Many of you will, no doubt, remember Lindsay Shepherd.
She was the teaching assistant in the Department of Communications at Wilfrid Laurier University, who was subjected to a three-member panel of inquiry after she showed a video taken from Canadian Public Television of me debating the compelled speech legislation introduced in Federal Bill C-16.
She showed my discussion with Nicholas Matt, who held the opposite position.
Here is part of the discussion in question.
The three-member panel included professors Nathan Rambucana, her supervisor, Herbert Pimlot, in charge of the master's program, and Adria Joel, manager of gendered violence and sexual assault prevention.
Shepard taped the meeting and released it publicly, producing what I think was the biggest scandal that ever enveloped a Canadian university, and certainly the only one in living memory that became news internationally.
The thing is, can you shield people from those ideas?
Am I supposed to comfort them and make sure that they are insulated away from this?
Like, is that what the point of this is?
Because to me, that is so against what a university is about.
So against it.
I was not taking sides.
I was presenting both arguments.
So the thing is about this is, if you're presenting something like this, you have to think about the kind of teaching climate that you're creating And this is actually, these arguments are counter to the Canadian Human Rights Code.
Ever since, I know that you talked about C16, ever since this passed, it is discriminatory to be targeting someone due to their gender identity or gender expression.
So bringing something like that up in class, not critically, and I understand that you're trying to like...
It was critical.
I introduced it critically.
How so?
Like I said, it was in the spirit of debate.
Okay.
In the spirit of the debate is slightly different than being like, okay, this is a problematic idea that we want to unpack.
But that's taking sides.
It's taking sides for me to be like, oh, look at this guy.
Everything that comes out of his mouth is BS, but we're going to watch anyway.
Okay.
So I understand the position That you're coming from and your positionality.
But the reality is that it has created a toxic climate for some of the students.
How many?
It's great.
Like how many?
One?
May I speak?
I have no concept of how many people complained, what their complaint was.
You haven't shown me the complaint.
Yes, I understand that this is upsetting, but there's also confidentiality matters.
The number of people is confidential?
Yes.
Although the university apologized publicly for its treatment of Shepard, as did Rambucana, it is not clear at all that the powers that be, so to speak, learned their lesson, and the mistreatment of Shepard not only continued, but arguably intensified.
So, she decided to press her case legally and presented a statement of claim against the three and Wilfrid Laurier early in the second week of June.
It lists in painful detail the many ways that this situation was mishandled during and after the initial Inquisition.
I also discussed the situation with Howard Levitt, Shepard's lawyer.
I decided that Wilfred Laurier had learned very little from its public embarrassment and that Shepard's claims were valid, justifiable and necessary, including her statement that her future lack of employability in academia was improbable, to say the least.
I've been on hiring committees and I can tell you that even the slightest whiff of scandal is enough to disqualify a candidate.
In consequence, not only did I decide to read and post the entirety of Shepard's claims, which I will do in a few minutes, I also decided to launch a claim of my own against the same defendants.
I thought that two lawsuits might make the point better than one.
I'll read some of my claim too after Shepard's, and you can all make up your own minds about the suitability of this course of action.
Ontario, Superior Court of Justice.
Between Lindsay Shepard, plaintiff, and Nathan Rambucana, Adria Jewell, Herbert Pimlot, and Wilfrid Laurier University, defendants.
Statement of claim.
To the defendant, a legal proceeding has been commenced against you by the plaintiff.
The claim made against you is set out in the following pages.
If you fail to defend this proceeding, judgment may be given against you in your absence and without further notice to you.
To Nathan Rambucana, and to Adria Joel, and to Herbert Pimlot, and to Wilfrid Laurier University.
The plaintiff claims the following against the defendants, individually and cumulatively, the following.
$500,000 for the tort of harassment.
$500,000 for the tort of intentional infliction of nervous shock.
$500,000 for the tort of negligence.
$100,000 for constructive dismissal.
Aggravated damages in the amount of 500,000.
General damages in the amount of 500,000.
Punitive damages in the amount of a million dollars.
The plaintiff resides in the town of Waterloo in the province of Ontario.
The defendants Herbert Pimlot and Nathan Rambucana are professors at the defendant Wilfrid Laurier University.
Pimlot was the coordinator for the master's program of the university, and Rambucana, at the relevant time, was the professor for the course, which Shepard was a teaching assistant for.
Both had considerable influence over the plaintiff's employment as a teaching assistant and status as a master's student.
The defendant, Adria Joel, was, at all relevant times, acting manager of the University's Diversity and Equity Office, in charge of gender violence prevention.
The defendant, University, is a creature of statute, created pursuant to the provisions of the Wilfrid Laurier Act.
The university is vicariously liable for all of the conduct of the individual defendants referred to herein, and, at all relevant times, created an environment supporting and facilitating, acquiescing to, and implicitly, and sometimes explicitly, endorsing that conduct.
The Constituent Statute of the University, the Wilfrid Laurier Act, 1973, as amended, 2001 and 2016, in providing the fundamental jurisdiction and authority for the University to operate, states as its object in section 4, that the objects of the University are for the pursuit of learning through scholarship, teaching and research, within a spirit of free enquiry and expression.
The university has no other object and no jurisdiction to operate otherwise.
The university has no other object and no jurisdiction to operate otherwise.
Pursuant to Section 5, Powers of the University, the Act further states that the university has all powers necessary and incidental to the satisfaction and furtherance of its objects, as a university.
The constituent statute, creating and empowering the university, provides it with no other power or authority.
Shepard was, at all relevant times, a student in the university master's program, pursuing her master's degree and employed as a teaching assistant for a course under Rambucana and following that under Professor Judith Nicholson.
As a teaching assistant, Shepard supported a class taught by Professor Rambucana.
She was generally responsible for teaching two groups of approximately 25 students, was assigned topics, and was entitled, pursuant to the policies of the university and of Rambucana, to devise her own curriculum.
Rambucana was an indifferent mentor, who had only met with Shepard twice about his course, and only then briefly.
Ironically, given his complaint against her as delineated below, he provided her with very limited direction as to the content to provide to her students in his classes.
The topic for one of her communication classes, held on November 1, 2017, was grammar.
She taught three classes that day.
Shepard introduced the topic of the grammatical correctness of gender-neutral language in the evolution of various languages and, to facilitate discussion on the subject, showed a few-minute extract from a TV Ontario program moderated by Stephen Paikin, consisting of a debate between Professor Jordan Peterson of the University of Toronto's Psychology Department and Nicholas Matt from the University of Toronto's Sexual Diversity Studies program.
Peterson and Nicholas Matt were debating compelled gender pronouns.
Peterson argued against being required to use these new words which, he argued, had not developed organically.
Matt took an opposing position.
Shortly following that class, Rambucana ordered her to attend a meeting the very next day with himself, Pimlot, the program coordinator for the entire master's program, and Adria Joel, acting director of the diversity and equity office.
Both Rambucana and Pimlot had considerable authority over Shepard's fate at the university.
Apparently, so did Joel.
Shepard had never been called into such a meeting.
Indeed, Rambucana, to that point, had barely acknowledged her existence.
At this session, all three lambasted Shepard, viciously attacking her personally, falsely alleging that there had been a complaint or complaints about her tutorial, and insisting that, in playing the TV Ontario clip, she had been threatening to her students.
Rambucana claimed that her showing this TVOntario clip breached the Charter of Rights and Freedoms and Federal Bill C-16, which does not even govern provincially regulated universities, created an unsafe learning environment and was illegal.
Shepard was accused of targeting trans folks, even though Shepard had chosen no side, had up till that point disagreed with what she understood to be Peterson's perspective and presented the arguments and the debate neutrally.
Rambucana attacked and slandered Peterson, claiming that he was part of the alt-right and that playing a clip of Peterson, without first providing any previous context to the students, was like neutrally playing a speech by Adolf Hitler.
Shepard argued that doing as he asked would be taking sides and that was not her role.
She was then further rebuked for taking that position.
At various points, during that almost hour-long vicious and abusive attack, Shepard was reduced to tears.
Ironically, rather than being a present-day personification of Adolf Hitler, as Rambucana implied, Jordan Peterson has spent decades educating his students about the evils of the Holocaust and, specifically as part of his psychological teachings, has studied and taught how individuals degenerate ethically to the point where they take part in atrocities.
As part of his psychological teachings, he has studied and taught how individuals degenerate ethically to the point where they take part in atrocities.
During the meeting, Shepard was effectively attacked as a protege and supporter of Peterson.
Pimlot continued to libel Peterson, explaining that people like him live in a fantasy world of false conspiracy, and accusing Shepard of being an agent of those ideas because she had neutrally shown this video with its opposing viewpoints.
Rambucana falsely, but imaginatively, claimed that Shepard herself was targeting people based on their gender identity or gender expression, and in doing so had violated the Federal Human Rights Code of Bill C-16, although Shepard's conduct was in no way violent of that or any law.
Shepherd asked the individual defendants whether her job as a teaching assistant was to shield her students from debate and ideas.
Rambucana asserted that it was and then accused her of targeting students due to their gender expression and identity.
When Shepherd pointed out that she had not taken sides in this debate, the three rebuked her for creating a toxic climate.
The three refused to advise Shepard what the complaint was or who complained, claiming that even the number of complaints was confidential.
As was subsequently ascertained, there had been no complaint at all.
Shepard protested that she did not understand how her teaching methods constituted any disservice to the university, since the ideas in the video were already part of social currency.
Joel responded without any foundation, accusing her of spreading transphobia.
Rambucana added to Jewell's attack by essentially comparing her actions to white supremacy.
Contrary to the allegations of the defendants at this meeting, Shepard conducted herself at this seminar precisely as her role required and singularly represented the principles of the Wilfrid Laurier University Act.
For this, she was viciously attacked by Rambucana, Pimlot, and Joel.
They continued to abuse her even after she began sobbing, accusing Shepard of causing harm to unnamed students.
Shepard apologized for crying during the meeting, pleading, I am stressed out because to me this is wrong, so wrong, noting that the very spirit of the university is to challenge ideas that you already have and reminding them that she had not taken any side or position.
The meeting concluded with Shepard being advised, even after she promised to show no further videos of Peterson or anything of the like, that she now had to run all of her seminar notes past Rambucana, to obtain specific approval for any future clips of anyone that she attended to show, and that Rambucana might have to sit in on her future classes.
She was prohibited from showing any further videos.
Finally, they suggested to her that her job might be in jeopardy.
The conduct of the defendants was objectively outrageous and flagrant.
They had reckless disregard for the fact that the foreseeable consequences of their conduct would cause Shepherd to suffer emotional stress, which it did.
There are various policies of the University which constitute a contract between the University and its members, including Shepherd.
Article 1.01 of the Procedures Relating to the Prevention of Harassment and Discrimination, Policy 6.1 of the University, notes that informal resolution possibilities, as well as emotional, academic, and departmental supports, will be explored.
None of this occurred.
It also noted in Article 1.02 of the Procedures Relating to the Prevention of Harassment and Discrimination Policy 6.1 that, if the concern falls outside of this policy's jurisdiction, or could be more appropriately dealt with elsewhere, the individual would be referred to the appropriate office.
That also did not occur.
Under Article 3.02 of Policy 6.1, the Office of Dispute, Resolution and Support will determine whether a complaint may go forward.
Article 3.04 states that the Office is available to provide guidance on the preparation of a complaint or response to a complaint.
That guidance was not provided to Shepard.
Article 5.01 of Policy 6.1 states that an investigation may be required when other efforts to resolve the complaint have not been successful or are not appropriate.
In the complaint by Jackson, referred to below, no other efforts to resolve the complaint were considered before proceeding to the formal investigation of Sheppard.
Article 8.03 of Policy 6.1 states that Wilfrid Laurier University's prevention of discrimination and harassment policy is not intended to inhibit academic freedom.
It was used by Rambucana, Joel and Pimlot for precisely that purpose.
Article 8.05 notes that the university may take disciplinary action against those who make allegations of harassment or discrimination which are reckless, malicious or not in good faith.
Although Pimlot, Rambucana, and Joel had acted recklessly, maliciously, and in bad faith, and it was ultimately determined by the university that this meeting never should have occurred, no action has been taken by the university against them, and Shepard was provided no protection from their predations.
The Prevention of Harassment and Discrimination policy provides, in Article 1.02, that each member of the campus community is responsible for helping to create an environment that promotes mutual respect and understanding for the dignity and rights of others.
This policy was violated by Rambucana, Pimlock and Jewell.
The Prevention of Harassment Discrimination Policy defines workplace harassment in Article 2.04 as engaging in a course of vexatious comment or conduct against a worker in the workplace that is known or ought reasonably to be known to be unwelcome or workplace harassment.
This provision, too, was violated by Rambucana, Pimlott and Joel.
Article 2.07 defines a poisoned environment as where harassing or discriminatory behaviors are severe and or pervasive and cause unreasonable interference with a person's study or work environment.
A poisoned environment may be created.
A poisoned work or learning environment is one that is intimidating, hostile and or offensive.
A poisoned environment can arise even from a single incident.
It may be created by the comments or actions of any person, regardless of his or her status.
Rambucana, Pimlott and Joel created a poisoned work environment for Shepard and thereby breached the university's contractual obligations to Shepard.
Article 4.04 states that the university will take appropriate steps to fairly investigate and respond to allegations of discrimination and or harassment in accordance with the procedures relating to this policy.
No such steps were taken.
Instead, Shepherd was wrongly attacked by the members of the administration until public and alumni outcry forced the university to retreat from its position.
Following this meeting being publicized, McClatchy, president of the university, was interviewed on The Agenda by Steve Pakin, the same show from which the clip of the debate between Dr.
Peterson and Matt was taken.
She was repeatedly asked by Pakin whether Shepard had done anything wrong by showing this clip from his earlier show.
McClatchley effectively defended the conduct of Rambucanna, Joel and Pimlot.
She refused to acknowledge that Shepard had not acted improperly, despite Pakin's continuing to press her on this.
Shepard had the foresight to taper Inquisition when it began, and after outrage from the public and alumni erupted, the president of the university, Deborah McClatchy, and Rambucana issued apologies.
In Rambucana's forced apology, he continued to lie, still insisting that there had been a complaint, and that he had been doing his duty by addressing it.
It was only when public and alumni outrage grew that McClatchy was ultimately forced to admit that what happened to Ms.
Shepherd in the meeting was shameful and that the material she showed was entirely appropriate.
That was a quote.
This was only after an investigator found that there never had been any complaint, formal or informal, and that Rambucana, Pimlots, and Joel's statements to the contrary were false and deceitful.
The university admitted in this statement from its president that this meeting never should have happened at all.
No formal complaint, nor even an informal concern relative to university policy, had been registered as to the screening of the video.
The president, only when besieged, acknowledged that these errors in judgment were compounded.
By the misapplication of the university's policies and procedures, that basic guidelines and best practices on how to appropriately execute the roles and responsibilities of staff and faculty were ignored or not understood, that procedures on how to apply university policies and under what circumstances were not followed, and that the institutional failure allowed this to happen.
The President noted that, as there was institutional failure, the responsibility ultimately started and ended with her.
She further acknowledged that Ms.
Shepherd was targeted with vitriol by members of the University.
McClatchy admitted that Shepard was involved in absolutely no wrongdoing, and publicly stated that the university was taking action to ensure that this did not occur again, a claim that was, and remains, entirely false.
Shepard has never received redress of any kind, nor has she been consulted about the input that this treatment has had on her and her career prospects.
Instead, She was subjected to continuing abuse and a toxic climate from the University and its representatives, as described below.
In McClatchy's apology on November 21, 2017, she states that,"...supports were in place to support student involvement in a situation who are targeted with extreme vitriol through the situation." Yet, she and the University offered Shepard no such support.
In McClatchy claiming to be troubled by the way, quote, everyone, end quote, involved in the situation was targeted with extreme vitriol, she showed the same and equal concern for Shepard's predators as for Shepard herself.
The President also acknowledged that the rationale for invoking the gender and sexual violence policy did not exist, that it was misapplied, and that this was a significant overreach.
Shepard relies on McClatchy's admissions herein.
McClatchy claimed that, quote, Laurier is committed to the abiding principles of freedom of speech and freedom of expression, end quote.
Her conduct throughout entirely betrayed that goal.
In Rambucana's disingenuous apology to Shepard on November 21, 2017, he stated, open quote, while I still cannot discuss the student concerns raised about the tutorial, end quote, But no student concern had even been raised about the tutorial prior to his and his co-defendant's bullying of Shepard.
He acknowledged that his meeting with a panel of three people would be an intimidating situation for Shepard and would not have invited a productive discussion.
Rambucana's apology claimed that he, quote, did not do enough to try to support her, Shepard, end quote, when he did absolutely nothing at all, but instead attacked her.
Following the public outcry, the next time Shepard met with her students, the chair of the Department of Communications, Peter Erkehart, attended that tutorial and offered Shepard students, but not Shepard, emotional support, suggesting that they would be welcome to go to the campus wellness center.
He sat at the back of the room for the entire tutorial, effectively shutting down any discussion on the issue and undermining Shepard's role in her classroom.
Erkehart proceeded, on behalf of the university, to publicly insult Shepard.
When asked by email by Maclean's magazine why he appeared in her class on that day, he responded,"...I assume she recorded it.
Why not ask her for the recording?" He then sent McLean's a second email.
Sorry, you're a pro.
I should have assumed that you've already heard that particular recording, using his position of power and authority over Shepard to intimidate and embarrass her publicly.
Professor Alicia Slawinski, who Shepard was taking a master's course from, asked in front of the class for Shepard to put away her laptop, and then said in front of other master's students that she gave this instruction, because she did not want to be recorded, even when Shepard assured her that she was not recording the class, further alienating and creating a toxic environment for Shepard.
Following these events, Rambucana's course ended and Shepard was assigned to be the teaching assistant to Professor Judith Nicholson, a professor of communication, who had publicly taken a negative position against Shepard prior to Shepard being assigned to her.
Before that semester even started, Nicholson had signed an open letter supporting Pimlot and Rambucana.
This made the university assigning Shepard to her tutelage entirely inappropriate, created a poisoned environment for Shepard, and made it impossible for her to succeed.
Shepard's apprehensions about Nicholson's lack of objectivity toward her were quickly borne out.
On three occasions, during their relatively brief dealings, Nicholson, without provocation, harassed and abused Shepard and deliberately created difficulty for her.
From the outset of their meeting, Nicholson told Shepard that it was her, quote, academic freedom, end quote, and that no one is permitted to make the university look bad, implying that Shepard had improperly done so.
On the second occasion, she sent out a course syllabus with a territorial acknowledgement, i.e.
a reference to the Aboriginal tribe which had once been on the land which Wilfrid Laurier was on.
Shepard, considering this irrelevant to the syllabus and a ludicrous act of political correctness and virtue signaling, cut out that part of the note and tweeted it, noting that such acknowledgements were now even on the syllabus of university courses.
Nicholson demanded in front of the other teaching assistants that she delete her tweet.
When Shepard protested that all she was tweeting was the university logo with the course name and territorial acknowledgement, Nicholson threatened to take her to the dean if she did not remove it.
Nicholson also absurdly claimed that this territorial acknowledgement was her intellectual property.
She proceeded to complain to the dean about Shepard's tweet in an attempt to further endanger Shepard's position in the university.
The dean informed Nicholson that the acknowledgement was not her intellectual property.
And called an urgent meeting with the two departments which Shepard was associated with, the Communication Studies and the Cultural Analysis and Social Theory departments, at least in part, to discuss these issues.
It was clear that if Shepard had tweeted positively about the land acknowledgement, she would not have been in difficulty with Nicholson.
The third occasion was in March 2018 when Shepard needed to reschedule her last class of the year and utilize polling software with a link to available alternate days for her class to fill out their available alternate dates.
When Shepard found times that all of her students were available to meet, she emailed Nicholson to seek her approval for the new dates.
Nicholson reprimanded her, copying two deans, claiming falsely that Sheppard had moved these classes without Nicholson's consent in advance, even though the letter was just such a request, and the request on its face was premised on Nicholson's consent.
When Shepard advised Nicholson that she never had any intention of changing the date without Nicholson's approval, which was why her letter explicitly requested that approval, Nicholson cancelled Shepard's tutorial entirely.
This was despite the fact that alternate dates were available for Shepard and her students to attend.
Nicholson instructed Shepherd's students to attend sessions of the other teaching assistants on dates which were largely coincident with dates which Shepherd and her students had arranged.
Since this was to have been Shepherd's last class, she never saw her students again.
Ethan Jackson, a transgender activist who has attacked Shepard throughout the events described herein, launched a formal, patently frivolous harassment complaint against her, to which, even after Ms.
Shepard had completed her coursework at the university so she would not see Jackson again, The university responded by proceeding with a formal investigation, despite its inherently vexatious, bad faith and frivolous allegations, which, pursuant to the applicable policies, the university should not have proceeded with.
Jackson had an online crowdfunding page seeking a sex change operation which was initially denied because of his mental health issues.
Additionally, Jackson was banned from the University of Waterloo campus in 2013 for protesting and deplatforming a member of parliament who was to give a speech on abortion by dressing up as a giant vulva and yelling.
Jackson was invariably hostile to Shepard.
Jackson's allegations against Shepard were that A.
She was on her telephone during one class and purportedly disengaged from participation in that class.
B. Ms. Shepard had made four tweets with screenshots from Jackson's controversial social media account.
C. Shepard responded to Jackson walking into the printing room and angrily ordering her to leave the room and cease using the communications department printer, which she required for her communications coursework by referring to him as petty and pathetic.
When Shepard and two others were putting up posters for a Laurier Society for Open Inquiry meeting, he claimed that they had followed him and his colleague as they were walking around the halls and that Shepard's posters had signage which he found offensive, posters which he acknowledges removing from the walls without authorization.
The complaint of Jackson was made maliciously after classes were over for the year, at a time when he and Shepard would not ever be interacting again since Shepard is not enrolled in Laurier courses for the following session.
Despite Jackson's complaint being inherently self-contradictory and ludicrous, the University not only proceeded to summon Shepard for an investigation, but threatened her with repercussions if she disclosed Jackson's complaint to anyone.
The attacks on Shepard have rendered her unemployable in academia, resulting in her abandoning her previous ambitions of obtaining her PhD or even teaching at a university as a master's graduate.
Shepard has suffered nervous shock as a result of the conduct of the defendants, which was the foreseeable and intended result.
In the alternative, it was the reasonably foreseeable outcome of their conduct, and the defendants were negligent in their treatment of her.
So that's Shepard's claim.
As I said after I reviewed this and talked in detail to Shepard's lawyer, I concluded that Wilfred Laurier had not learned what needed to be learned and launched a claim of my own this week.
It reads in part...
The plaintiff, that's me, claims against the defendants, Nathan Rambucana, Herbert Pimlot, Adria Jewell, and Wilfrid Laurier University, the following, $500,000 for defamation, $500,000 for injurious falsehood, $500,000 in punitive damages, Pre-judgment and post-judgment interest in accordance with the Courts of Justice Act, costs on a substantial indemnity basis, and such further and other relief as counsel may advise and this Honorable Court may deem just.
The Plaintiff's Claim Against Rambucana, Pimlott, Joel and the University.
Defamatory Statements on YouTube.
On or about November 2, 2017, Rambucana ordered his then teaching assistant, Lindsay Shepard, to attend what turned out to be a disciplinary meeting with himself, Pimlott and Joel to discuss her having shown an extract from a TV Ontario program to her students.
The TVOntario program, moderated by Steve Pakin, consisted of a debate between Peterson and Nicholas Matt.
At the meeting on or about November 2, 2017, Rambucanna, Pimlot and Joel each made numerous defamatory statements about Peterson, all of which the others endorsed, both expressly and implied.
The meeting's content has since been posted online on the video-sharing website, YouTube, and is available on the Internet, where it is open to the public and easily accessible by anyone who wishes to view its content.
I'm skipping a bit here.
At the meeting, on or about November 2, 2017, Rambucana, Pimlot, and Joel falsely and maliciously made numerous defamatory statements about Peterson, including, but not limited, to the following.
A. Peterson identified student protesters by posting their social media accounts for the purpose of other people bullying and threatening them online.
B. Peterson is basically debating whether or not a trans student should have rights.
c. Peterson's position would be the equivalent of debating whether or not a student of color should have rights or should be allowed to be married, contrary to the Charter of Rights and Freedoms.
d. Peterson has engaged in the targeting of trans students, giving out their personal information for the purpose of having them attacked, harassed, so that death threats will find them.
This is something that Peterson has done to his own students.
Peterson has done to other students.
e.
Playing a speech by Peterson is basically like playing a speech by Hitler.
F. Peterson's opinion is like alt-right opinion, white supremacist opinion, anti-trans opinion, anti-gay opinion, anti-woman, misogynist opinion.
G. Peterson's view is whether trans people are people or not.
Defamatory statements made by Pimlot.
Peterson is academically suspect, to say the least.
He does not have the substantial academic evidence to be a credible person.
Peterson's positions don't have credible evidence, just like Charles Murray with his race claims of white superiority.
Peterson brings hatred and targets groups.
Peterson exhibits charlatanism.
Peterson has nothing really that is credible in terms of research.
Defamatory statements made by Joel.
A. Peterson's position is causing harm to trans students by framing their identity as invalid or their pronouns as invalid contrary to the Ontario Human Rights Code.
B. Peterson is spreading transphobia.
Now I'm skipping ahead a bit again.
The said words in their natural and ordinary meaning and the connotation of the comments obvious to any reader were meant and were understood to mean that Peterson is comparable to Adolf Hitler, the greatest despot in world history, deliberately spreads hatred both generally and in particular to students.
is a member of the alt-right is unfit to be a professor breaches the code of ethics of his profession and university is a white supremacist has and expresses opinions which are uninformed and uneducated is sexist is misogynist is racist is homophobic is transphobic is a deplorable person,
is incompetent, is a reprobate, lacks integrity, lacks the appropriate ethics to be a psychologist and professor, is a bully and abusive towards students, wants to deprive minorities of any rights, organizes attacks, even death threats on students, breaches Canadian law, dehumanizes certain of his students, and lacks credibility and credentials.
The statements made by Rambucana, Pimlot, and Joel infer all of the above, including, but not limited to, that Peterson is unsavory, sexist, misogynist, dangerous, racist, homophobic, transphobic, analogous to Adolf Hitler, and incompetent in his profession as an author, teacher, and professor, and were false.
and specifically designed to impugn his reputation.
These defamatory statements were malicious and designed specifically to damage his personal and professional character as a professor, author, lecturer and public intellectual.
Well, you get the picture.
That's the end of that.
I'm hoping that the combination of the two lawsuits will be enough to convince careless university professors and administrators blinded by their own ideology to be much more circumspect in their actions and their words.