Documents Obtained by Public Record Request From University of California, San Diego

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 1 of 46
UCSD 2010-22000001
EXHIBIT TO VERIFIED COMPLAINT FOR DECLARATORY AND

INJUNCTIVE RELIEF
TABLE OF CONTENTS
Exhibit 1
DOCUMENTS OBTAINED BY PUBLIC RECORD REQUEST FROM
UNIVERSITY OF CALIFORNIA, SAN DIEGO......1
EXHIBIT 1
UCSD 2010-22000002
ASSOCIATED STUDENTS
February 25,2010
ALL ACADEMICS AND STAFF AT UCSD
ALL STUDENTS AT UCSD
SUBJECT: Student Run Television (SRTV)
On Thursday night, a deeply offensive and hurtful program was aired on Student Run Television
(SRTV), a service ofthe Associated Students. The content of this program does not represent the
views of the Associated Students, and was aired by KoalaTV, the television show put on by the
student organization The Koala. We condemn the actions of The Koala, its program and its
content.
The Koala was not properly authorized to display content on SRTV. We are in the process of
determining how the program was aired. In the meantime, as authorized by the ASUCSD
Standing Rules, and in conjunction with our Associate Vice President of Student Services, I
turned offthe station to allow for a review of its Charter. We will only open it again when we
can be sure that such hateful content can never be aired again on our student funded TV station.
Alongside this initiative, I have frozen all student media organization funding. The Koala has
long since been a controversial publication at UC San Diego and is primarily funded by our
student fees. I do not believe we should continue funding this organization with our fees.
We must develop effective policies to ensure that our fees do not go to the support the hateful
speech that targets members ofour community. I ask that those media organiz~tions that did
nothing wrong and are unfairly affected to be patient until we can resolve this situation and
develop new funding bylaws for our Association.
To this end, I have charged a campus-wide committee to review the funding of student media.
This committee is open to every member of the UC San Diego community - faculty, staff,
students, and whoever else feels strongly about this issue. The committee shall meet on
Thursday, at 8:00PM, in the 4th floor Price Center Forum. Feel free to email me at
aspresident@Ucsdedu if you have any questions.
The Associated Students stands in solidarity with those affected by Thursday night's program,
and we remain committed to being the voice for all UC San Diego students.
UtsavGupta
Associated Students President
UCSD 2010-22000003
Subject:
Attachments:
Rue, Penny
Friday, March 12, 2010 4:49 PM
Anderson, Lynn; Armstrong, Bill; Barnett Terry, Renee; Brown, Mae; Calfas, Karen; Ceperley,
Andrew; Chadwick, Don; Davalos, Cynthia; DeWine, Paul; Edwards, Earl; Fleming-Magit,
Regina; Guerrero, Rey; Hynes-Wilson, Mentha; Juarez, Reina; Koch, Dave; Lozano, Carmen;
Mahaffey, Patty; Ratcliff, Gary; Rue, Penny; Scott, Patricia; Spriggs, Ed; Stascavage, James;
Thompson, Loren; Valladolid, Tony
Status update
image001.png
Categories:
Dark Red
From:
Sent:
To:
All,Iknowyouareexpectingandawaitingmoreinformationaboutnextstepsasthecampuscomestogripswithour
climateconcernsilluminatedbyourBSUandotheractiviststudents.Beassuredthatmuchisgoingonbehindthe
scenestoplacethecampusinthebestplacegoingforward.
WevebeenworkinghardallweektodottheIsandcrosstheTsontheadministrativecommitments,andthatdocument
willbecomepublicshortlyearlynextweek,Ibelieve.Atthattime,thecommitmentsweareresponsibleforwillbe
veryclear.Wearemakinggreatprogresswithourstudentswhocontinuetoassistinyieldeffortsandtheearlycalling
campaign,andtheBlackLifeBookhasgonetopress.WehavemetwithAfricanAmericancommunityleaderstolisten
totheirconcernsandsuggestions.
StudentAffairswillcontinuetoforgeaheadonadditionalideasthatwehaveforimprovingclimate,includingstudent
leadertraining,intergroupdialogue,bystandertraining,enhancedorientation,moreprominentbiasreporting,and
greateracademicconnections,includingtheveryrealpossibilityofaUniversitywidecourse.
Thatsthegoodnews.Wealsocontinuetorespondtomountingpressurefromavarietyofsourcesoutsidethe
universitythatthreatenourabilitytolead,andthathasconsumedandwillcontinuetoconsumemostofmytimeand
energy.
StatelegislatorsareplanningforaforumonAddressingIntoleranceinHigherEducationaimedspecificallyatus.
http://democrats.assembly.ca.gov/members/a52/News_Room/Press/20100310AD52PR01.aspx
ThespeakeroftheStateSenatehasaskedforaresponsetoadetailedsetofquestionsaboutcampuspolicies,
investigations,andsanctionsregardingactsofracismandvandalism.
TheJusticeDepartmentOfficeofCivilRightshasinitiatedaninquiry.
Ontheotherhand,conservativegroupsarecriticizingusforourhandlingofthecampusmediaandhaveexpressed
concernsaboutpossibleviolationsofProp209.Theseinclude:
PacificLegalFoundation
ACLU
FIRE
StudentPressLawCenter
UtsavhasworkedtirelesslytofindawaytodisestablishtheASrelationshipwiththeKoala,butaconcertedeffortby
othermediagroupsandthespotlightofupcomingelectionshashamperedhisefforts.Icannottellyouhowbadablack
eyeitisfortheUniversitythatwedonotseemtohavethepowertocutourtiestothisbody.Ifyouhaveanyinfluence
withcampusmediagroupswhofearfortheircontinuedfunding,anythingyoucandowouldbevaluabletoreassure
themthatiftheycareabouttheUniversity,itwouldbehelpfulforthemtolookatthebiggerpicture,andthattheir
fundingwillbesecuregoingforwardoncewehaveweatheredthisdifficultpatch.
UCSD 2010-22000004
Thanksforallthatyouaredoingtoconnectwithstudentswhoarestrugglingorconfused,orwhoneedhelpin
understandingwhatthelargerissuesare.ThisisatimewhereStudentAffairscancometotheforefrontinhelpingour
universitymoveforward,andIwillcountonallofyoutohelp.PleasekeepmepostedonissuesthatyouthinkIshould
beawareof.Best,Penny
Penny Rue, Ph. D.

Vice Chancellor-Student Affairs
University of California, San Diego
La Jolla, CA 92093
858-534-4370 (ph)
858 534-1340 (fx)
How will you invent the future?

To learn more, click here.
UCSD 2010-22000005
From:
Sent:
To:
Cc:
Subject:
Ratcliff, Gary [grratcliff@ucsd.edu]

Wednesday, March 17, 2010 6:17 PM
Brink, David
Rue, Penny
RE: Koala
Categories:
Dark Red
David:
Ifyouhavethetimeforaconversationovercoffee,IcansharewithyouthelegallysoundmethodsthatbothDanPark,
thecampuscounsel,andIhaveadvisedstudentleaderstoconsiderinordertodiscontinuestudentgovernmentfunding
oftheKoala.Iwouldappreciatehearingyourthoughtsonthesubject.
Regards,
GaryRatcliff
AssistantViceChancellorofStudentLife
From: Rue, Penny [mailto:prue@ucsd.edu]

Sent: Wednesday, March 17, 2010 6:04 PM
To: Brink, David
Cc: Ratcliff, Gary
Subject: RE: Koala
David,wecoulduseyourhelp;Iamasdistressedasyou.WereworkingverycloselywithCampusCounselonthisone
andlookingforcreativesolutions.ItsapoliticalbattlewithintheAssociatedStudentsrightnowandelectedmembers
arenotanxioustoalienatealltheotherpublicationsbythelegalviewpointneutralremediestheyhave.Ifyouvegota
creativelegalsolution,wedlovetohearit.Best,Penny
From: Brink, David [mailto:dbrink@ucsd.edu]

Sent: Wednesday, March 17, 2010 5:59 PM
To: Rue, Penny
Cc: Lerer, Seth
Subject: Koala
DearViceChancellorRue,
SomeofmycolleagueshavebeendistressedtolearnthattheKoalaisstillsupportedby
studentfees.Thereseemstobeasignificantdifferencebetweencensorshipandsubsidy.
Theremightbeconstitutionalproblemswithoutrightcensorshipofdiscriminatory
speechorhatespeech,thougheventhisisdebatable.Butitseemseasiertojustifyrefusal
tosubsidizediscriminatoryorhatespeechthatviolatesUCSDPrinciplesofCommunity.
Backin2006LarryAlexander,whoisaconstitutionalscholaratUSDLawSchool,andI
heldapaneldiscussionattheUCSDCrossCulturalCenteronthelimitsofdiscriminatory
speech.LarryandIhaveverydifferentviewsanddisagreeaboutthepermissibilityof
censoringhatespeech,butwewereagreedthatevenifhatespeechcannotbecensoredit
doesnotneedtobesubsidizedifitviolatescampusprinciplesofnondiscrimination.I
4
UCSD 2010-22000006
Cc: Kristofco, Clare; Wahlig, Nancy; Davalos, Cynthia

Subject: RE: Bias Incident Report Form
Lori,
Thanks for sharing. I can see why this newspaper can offend most individuals.
Juan
From: Chamberlain, Lori

Sent: Thursday, November 12, 2015 3:08 PM
To: Petitt, Becky; Gonzalez, Juan
Cc: Kristofco, Clare; Wahlig, Nancy
Subject: FW: Bias Incident Report Form
There is no reporting party on this, but I thought you should all see it.
Lori
From:ophd-birf@ucsd.edu [mailto:ophd-birf@ucsd.edu]
To: Dolbeck, Leeann; Chamberlain, Lori; Rogers, Carol; Dalcourt, Elena; Sandulak, Michael; Alcantara,
Denise
Subject: Bias Incident Report Form
Bias Incident Report Form

--------------------------------------------
Incident Information
Date of Incident: 11/12/15
Time of Incident: 12PM
Have you reported this incident to other UCSD offices?
On/Off Campus Location: On Campus
Specific Location: Library walk
Type of Incident: Written Slur / Graffiti, Hate Symbol, IncidentTypeOther
Type of Incident | Other :
Perceived Basis of Incident: Color, Race, Religion
Perceived Basis of Incident | Other :
Description of Incident: The Koala is a newspaper that is solely meant to cause hatred. As a
victim of rape and a miniority in UCSD, I no longer feel safe on campus. I'm utterly offended
by the conent in the newspaper. I will not mention specifcs, but I urge you to read the
newspaper yourself. I am honestly shocked the a purtion of my tution is dedicated to printing
out this newspaper.
How would you like the University to respond: Stop the Koala.
UCSD 2010-22000007
Alleged Offender Information

Name:
Phone:
Email:
UCSD Affiliation: Student
UCSD Affiliation Other:
College: Unknown College or Unselected
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Other information about the Victim:
Reporter Information
Name:
Phone:
Email:
UCSD Affiliation:
UCSD 2010-22000008
From:
To:
Cc:
Subject:
Date:
Petitt, Becky
Park, Daniel
Wahlig, Nancy; Davalos, Cynthia; Silva, Frank; Chamberlain, Lori; Gonzalez, Juan; Kristofco, Clare; Briggs Addo,
Ann; Cole, Joshua
RE: Bias Incident Report Form
Friday, November 13, 2015 10:39:23 AM
Thanks, Dan. Id like to think creatively about how we can address this. Ill ask Joshua to
coordinate a meeting.
brp
From: Park, Daniel

Sent: Friday, November 13, 2015 10:26 AM
To: Kristofco, Clare; Petitt, Becky; Gonzalez, Juan; Chamberlain, Lori
Cc: Wahlig, Nancy; Davalos, Cynthia
Subject: Re: Bias Incident Report Form
Becky,
Clare is right that this issue has come up before. If it would help, I would be happy to participate in
a meeting to discuss the legal landscape.
From: Clare Kristofco <ckristofco@ucsd.edu>

Date: Thursday, November 12, 2015 at 4:39 PM
To: "Petitt, Becky" <bpetitt@ucsd.edu>, "Gonzalez, Juan" <juangonzalez@ucsd.edu>, Lori
Chamberlain <lachamberlain@ucsd.edu>
Cc: "Wahlig, Nancy" <nwahlig@ucsd.edu>, "Davalos, Cynthia" <cdavalos@ucsd.edu>, "Park,
Daniel" <dwpark@ucsd.edu>
Becky,
We have been down this path many times over the years for even more egregious issues. Ive copied
Dan Park, as we always end up in the legal counsels office for advice.
Clare
From: Petitt, Becky

To: Gonzalez, Juan; Chamberlain, Lori
Cc: Kristofco, Clare; Wahlig, Nancy; Davalos, Cynthia
Im likely in the minority here, but I think this crosses the free speech line and Id like to
explore ways we can do something about it. I know its a delicate undertaking.
brp
From: Gonzalez, Juan

To: Chamberlain, Lori; Petitt, Becky
UCSD 2010-22000009
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Petitt, Becky; Gonzalez, Juan
Kristofco, Clare; Gary Ratcliff; Park, Daniel
Fwd: Bias Incident Report Form
Tuesday, November 17, 2015 1:19:55 PM
Sent from my iPad

Begin forwarded message:
From: <ophd-birf@ucsd.edu>
Date: November 17, 2015 at 12:24:05 AM PST
To: <ldolbeck@ucsd.edu>, <lachamberlain@ucsd.edu>, <clrogers@ucsd.edu>,
<edalcourt@ucsd.edu>, <msandulak@ucsd.edu>, <dalcantara@ucsd.edu>

--------------------------------------------
Date of Incident: 11-16-15
Time of Incident: 11:00 pm
Have you reported this incident to other UCSD offices? No
Specific Location:
Type of Incident: Online Harassment, Written Slur / Graffiti
Perceived Basis of Incident: Color, Race
Description of Incident: The campus newspaper The Koala published an explicitly
racist article mocking safe spaces. They even use the racial slur "nigger" multiple
times. The article says that a "dangerous space" will be created in front of Geisel
to contrast the safe spaces such as the black resource center. The article says in
such a space people can yell slurs and do whatever they wish.
How would you like the University to respond: The university needs to stop
funding the Koala, and stop endorsing it.
UCSD 2010-22000010

Name: The koala
Phone:
Email:
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
UCSD Affiliation:
UCSD 2010-22000011
From:
To:
Subject:
Date:
ophd-birf@ucsd.edu
Dolbeck, Leeann; Chamberlain, Lori; Rogers, Carol; Dalcourt, Elena; Sandulak, Michael; Alcantara, Denise

--------------------------------------------
Time of Incident: 6:00pm
Specific Location: Newspaper
Type of Incident: Written Slur / Graffiti
Perceived Basis of Incident: Race, Sex, Sexual Orientation
Description of Incident: The newspaper mocks safe spaces, and other resources used for
students who have had and are continuing to have experiences being victimized such as
CARE. It propagates insensitive mindsets with its sexist and racist comments masked under
cruel humor.
How would you like the University to respond: Screen works to make sure that there is no
propagation of these attitudes

Name: The Koala
Phone:
Email:
UCSD Affiliation: Other
UCSD Affiliation Other: Newspaper
10
UCSD 2010-22000012
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
UCSD Affiliation:
11
UCSD 2010-22000013
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Another.
Sent from my iPad

--------------------------------------------
Specific Location: Student org meets on campus
Type of Incident: Verbal Harassment, Online Harassment, Written Slur / Graffiti,
Hate Symbol
Perceived Basis of Incident: Age, Ancestry, Citizenship, Color, Disability, Gender
Identity, National Origin, Race, Religion, Sex, Sexual Orientation
Description of Incident: The UCSD Koala has been known for producing hate
speech toward student demographics that are extremely triggering and
frequently make me feel unsafe on this campus. Last night they released an
article on thekoala.org that mocked students' need for safe spaces, and included
allusions to sexual violence and racist acts. Last week they also released an article
slandering, objectifying, and threatening to black women. And as a black woman
it has made me and others in my community feel threatened.
12
UCSD 2010-22000014
How would you like the University to respond: I would like to see UCSD dismantle
The Koala immediately. While I understand the need to protect free speech, this
institution is choosing to promote hate speech on this campus. For many many
MANY people, UCSD already feels unwelcoming. It is painful to read threats
against my body made in a school-funded newspaper. It's gross and terrifying,
and extremely bad for incoming students on tours who get handed the paper and
are taught that UCSD is a prejudiced institution from The Koala.

Name: The Koala Newspaper
Phone:
Email:
UCSD Affiliation Other: Student Organization
Victim Information
Name:
Phone:
Email:
Other information about the Victim: The general student body is always
complaining about The Koala, and nothing is ever done as if UCSD truly does not
care for the well-being of the seemingly vast majority of its students.
Name:
Phone:
Email:
13
UCSD 2010-22000015
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Sent from my iPad


--------------------------------------------
Have you reported this incident to other UCSD offices? no
On/Off Campus Location:
Specific Location: Online UCSD Website: http://thekoala.org/
Type of Incident: Verbal Harassment, Online Harassment
Perceived Basis of Incident: Gender Identity, Race
Description of Incident: The Koala is directly disrespectful and intolerant of the
UCSD community and its campus climate. While UCSD promotes safe spaces for
students to discuss the issues and their experiences, the most recent article of
The Koala, titled "UCSD Unveils New Dangerous Space on Campus," promotes
hate speech and perpetuates racism and sexism. UCSD should have no place or
space for such discrimination.
How would you like the University to respond: Defund and shut down The Koala.
14
UCSD 2010-22000016

Name:
Phone:
Email:
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
UCSD Affiliation:
15
UCSD 2010-22000017
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
And another.
Sent from my iPad

--------------------------------------------
Time of Incident: 12:00PM
Have you reported this incident to other UCSD offices? Yes, I called the OFHD.
Specific Location: Technically, on and off. It is a newspaper that is online and on
campus
Perceived Basis of Incident: Color, Disability, Gender Identity, Genetic
Information, National Origin, Race, Religion, Sex, Sexual Orientation
Description of Incident: It isn't really an "incident" as it is an ongoing problem. I
am reporting the Koala, because I was told the more voices you hear from, the
better. This newspaper has offended me, and all of my teammates alike, and
anyone else I have told. I read this "satirical" newspaper and did not laugh once.
Having UCSD fund a newspaper that tells women to get fat if they don't want to
get raped, or tells black people that they could learn to swim by being "face
down in a prison shower" is a disgrace.
16
UCSD 2010-22000018
How would you like the University to respond: I have never been ashamed of
anything that university represents, except for this. Maybe you'd argue that the
university doesn't represent it or support it. But giving it funds is doing just that,
and us being public means the government supports it too. Pull the funds, and
make them turn to personal donations if they want to continue this nonsense.
They have the UC stamp/icon on the paper. UCSD already has a bad racial climate
and this is an obvious contributor that can be eradicated.

Name: The Koala
Phone: not sure if they have one
Email:
Victim Information
Name:
Phone:
Email:
College:
Other information about the Victim: I know that it is hard to get around the
freedom of speech obstacle. But saying that we cannot take away their funding is
incorrect. In my research of The Koala's history, funding was pulled from the
paper by an AS vote. Why can we not renew that vote and decide against the
funding? I think it's plausible. This paper being racist is not just an opinion, it is a
fact. Look at the history of its editors, one having infamously called "BSU and its
allies a bunch of ungrateful n***ers". Coincidence?
Name:
Phone:
17
UCSD 2010-22000019
Email:
18
UCSD 2010-22000020
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
FW: Bias Incident Report Form
Wednesday, November 18, 2015 11:08:37 AM
From: ophd-birf@ucsd.edu [mailto:ophd-birf@ucsd.edu]

Sent: Wednesday, November 18, 2015 11:08 AM
Denise

--------------------------------------------
Time of Incident: 11:00am
Specific Location: saw newspapers online and hard copies
Type of Incident: Online Harassment, Written Slur / Graffiti, Hate Symbol
Perceived Basis of Incident: Color, Gender Identity, Race, Religion, Sex, Sexual Orientation
Description of Incident: I read this newspaper that sends a hateful message to minority
students.
How would you like the University to respond: I would like the University to shut down the
koala newspaper and the creators of the newspaper should be punished by their college
deans.

Name:
Phone:
Email:
19
UCSD 2010-22000021
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Other information about the Victim: This affects everybody on campus
Name:
Phone:
Email:
UCSD Affiliation:
20
UCSD 2010-22000022
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori

Sent: Wednesday, November 18, 2015 10:44 AM
Denise

--------------------------------------------
Date of Incident:
Time of Incident:
Specific Location:
Type of Incident: Verbal Harassment, Online Harassment
Perceived Basis of Incident: Color, Gender Identity, Sex, Sexual Orientation
Description of Incident: The Koala newspaper is disturbing, sexist, racist, and homophobic.
How can something like this be present at an 'inclusive' campus?
How would you like the University to respond: The Koala should be more inclusive or be
banned from being published.

Name: The Koala
Phone:
Email:
21
UCSD 2010-22000023
Victim Information
Name:
Phone:
Email:
Name:
Phone:
Email:
UCSD Affiliation:
22
UCSD 2010-22000024
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori

Sent: Tuesday, November 17, 2015 7:29 PM
Denise

--------------------------------------------
Time of Incident: 12:00pm-1:00pm
Specific Location:
Type of Incident: IncidentTypeOther
Type of Incident | Other : Sexist & Racist Publication
Perceived Basis of Incident: Color, Disability, Gender Identity, National Origin, Race, Sex,
Sexual Orientation
Description of Incident: The Koala newspaper on campus is a disturbing publication created by
certain students who write sexist, racist, and other disturbing topics that I feel are offensive
and harmful to me and many other UCSD students. The Koala has existed for a very long time
now on campus. But I think this newspaper violates many of the principles and morals of this
campus where UCSD should be a safe space and environment that has an inclusive campus
climate for ALL students.
How would you like the University to respond: Stop the UCSD students who are editors and
publishers of the Koala newspaper from continuing to distribute this newspaper on campus. It
is damaging to the self-esteem and overall well-being of many UCSD students on campus.

Name:
23
UCSD 2010-22000025
Phone:
Email:
UCSD Affiliation:
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
UCSD Affiliation:
24
UCSD 2010-22000026
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Sent from my iPad

Date: November 17, 2015 at 1:46:56 PM PST

--------------------------------------------
Date of Incident: 11/16
Time of Incident:
Specific Location:
Type of Incident: Online Harassment
Perceived Basis of Incident: Color, Gender Identity, Race, Religion, Sex
Description of Incident: A newspaper supported by UCSD, The Koala, is clearly
defying the Integrity Policy that all Tritons are required to abide. I am extremely
bothered to witness such hatred expressed in a newspaper supported by UCSD.
This needs to bee solved. I am not paying this school to promote hatred and fund
The Koala. The evidence is easily accessible at thekoala.org.
How would you like the University to respond: The University needs to
immediately take the initiative to end any hate speech, actions, or crimes that
offend any groups represented on campus. Students participating in The Koala
should not be able to share their newspapers with the UCSD students on Library
25
UCSD 2010-22000027
Walk if it defies on our UCSD's "main rules" as understood from the Integrity
Policy. I demand an end to this newspaper.

Name: Members of The Koala
Phone:
Email:
Victim Information
Name: ALL UCSD STUDENTS
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
26
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
We are meeting with this employee on Wednesday, fyi.

Lori
Sent from my iPad

--------------------------------------------
Time of Incident:
Have you reported this incident to other UCSD offices? SARC/CARE
Specific Location: Electronic & handed out at Founders Day
Type of Incident: Verbal Harassment, Physical Harassment, Online Harassment,
Written Slur / Graffiti, IncidentTypeOther
Type of Incident | Other : Sexual Harrassment
Perceived Basis of Incident: Color, Gender Identity, Genetic Information, Marital
Status, Pregnancy, Race, Sex, Sexual Orientation
Description of Incident: The koala's last publication was incredibly offensive. It
included pornographic images and was condoning sexual assault. This should not
be allowed to go to print or be posted to the internet with the UCSD name on it
How would you like the University to respond: Please set up a system for
administrative approval of the content published in the magazine.
27

Name: The Koala
Phone:
Email: editor@thekoala.org
Victim Information
Name: UCSD/ Community
Phone:
Email:
Other information about the Victim: As a student I read the Koala and was
offended, but this goes way beyond what is acceptable in terms satrical op-ed.
Not only have I been affected by this, but have had numerous students come to
me with complaints concerning the publication. Their main concern was that the
koala is funded through AS. I belive this funding is what should be in question
rather than the student's rights to free speech. Thank you for your consideration,
please contact me with any questions!
Name:
Phone:
Email:
UCSD Affiliation Other: Staff/Alumni
28
UCSD 2010-22000030
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Sent from my iPad


--------------------------------------------
Specific Location:
Type of Incident: Online Harassment, Written Slur / Graffiti, Hate Symbol,
IncidentTypeOther
Type of Incident | Other : Newsletter
Perceived Basis of Incident: Color, Gender Identity, National Origin, Race, Sex,
Sexual Orientation
Description of Incident: The Koala has recently published a new newsletter that is
ruining the campus climate and making me and other students feel unsafe at this
university. I believe that while the Koala has the freedom of speech on the
campus, they are in violation of the principles of community in providing an
inclusive space for people. Their student body consists of primarily white
heterosexual people and they continue to oppress students that are already
underrepresented on this campus with continuous hate speech
29
UCSD 2010-22000031
How would you like the University to respond: I believe the University has a very
important role in creating a positive campus climate where all students feel
welcomed on this campus. I believe the administration needs to shut down the
Koala as they have notoriously been discriminating against minorities since their
conception. I believe that they should be held to the same standard that greek
institutions are held and if they are unable to uphold the principles of
community, they should not be a registered organization at UC San Diego.

Name: BRIAN GIORI
Phone:
Email:
Victim Information
Name: All minorities on campus
Phone:
Email:
Name:
Phone:
Email:
UCSD Affiliation:
30
UCSD 2010-22000032
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Sent from my iPad


--------------------------------------------
Time of Incident: 10pm
On/Off Campus Location:
Specific Location: thekoala.org
Type of Incident: Verbal Harassment, Online Harassment, Written Slur / Graffiti,
Hate Symbol
Perceived Basis of Incident: Color, Race, Membership Affiliation
Description of Incident: The latest article in the Koala is blatantly offensive and
preaches a single point of view. It is perpetuating assimilation. I thought this
campus was suppose to be about diversity and equality.
How would you like the University to respond: Permit a student organization to
have control over the campus climate resources. It is evident that UCSD is not
overseeing this hateful rhetoric. Therefore, the students need control to hold
individuals accountable. It is 2015 and this campus is for higher learning not
ignorant babbling.
31
UCSD 2010-22000033

Name: The Koala
Phone:
Email: Editor@thekoala.org
Victim Information
Name:
Phone:
Email:
College:
Name:
Phone:
Email:
UCSD Affiliation:
32
UCSD 2010-22000034
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
I will be forwarding a number of "Bias Incident Report Forms" that we have received
regarding the Koala issue. I am at a mandatory meeting at UCI today and haven't yet
responded to these.
Lori
Sent from my iPad

--------------------------------------------
Have you reported this incident to other UCSD offices? Black Student Union
Specific Location: online.
Perceived Basis of Incident: Color, Disability, Gender Identity, Race, Sex, Economic
Background
Description of Incident: The Koala has posted up a new archive that directly
stigmatizes and attacks students of color, like myself into feeling that this is an
unsafe campus.
How would you like the University to respond: Find ways to address the Koala by
defunding it, finding those complicit in writing,funding, supporting it and putting
33
UCSD 2010-22000035
them on blast for breaking sanctions that make the campus climate cold and
negative.

Name:
Phone:
Email:
UCSD Affiliation:
Victim Information
Name:
Phone:
Email:
College:
Other information about the Victim: I'm a trans southeast Asian and 1st
generation student of color, who does not feel safe and supported or retained on
this campus
Name:
Phone:
Email:
UCSD Affiliation:
34
UCSD 2010-22000036
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
Sent from my iPad


--------------------------------------------
Time of Incident:
Specific Location:
Type of Incident: Verbal Harassment, Written Slur / Graffiti, Hate Symbol
Perceived Basis of Incident: Race
Description of Incident: The Koala uses hate speech to marginalize certain groups
of students on campus, in their most recent issue - the black community. UCSD
should be a place where students feel safe and comfortable in their learning
environment and the Koala inhibits this.
How would you like the University to respond: Defund the Koala.

35
UCSD 2010-22000037
Name: Koala
Phone:
Email: editor@thekoala.org
UCSD Affiliation Other: Newspaper
Victim Information
Name:
Phone:
Email:
UCSD Affiliation:
Name:
Phone:
Email:
UCSD Affiliation:
36
UCSD 2010-22000038
From:
To:
Cc:
Subject:
Date:
Chamberlain, Lori
I will be forwarding a number of "Bias Incident Report Forms" that we have received
regarding the Koala issue. I am at a mandatory meeting at UCI today and haven't yet
responded to these.
Lori
Sent from my iPad

--------------------------------------------
Have you reported this incident to other UCSD offices? Black Student Union
Specific Location: online.
Perceived Basis of Incident: Color, Disability, Gender Identity, Race, Sex, Economic
Background
Description of Incident: The Koala has posted up a new archive that directly
stigmatizes and attacks students of color, like myself into feeling that this is an
unsafe campus.
How would you like the University to respond: Find ways to address the Koala by
defunding it, finding those complicit in writing,funding, supporting it and putting
37
UCSD 2010-22000039
From:
To:
Cc:
Subject:
Date:
Attachments:
Chamberlain, Lori
3 more reports
Bias Incident Report Form.msg
We do not typically receive so many reports regarding a single issue, fyi.
Lori
Lori Chamberlain
Office for the Prevention of Harassment & Discrimination
9500 Gilman Drive, Mail Code 0024
La Jolla, California 92093-0024
(858) 534-0393 (fax)
(858) 534-8297 (phone)
38
UCSD 2010-22000040
39
UCSD 2010-22000041
We really appreciate your concerns and thank you for your part in
promoting the elimination of hate and bias at UCSD.
Sincerely,
Lori
Lori Chamberlain
Office for the Prevention of Harassment & Discrimination
9500 Gilman Drive, Mail Code 0024
La Jolla, California 92093-0024
(858) 534-0393 (fax)
(858) 534-8297 (phone)

Sent: Tuesday, November 17, 2015 11:42 AM
To: Dolbeck, Leeann; Chamberlain, Lori; Rogers, Carol; Dalcourt, Elena;
Sandulak, Michael; Alcantara, Denise

-------------------------------------------Incident Information
Have you reported this incident to other UCSD offices? Yes, I called the
OFHD.
Specific Location: Technically, on and off. It is a newspaper that is
online and on campus
Perceived Basis of Incident: Color, Disability, Gender Identity, Genetic
Information, National Origin, Race, Religion, Sex, Sexual Orientation
Description of Incident: It isn't really an "incident" as it is an ongoing
problem. I am reporting the Koala, because I was told the more voices you
hear from, the better. This newspaper has offended me, and all of my
teammates alike, and anyone else I have told. I read this "satirical"
newspaper and did not laugh once. Having UCSD fund a newspaper that tells
women to get fat if they don't want to get raped, or tells black people
that they could learn to swim by being "face down in a prison shower" is a
disgrace.
How would you like the University to respond: I have never been ashamed of
anything that university represents, except for this. Maybe you'd argue
that the university doesn't represent it or support it. But giving it
funds is doing just that, and us being public means the government
supports it too. Pull the funds, and make them turn to personal donations
40
UCSD 2010-22000042
From:
To:
Subject:
Date:
Gonzalez, Juan
Koala
Wednesday, November 18, 2015 6:47:31 PM
Good evening,
It has recently come to my attention that the
newspaper/magazine/publication (??) Koala is actually funded by Associated
Students. I first encountered this publication on library walk. This guy
was handing them out and I saw many people saying no to him. I didn't know
what it was but I felt bad everyone was rejecting him and I accepted one.
I flipped through it as I walked to class and I was disgusted. The images
were graphic and inappropriate. The writing was offensive. I immediately
threw it away. Knowing that my school is funding such a heinous magazine
is not okay and I stand by my fellow students to get it off this campus.
Please please cease funding for this awful publication.
41
UCSD 2010-22000043
November 18, 2015

We, the UC San Diego administration, strongly denounce the Koala publication and the offensive and
hurtful language it chooses to publish. The Koala is profoundly repugnant, repulsive, attacking and
cruel. The UC San Diego administration does not provide any financial support for the Koala, and we
call on all students, faculty, staff and community members to join us in condemning this publication and
other hurtful acts.
Pradeep K. Khosla
Chancellor
Suresh Subramani
Executive Vice Chancellor
David A. Brenner
Vice Chancellor Health Sciences
Dean, School of Medicine
Margaret Leinen
Vice Chancellor Marine Sciences
Director, Scripps Institution of Oceanography
Sandra Brown
Vice Chancellor Research
Becky Petitt
Vice Chancellor Equity, Diversity and Inclusion
Steve Gamer
Vice Chancellor Advancement
Juan C. Gonzalez
Vice Chancellor Student Affairs
Gary C. Matthews
Vice Chancellor Resource Management and Planning
Pierre Ouillet
Vice Chancellor and Chief Financial Officer
42
UCSD 2010-22000044
From:
To:
Subject:
Date:
Matthews, Gary
Re: The Koala
Hello,
No problem. And this is news to me, we will get on it asap. We will be
peaceful and productive, we don't want to give anyone any reasoning to
harm us, we just want our voices heard.
Have a safe flight and enjoy the Bay!
Best,
> Thanks for the concern and info

> Please note Koala get no University funding The Associated Students find
> them
> Pressure should brought to that organization to end the madness. About to
> board .
> Have peaceful productive March
> Gary
>
> Gary C Matthews
> Vice Chancellor
> Resource Management Planning
> University of California
> San Diego
> 858 534-6821
>
>> On Nov 18, 2015, at 9:29 AM,
wrote:
>>
>> Good Morning Gary,
>>
>> I hope you are having a safe and productive trip up there in San
>> Francisco. I am emailing you because I wanted to talk to you about my
>> concerns about the Koala newspaper. This is not the first time that it
>> has
>> offended me, or the black students in general really and we are having a
>> demonstration today at 12pm at the silent tree in lou of this and all of
>> the other anti-black events that's have been occurring all over the
>> united
>> states.
>>
>> It is very disturbing to know that our schools funds things like this
>> yet
>> I personally have over $10,000 in student loans. I am almost positive
>> that
>> one of the demands will be that the administrator that funds the paper
>> resigns because in all reality, I don't believe the paper is doing the
>> job
>> that it is "set out" to do. We believe that it is counter-productive and
>> reinforcing the stereotypes that society already have on black people
43
UCSD 2010-22000045
From:
To:
Cc:
Subject:
Date:
Subramani, Suresh (EVC)

Gonzalez, Juan; Khosla, Pradeep
Briggs Addo, Ann; Kristofco, Clare; Petitt, Becky
RE: AS votes to discontinue funding the publications of media student organizations
Thursday, November 19, 2015 3:43:45 PM
Juan,
Lets not ditch the good ones worthy of this funding and work actively on finding ways to encourage
and help them financially. I know you are working on this.
Best Regards,
Suresh
From: Gonzalez, Juan

To: Khosla, Pradeep; Subramani, Suresh (EVC)
Cc: Briggs Addo, Ann; Kristofco, Clare; Petitt, Becky
Subject: FW: AS votes to discontinue funding the publications of media student organizations
I wanted to be certain you were aware of this vote by AS last night. AS this continues to evolve, we
will keep you posted.
Juan
From: Gary Ratcliff

Sent: Thursday, November 19, 2015 10:45 AM
To: Gonzalez, Juan; Petitt, Becky; Kristofco, Clare; Park, Daniel; Briggs Addo, Ann; Davalos, Cynthia;
Emily Marx; Moore, John; Sawrey, Barbara; Wienhausen, Gabriele; Mahaffey, Patricia; Silva, Frank; Artis,
David
Subject: RE: AS votes to discontinue funding the publications of media student organizations
Colleagues:
Last night, the Associated Students (AS) voted to discontinue funding publications of media
student organizations. Students on campus have expressed their disapproval of the Koala
and Associated Students (AS) funding of student organization publications.
The Campus Counsel has made it clear the university must use viewpoint neutral criteria in
allocating resources to student organizations. AS cannot decline a request to fund an event or
publication of a particular student organization because of its viewpoint. AS did not do that last
night. AS adopted a blanket restriction on a type of student organization expenditure it will not
fund. For example, some student governments do not accept funding requests for equipment,
travel, and food. The student government at SDSU does not accept requests for publications. Last
night, AS voted to do the same.
44
UCSD 2010-22000046
Presently, thirteen student organizations are registered as media students organizations. The names
of these organizations are available on the student organization directory (see link below). One
organization, the Muir Quarterly, is linked to an undergraduate college, which has the option to
fund this publication. The Saltman Quarterly is linked to an academic department, and the Medical
Literature Society and Undergraduate Research Journal may be linked to departments as well. The
departments affiliated with these organizations may choose to fund these publications.
http://rangiroa.ucsd.edu/studentorgregistration/RdOnlyList.aspx?frmFocus=11
Contact me if you have any questions.

Regards,
Gary Ratcliff
45

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Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 1 of 46

EXHIBIT TO VERIFIED COMPLAINT FOR DECLARATORY AND

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 2 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 3 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 4 of 46

Penny Rue, Ph. D.

How will you invent the future?

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 5 of 46

Ratcliff, Gary [grratcliff@ucsd.edu]

From: Rue, Penny [mailto:prue@ucsd.edu]

From: Brink, David [mailto:dbrink@ucsd.edu]

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 6 of 46

Cc: Kristofco, Clare; Wahlig, Nancy; Davalos, Cynthia

From: Chamberlain, Lori

Bias Incident Report Form

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 7 of 46

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 8 of 46

From: Park, Daniel

From: Clare Kristofco <ckristofco@ucsd.edu>

From: Petitt, Becky

From: Gonzalez, Juan

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 9 of 46

Sent from my iPad

Bias Incident Report Form

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 10 of 46

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 11 of 46

Bias Incident Report Form

Alleged Offender Information

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Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 13 of 46

Bias Incident Report Form

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 14 of 46

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 15 of 46

Sent from my iPad

Bias Incident Report Form

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 16 of 46

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 17 of 46

Bias Incident Report Form

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 18 of 46

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 19 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 20 of 46

From: ophd-birf@ucsd.edu [mailto:ophd-birf@ucsd.edu]

Bias Incident Report Form

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 21 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 22 of 46

From: ophd-birf@ucsd.edu [mailto:ophd-birf@ucsd.edu]

Bias Incident Report Form

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 23 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 24 of 46

From: ophd-birf@ucsd.edu [mailto:ophd-birf@ucsd.edu]

Bias Incident Report Form

Alleged Offender Information

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 25 of 46

Case 3:16-cv-01296-JM-BLM Document 1-2 Filed 05/31/16 Page 26 of 46

Sent from my iPad

Bias Incident Report Form