
2. Message from Defendant Boyle forcing members out of DCR, refusing them membership and
access to meetings
3. Message from Defendant Provost regarding her use of the listserv “Blacklist” function
G) E-mails documenting Executive Board support for Plaintiff Robinette as Chairman, before
his sexual orientation was disclosed
1. Message from Defendant Day congratulating Robinette on winning an election
2. Message from Defendant Provost asking if Robinette needed any lobbying of individual voters
to ensure his victory in the statewide Co-Chair election
3. Message from Defendant Provost asking if Robinette needed her to nominate him officially for
the position of statewide Co-Chair
4. Message from Defendant Provost to entire DCR club expressing her congratulations to
Robinette for winning the statewide Co-Chair election (sent after all alleged wrongdoing
contained in the Articles of Impeachment)
H) E-mails containing anti-gay arguments
1. E-mail mocking the LGBT Center’s campus-wide flyer initiative for respect
2. E-mail from former CR officer arguing passionately against VP for Student Affairs Larry
Moneta’s campus wide blast e-mail calling for tolerance and respect regarding the LGBT
community
I) Defendant Boyle’s invitations to vandalize and “throw” school property from windows
(Plaintiff later informed police before impeachment)
1. Defendant Boyle discussing recruiting another DCR member to vandalize because “he’s a
thrower for sure”; also uses racist language
2. Defendant Boyle discussing additional potential DCR officers as recruits for vandalism
J) Responding to a DCR club e-mail regarding an election, Defendant Tasher wrote about
“two inch cock syndrome” and women’s “racks”
K) E-mail from Defendant Tasher requesting club expenditures on clothing items
L) Unwanted Sexual Advances from Former Male DCR Officer
1. Former DCR officer e-mailed Robinette with only the word, “Semen”
M) E-mail from Defendant Provost explaining procedure for unprecedented “closed” Exec
meeting
N) Resignation letters from senior club officers immediately following Robinette’s
impeachment
1. Former Vice-Chair Clifford Satell
2. Former Treasurer Trent Serwertz
3. Former Vice-Chair Matthew Leonard
4. Former Executive Board Member Amy Li

O) Blackmail message from Defendant Provost to Doe VII

P) Hostile Environment
1. Anonymous Duke CollegeACB post containing vulgarity; language resembles the language
used to vandalize the East-West Bridge
2. Anonymous post: “faggot” repeated dozens of times
Q) Death Threats
1. Death threat #1 forwarded by Sabrina.McCutchan@gmail.com
2. Death threat #2 sent to Robinette by anonymous
3. Death threat #3 sent to Doe III by anonymous
4. Photograph of East-West bridge vandalism

R) Letter to the Editor Regarding DCR’s DSG Endorsements, Written by Robinette

 A.1, 2, 3) University Audit Results:

B.1) “Coming Out” Discreetly to the Director of LGBT Life

and at the LGBT Center:
From: Janie Long <janie.long@duke.edu> Sent: Thu 10/08/09 4:46 PM

To: "Justin F. Robinette" <justin.robinette@duke.edu> Priority: Normal

Cc: "Christopher J. Purcell" <christopher.purcell@duke.edu>

Subject: Re: Duke College Republicans Type: Embeded HTML/Text

Hi, Justin.

Thanks for your e-mail and interest. I would be happy to discuss with you possible ways for you to interact with the students who come to the Center. My program coordinator,
Chris Purcell, suggested a meeting the afternoon of Thursday, October 15th. I am open between 1:30 and 4:00. Would some of that time slot work for you? We can meet in my
office here at the Center. If that time does not work, feel free to suggest other possible meeting times.

I look forward to hearing from you.

C) E-mails sent by Defendant Carter Boyle (Current DCR Chair)
1. “Shit on Dicks” in the Subject Line, and Links to “Butt Sex” on Valentine’s Day:

2. Derogatory homosexual image drawn by Defendant Boyle, used to describe

another student:

Pretty much anyone who could ever fathom dressing like that for Halloween is 8==> <==8
On Fri 11/06/09 1:02 AM , Justin Robinette <justin.robinette@duke.edu> wrote:

http://www.facebook.com/home.php?#/photo.php?pid=30710096&id=1096860316

--
Justin Robinette
Duke University | Class of 2011
Chairman, Duke College Republicans
(850) 832-2229

3. “Enius” is a Derogatory Word for “Penis:”

4. Message with link to unsolicited heterosexual pornography:

5. 2nd Message with link to unsolicited heterosexual pornography:

6. Racist message referring to “naggers:”

7. Racist message referring to slavery:

8. Racist message referring to President Obama as “President Wheat and Rice:”

9. Racist message mocking African-Americans:

 9. Racist message mocking African-Americans:
From:
Carter Boyle <carter.boyle@duke.edu> Sent:
Sun 08/30/09 4:33 PM

To:
rachel.provost@duke.edu, travis.rapp@duke.edu, justin.robinette@duke.edu,matt.leonard@duke.edu Priority:
Normal

Subject:
Fwd: Bill Cosby on Problems in the Black Community Type:
Embeded HTML/Text

Obama and Gates could learn from this...

On Sun 08/30/09 3:09 PM , dboyle1997 <dboyle1997@aol.com> wrote:

'They're standing on the corner and they can't speak English.

I can't even talk the way these people talk:

Why you ain't,

Where you is,
What he drive,
Where he stay,
Where he work,
Who you be...

And I blamed the kid until I heard the mother talk.

And then I heard the father talk.

Everybody knows it's important to speak English except these knuckleheads. You can't be a doctor with that kind of crap coming out of your mouth
In fact you will never get any kind of job making a decent living.

People marched and were hit in the face with rocks to get an Education, and now we've got these knuckleheads walking around.

The lower economic people are not holding up their end in this deal.

These people are not parenting. They are buying things for kids.

$500 sneakers for what?

And they won't spend $200 for Hooked on Phonics.

I am talking about these people who cry when their son is standing there in an orange suit.

Where were you when he was 2?

Where were you when he was 12?

Where were you when he was 18 and how come you didn't know that he had a pistol?

And where is the father? Or who is his father?

People putting their clothes on backward:

Isn't that a sign of something gone wrong?

People with their hats on backward, pants down around the crack, isn't that a sign of something?

Isn't it a sign of something when she has her dress all the way up and got all type of needles [piercing] going through her body?

What part of Africa did this come from??

We are not Africans. Those people are not Africans; they don't know a thing about Africa .....

I say this all of the time. It would be like white people saying they are European-American. That is totally stupid.

I was born here, and so were my parents and grand parents and, very likely my great grandparents. I don't have any connection to Africa, no more than white Americans have to
Germany , Scotland, England, Ireland, or the Netherlands . The same applies to 99 percent of all the black Americans as regards to Africa . So stop, already! ! !

With names like Shaniqua, Taliqua and Mohammed and all of that crap ......... and all of them are in jail.

Brown or black versus the Board of Education is no longer the white person's problem.

We have got to take the neighborhood back..

People used to be ashamed. Today a woman has eight children with eight different 'husbands' -- or men or whatever you call them now.

We have millionaire football players who cannot read.

We have million-dollar basketball players who can't write two paragraphs. We, as black folks have to do a better job.

Someone working at Wal-Mart with seven kids, you are hurting us.

We have to start holding each other to a higher standard..

We cannot blame the white people any longer.'

Dr.. William Henry 'Bill' Cosby, Jr., Ed..D.
WELL SAID, BILL
It's NOT about color...
It's about behavior!!!

PASS THIS ON AROUND THE WORLD!!!!!!

11. Anti-Semitic message referring to the President of Duke Democrats:

12. Offensive message/jokes referring to Rwandan Genocide and Lesbians in Hell:

13. Offensive message regarding “A Giant Cock in His Face Saying: “WE’RE THE
COLLEGE REPUBLICANS, BITCH!”:
14. Offensive message including vulgarity and profanity:
D.) E-mails from Defendants expressing support for Plaintiff’s
policies as Chairman:
1. Defendants’ Support for Robinette’s “Letters to the Editor” Policy:

2. Message from Defendant Tasher supporting and encouraging Robinette’s

positions and actions:
3. Message from Defendant Provost adamantly defending Robinette:

4. Message from Defendant Boyle stating that he “stand[s]…firmly” with

Robinette’s actions

5. Support for Endorsement: Robinette “Reflected Qualifications of Both

Candidates and Included the Board’s Dissenting Opinions” (The Chronicle):
E. Defendants Fixed Elections, Not Robinette: E-mails from
Defendants attempting to Fix club elections
1. Message from Tasher instructing Robinette whom to push into which club
elections:

2. Message from Defendant Tasher instructing Robinette to “make sure [club

members] know whom to support”:

3. Message from Defendant Tasher attempting to premeditate and fix club elections:
4. Message from Defendant Provost stating that she, and only she, was
nominated and confirmed as responsible for all club elections:

5. Message from Defendant Provost attempting to “fix” club elections

 F. E-mails from Defendants regarding club membership:

1. Defendants Requested Robinette Add Members to Listserv, then Later

Impeached Him For It:

2. Message from Defendant Boyle forcing members out of DCR:

3. Message from Defendant Provost regarding the listserv “Blacklist” function:
G. Executive Board Support for Robinette before He Was Outed

1. Message from Defendant Day congratulating Robinette on winning an election:

2. Message from Defendant Provost asking if Robinette needed any additional help securing his statewide
co-chair election:

3. Message from Defendant Provost asking if Robinette needed her to nominate him officially for the
statewide position:
4. Message from Defendant Provost to entire DCR club expressing her congratulations to Robinette for
winning the statewide Co-Chair election )sent after all alleged wrongdoing contained in the Articles of
Impeachment:
 H. E-mails Containing Anti-Gay Arguments

1. E-mail mocking the LGBT Center’s campus wide flyer initiative for respect:

2. E-mail from former CR officer arguing passionately against VP for Student

Affairs Larry Moneta’s campus wide blast e-mail calling for tolerance and
respect regarding the LGBT community:

On Wed, Apr 15, 2009 at 2:44 PM, Jake Bullock <jmb76@duke.edu> wrote:
I have a serious problem with the implications of Larry Moneta's recent email. While I don't support
the views of the WBC, administrators cannot be allowed to encourage pro-gay behavior on campus.
This is truly unbelievable. It is a direct assault to the spirit of the establishment clause in the US
Constitution. It is one thing to encourage students to avoid dangerous drinking behaviors or drug
use, but it is quite another to send a blast email calling for the defense and tolerance of immorality
and sin. Whatever Moneta's intentions were, he failed to keep private beliefs from influencing
crucial university correspondences.
 I. Defendant Boyle’s Invitations to Vandalize and “Throw”
School Property From Windows:
1. Defendant Boyle discussing recruiting another DCR member to vandalize because “he’s a thrower
for sure”; also uses racist language:

2. Defendant Boyle discussing recruiting another DCR member to vandalize:

J. E-mail Containing Defendant Tasher’s Offensive “thoughts” on

Women:
K. Defendants Requested Robinette Expend Funds on Certain
Purchases; He Often Refused:

L. Unwanted Sexual Advances from Former Male DCR Officer:

1. Former Male DCR Officer Emailed Robinette With Only the Word, “Semen:”
M. E-mail from Defendant Provost Explaining Procedure for
Unprecedented “Closed” Meeting:
 N. Senior Officers’ Resignations Immediate Following
Impeachment of Robinette:
1. Former Vice-Chair Clifford Satell:
2. Former Treasurer Trent Serwertz:

3. Former Vice-Chair Matthew Leonard:

4. Former Executive Board Member Amy Li:
O. Blackmail from Defendant Provost to Doe VII:
 P. Hostile Environment

1. Anonymous College ACB post containing vulgarity; language used

resembles the language used to vandalize the East-West Bridge:

2. Anonymous post: “faggot” repeated dozens of times

 Q. Death Threats
1. Death threat #1 forwarded by Sabrina.McCutchan@gmail.com to Plaintiff
Robinette:

2. Death threat #2 sent to Robinette by anonymous:

3. Death threat #3 sent to Doe by anonymous:

4. Photograph of East-West Bridge Vandalism:
 R. Letter to the Editor Regarding DCR’s DSG Endorsements,
Written by Robinette

College Republicans endorses Lefevre

By DUKE COLLEGE REPUBLICANS

March 30, 2010

In an extremely tight vote, Duke College Republicans voted to endorse Mike Lefevre for DSG president. We endorse Lefevre with Will Passo as

second preference in the instant runoff.

We felt that Lefevre has a track record for tangible positive change on campus. During the past three years he has represented the student body in

DSG with passion and integrity, often serving to bridge the gap between faculty and students. Among his many accomplishments, Lefevre brought

Zip Cars to the University and worked to close a $2.2 million budget gap in Duke Dining. We believe his thorough understanding of Duke’s

institutions will help further empower the student body and advance the well being of the student body.

We were also highly impressed with DSG presidential candidate Will Passo. Passo’s ability to articulate his ideas for the future of DSG speaks

highly of his ability to potentially lead the student government. Duke Democrats would no doubt favor Passo for president because he has served as

a Duke Democrat executive. Yet the Republicans were still extremely impressed by his former DSG service and his platform for DSG president. Of

the three candidates, Will Passo seems to be the biggest advocate for us—something we need from a DSG president—and personally and

professionally would find him to be an asset as our DSG president.

Justin Robinette

Chair, Duke College Republicans

Trinity ’11