Bose V Rhodes College: Bose' Final Title IX Investigation Report

Case 2:16-cv-02308-JTF-tmp Document 161-12 Filed 07/20/18 Page 1 of 16 PageID
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EXHIBIT L TO TRIAL MEMORANDUM –

FINAL REPORT FROM WHITNEY HARMON’S
INVESTIGATION
2223
BAICER..,DONELSON
BEARMAN, CALDWELL BERKOWITZ, PC
&,
2000 FIRST TENNESSEE BUllDING
165 MADISON AVENUE
MEMPHIS, TENNESSEE 38103
PHONE; 901.526.2000
FAX: 901.577.2303
WWW .bakerdonelson.com
MEMORANDUM
TO: Claire Shapiro, Title IX Coordinator
FROM: Whitney M. Harmon, Shareholder
DATE: March 27, 2016
RE: Confidential Investigation Report - Bose/Bea
The information contained in this Report is a compilation of information received from

parties and witnesses through interviews and their provision of evidence, and is solely for
consideration and potential use in connection with Rhodes College Title IX proceedings. The
Report includes any information received that might potentially be relevant to such proceedings,
with determinations of credibility and weight of the evidence reserved for a later part of the
proceedings.
The information contained in this Report should only be used in connection with Rhodes'
Title IX proceedings and should not be used in any manner inconsistent with Rhodes'
Sex/Gender Discrimination and Sexual Misconduct Policy. The Report potentially contains
FERPA-protected information of more than one student, and no one may re-disclose another
student's FERPA-protected information without consent, regulatory exemption, or for an
improper purpose. The Report, and the information in the Report, are not to be disseminated to
anyone other than the Claimant, Respondent, their advisors and supporters (who, in turn, must
not re-disclose the information), and Rhodes' agents and employees involved in these
proceedings. Any improper dissemination of other students' FERPA-protected information
without consent could lead to sanctions under the Policy.
RHODES02056
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Confidential Investigation Report

March 27, 2016
Page 2
I was asked to conduct an investigation into a complaint of sexual harassment by a

Rhodes faculty member. As part of the investigation I reviewed two Sexual Misconduct Report
Forms regarding the allegations by Claimant, Prianka Bose, against Respondent, Dr. Bea; one
report made by Claimant and one by a faculty member.
My investigation also included interviews of the Claimant, Respondent, the original

reporter, and other students identified as individuals with potentially relevant information. All
interviews began with an introduction, discussion of confidentiality, the application of the Honor
Code, and an explanation of the prohibition on retaliation.
Interview with Prianka Bose - Claimant
• February 26, 2016 -10:30- Office of Brice Timmons, Counsel for Claimant
• Individuals in attendance included attorneys Brice Timmons, Jana Lamanna, Sheerin

Mehdian; Dr. and Mrs. Bose; and a court reporter.
• Prior to beginning the interview we discussed confidentiality considerations in

accordance with Rhodes' policy and federal law. Claimant stated she was comfortable
with me sharing her identity and information about the allegations raised with others
involved in the process.
When asked how she knew the Respondent Claimant stated she had him as a professor for
Organic Chemistry I and II. Organic II was during the fall semester of2015.
In her Complaint, Claimant states she attended Respondent's office hours four times a week and
would often go to his office before class to ask questions before taking quizzes and exams.
Claimant also noted that she took two exams and three quizzes in Respondent's office.
When asked why she was taking quizzes in Respondent's office, Claimant responded as follows:
• In spring 2015 Claimant was under concussion protocol, so took quizzes in Respondent's
office
• She said Respondent told all students that they could take exams early or in his office if
they needed to.
• She said other students under disability services or for other reasons would take tests and
quizzes in professors' offices.
• Claimant stated she was also taking quizzes/tests in other professor's offices during that
semester.
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March 27, 2016
Page 3
When asked why else Claimant visited Respondent in his office during Spring Semester 2015,
Claimant responded as follows:
• Claimant stated she would attend Respondent's office hours before class - would discuss
practice problems from online fornm.
• Claimant stated all conversations were strictly about school, or the course material.
Claimant stated she did not have any problems with Respondent during spring term. When
asked about her encounter with Respondent in July of2015, Claimant stated as follows:
• One day in July Claimant ran into Respondent in the parking lot, sometime in the
afternoon. Claimant was alone.
• Claimant stated she heard her nan1e and she saw him waving and coming toward her.
Claimant stated that Respondent started talking about why she was there for the summer,
asked her if she was living on campus. Claimant stated she did not tell Respondent
where she was living that summer.
• Claimant stated she asked Respondent if he was doing work for the chemistry
department.
• Claimant stated that the conversation took a turn to topics like what she likes to do in
evenings and that Respondent asked her about her boyfriend. Claimant stated that at that
time she told him she needed to go.
• Claimant stated Respondent told her he was really excited to have her in Orgo, and asked
if she wanted to have dinner with him. Claimant stated that she said no. Claimant stated
that she did not ever have dinner with Respondent.
• Claimant stated she then got in her car and called her mother to tell her what had
happened. Claimant stated her mother told her to keep it professional and not to do
anything to lead Respondent on.
Claimant asked if she told anyone other than her mother about this encounter with Respondent.
Claimant stated as follows:
• Claimant said she went to her friend, Chelsea Dezfuli's house and told her about the
conversation she had just had with Respondent.
• Claimant stated that her friend said maybe Respondent did not mean it that way and she
(Claimant) should just keep their interactions professional.
When asked if Respondent ever asked her to dinner again, Claimant stated that he did not.
Claimant stated she did not know if Respondent had ever had dinner with other students.
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March 27, 2016
Page 4
Claimant stated that she and Respondent had not had conversations previously about boyfriends,
dating, etc. All conversations had been about school.
When discussing the subject of the type of conversations between Claimant and Respondent,
Claimant stated:
• Respondent "always tells me that I look nice." Claimant stated that was how Respondent
started his conversation with her on the afternoon in July - "You like nice, what are you
up to?"
• Claimant stated he would "sporadically" say things like this to her throughout the fall
semester.
When asked if she was still under concussion protocol in the fall of 2015, Claimant confirmed
that she was not. Claimant stated that during the fall of2015, she continued to visit Respondent's
office, but never by herself. Claimant stated she always was accompanied by other students
from class.
In her Complaint, Claimant alleged that from September to November 2015, Respondent would
come into her Chemistry Lab, and approach her to have a conversation. Respondent was not
Claimant's Chemistry Lab professor.
When asked about Respondent's presence in Claimant's Chemistry Lab, Claimant stated as
follows:
• Claimant stated Respondent was just always around, but he would not stay long.
• Claimant stated that most of the time she wouldn't realize that Respondent was there.
• Claimant stated Respondent would talk to Dr. Brien, and then come talk to her about the
project, comment on how she could do it faster or better, etc. Claimant stated she did not
notice Respondent doing this with any other student even though there were other
students from his Org. II class in that lab, and that he usually left the lab after talking to
her.
• Claimant stated her lab partner was also in Respondent's lecture with her. Claimant
stated her lab partner would comment on why Respondent would fix something for her,
because Claimant was doing fine. Claimant stated Respondent did not talk to her lab
partner during the lab.
• Claimant stated that if another student were to talk to Respondent during the lab, the
student would have to initiate the conversation but Respondent initiated contact with her.
• Claimant stated that sometimes Respondent would try to have personal conversations
with her during lab but Claimant would cut this off to focus on the experiment.
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March 27, 2016
Page 5
• Claimant stated that Respondent's reasoning for his visits to the lab was to see how the
first lab went. Claimant stated Respondent was the only professor who did this that she
remembers.
When asked if she complained to anyone abont her interactions with Respondent in the lab,
Claimant stated she only made complaints to her lab partner. Claimant stated the interactions
were irritating because Respondent was being distracting, so she sometimes vented to her lab
partner.
In her Complaint, Claimant alleged that in September of 2015, Respondent called her to his
office after class to take some extra study materials. Claimant alleges that when she got to his
office Respondent asked her about whether she had been published and started talking to her
about research opportunities. Claimant alleges Respondent asked her to be his research assistant.
Claimant also alleges Respondent started asking about her family and her social life.
When asked about her conversation with Respondent about being a research assistant, Claimant
responded as follows:
• Claimant stated that Respondent tried to pull her out of the lab to have a conversation
with her about being his research assistant. Claimant stated Respondent told her to come
to his office after class to discuss it, and she did.
• When Claimant went to Respondent's office, Respondent asked about what publications
she had. Claimant gave Respondent a summary of her experience and Respondent told
her that they needed to get her some research opportunities. Claimant stated that
Respondent told her "he would love for her to be his research assistant."
• Claimant stated in the interview that she did not want to be Respondent's research
assistant and she told Respondent that she wanted to discuss it with her father before
accepting.
• Claimant stated she then got up to leave the office and Respondent stopped her and
started asking questions about her family. Claimant stated Respondent asked if Claimant
was in any clubs at school, asked her about her sorority, and whether she went to parties.
Claimant stated she did not give specifics and then said she told Respondent that she
needed to leave. Claimant stated Respondent told her that he would walk her out.
• Claimant stated that she told Respondent it was not necessary for him to walk her out
but he stated he was walking out anyway. After they got outside, Claimant stated that she
went a different direction and called her father.
• Claimant stated Respondent walked with her from Kennedy to Palmer Hall, and then she
got on phone to divert him.
• Claimant stated there was no real follow-up on this conversation with Respondent.
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March 27, 2016
Page 6
Claimant stated that she stopped going to Respondent's office honrs after this conversation.
In her Complaint, Claimant alleges that on November 19, 2015, she was sitting in the Rat with a
friend. Claimant alleges Respondent came up behind her and asked if she was texting her
boyfriend.
When asked about her interaction with Respondent on November 19, 2015, in the Rat, Claimant
responded as follows:
• Claimant stated she was sitting facing the wall of the Rat, and Respondent walked all the
way around the room to go completely around her and lean over her shoulder. (Claimant
drew a map of the area, indicating the path she assumed Respondent took. That map is
attached.]
• Claimant stated that Respondent leaned into her personal space, and said in her ear - "are
you texting yonr boyfriend." Claimant stated that she did not say anything, but
Respondent smiled at her and just walked away.
• Claimant said her friend was encouraging her to talk to someone about the interaction,
but Claimant said she wanted to talk to Respondent herself.
• Claimant stated that she asked Respondent outside if she could talk to him and he said of
conrse. Claimant stated she told him she had been feeling uncomfortable and the
question about the boyfriend made her uncomfortable. Claimant stated Respondent did
not say anything to her and walked away. Claimant characterized Respondent's reaction
as angry. She stated you could tell this based on his body language .
.When asked about other discussions Claimant had with Respondent, Claimant stated as follows:
• Claimant stated Respondent was sometimes disruptive while she was taking exams in his
office. Claimant stated Respondent would be talking to her - venting, talking about his
mom, about his personal stuff to her.
• Claimant stated that when she was taking Quiz 3 (October 21, 2015)- Respondent got an
email from someone saying they could not take a test or quiz - Respondent slammed his
hand on the desk and got upset. Claimant stated that she asked if he was okay and he
said I can't believe that people are so irresponsible ... She kept taking the test and tried to
block him out.
• When asked what other personal details Respondent shared with Claimant during their
conversations, she listed the following - Respondent's father died, mother lives alone, he
is afraid of planes, he lives in small village near Barcelona - spends Christmas with his
mom, was in military, worked at University of Missouri/Minnesota, worked with a lot of
Indians, he would ask her what Indian words meant, he was the first person in his family
to go to college, Claimant thinks he is an only child, Respondent always wanted to be in
Chemistry, Respondent's first Chem set was the best day ever, really likes bikes.
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March 27, 2016
Page 7
• Claimant stated that all of this information from Respondent started to come out in the
fall of 2015 while she was in the office to take tests/quizzes, and these details were not
shared while other students were in the office.
When asked what other experiences Claimant had with Respondent relevant to her allegations,
she stated as follow:
• Claimant stated that she and her lab partner were working on a practice problem and
asked Respondent about the problems on November 23, 2015. Claimant stated
Respondent would not answer her questions, and just shrugged his shoulders.
• Claimant stated that this was when she realized that Respondent did not want to help her
anymore. Claimant stated that after that if her hand was raised in class Respondent
would not call on her.
• Claimant stated that she tried to discuss this with Respondent after class on November
23, 2015, in his office, but Respondent turned around to his computer and busied himself.
Claimant stated that she told Respondent that things had gotten uncomfortable between
them but that she was not going to report him; she just wanted to get through the
semester. Claimant stated Respondent did not say anything. Claimant stated this
conversation took place right before Thanksgiving break.
Claimant stated she never communicated with Respondent by email or text, only in person.
Claimant stated that she learned Respondent had accused her of cheating after Thanksgiving
Break. Claimant stated that she feels like this was retaliation from Respondent.
Claimant stated that up until the last few weeks of fall semester Respondent was very nice to her
and tried to talk to her a lot, and was helpful. Claimant stated that the minute she told
Respondent she was uncomfortable he changed.
I asked Claimant if she had other names of witnesses. She identified no additional witnesses.
Claimant read through my interview notes and signed off on their accuracy. The interview
ended.
Interview with Dr. Roberto de la Salud Bea - Respondent
• February 18, 2016- Rhodes HR Conference Room
• We discussed confidentiality considerations in accordance with Rhodes' policy and

federal law.
When asked to discuss his relationship with Claimant, Respondent stated as follows:
• Claimant was a student in Respondent's in Organic Chem 1 class in the spring of2015
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March 27, 2016
Page 8
• Respondent stated that sometimes Claimant came to his office hours to speak with him
and if they saw each other outside of class they would say hello.
• Claimant was also a student in Respondent's Organic Chem 2 class in the fall of 2015.
Respondent stated that at that time Claimant was no longer on concussion protocol but
still asked to come by early and take tests/quiz in his office. Respondent stated that he
allowed that and that other students do the same thing.
• Respondent stated he reported Claimant to the Honor Council for issues related to her
answers to quizzes in his class.
• Respondent stated that it was during the Honor Council hearing that Claimant asked him
ifhe remembered the things in her Title IX allegations. Respondent stated that he did not
remember the things that she brought up at that time.
When asked what specifically he knew about the allegations made by Claimant, Respondent
stated as follows:
• Respondent stated that he does remember seeing Claimant in the Rat texting on her
phone, and he remembers asking "oh is this your boyfriend?" Respondent stated
Claimant did not say anything in response, but may have smiled. Respondent stated there
were lots of people around at the time. Respondent stated that he does not remember
Claimant following him out of the Rat in November to discuss the comment he made
about the phone.
• Respondent also admits talking to Claimant during her lab. Respondent stated that
Claimant was one of his best students, and that he also talked to other students in that
setting.
• Respondent stated that he does not remember Claimant ever saying don't do these things
(like asking about her boyfriend) or anything about it making her uncomfortable.
• Respondent stated that Claimant thinks he is getting revenge on her, which is not true.
When asked specifically about any conversations with Claimant during the summer of 2015,
Respondent stated as follows:
• Respondent stated he does not remember any interactions with her during that period.
Respondent stated it is possible that they had casual interactions in passing - like saying
hello, how are you.
• Respondent stated he does not remember any conversations about where Claimant lived,
whether she attended parties on campus, or about her boyfriend.
• Respondent stated that he never asked Claimant to dinner, and that they have not ever had
dinner together.
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March 27, 2016
Page 9
When asked if he ever had personal conversations with Claimant, Respondent stated as follows:
• Respondent stated Claimant asked Respondent for a recommendation letter. In order to

write the recommendation, Respondent asked for Claimant's CV but nothing personal.
Respondent stated that he does the same thing for anyone who asks for a
recommendation.
When asked if Respondent visited Claimant's Chemistry Lab, Respondent stated as follows:
• Respondent stated that on a regular basis the chemistry professors visit other labs to see
what is going on. Professors will talk to students, and Respondent stated that he usually
goes to every lab when he can.
• Respondent stated that other professors come to his lab as well and interact with students.
When asked if Respondent asked Claimant to be his research assistant, he stated as follows:
• Respondent stated that he did not have any discussions with Claimant about being a
research assistant. Respondent stated that he already had two research assistants during
that period, and he usually just keeps two. Respondent stated that at the time of the
interview he has 4 research assistants.
When asked when Respondent's relationship with Claimant changed or became tense,
Respondent stated as follows:
• Respondent stated the relationship never really got tense until Claimant received notice
from the Honor Council, but not before.
• Respondent stated that even as late as the last quiz (Quiz #5 - December 2), Claimant
came to his office hours and their interactions were the same. As evidence of this,
Respondent stated that on the final quiz Claimant wrote "Thank You" on the back of the
last page. [A copy of that Quiz is attached.]
• Respondent stated Claimant was still initiating meetings in his office with him at that
point, and would come to the office alone.
• Respondent described his relationship with Claimant to be the same as any other student.
I asked Respondent if he had relevant documents or names of witnesses. Respondent identified

Dr. Kim Brien and stated he would make any documents available.
Respondent read through my interview notes and signed off on their accuracy. Respondent was
reminded about the school's prohibition against retaliation and the interview ended.
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March 27, 2016
Page 10
Interview with Dr. Kimberly Brien - Witness - Chemistry Professor - Claimant's Lab
Professor
• February 18, 2016 - HR Conference Room

federal law.
When asked what she knew about the allegations made by Claimant, Witness responded as
follows:
• Claimant was in her Organic Lab last semester. Toward the end of the semester Witness
stated Claimant approached her and said I need to talk to you. Witness stated that
Claimant said Respondent said some really inappropriate things to her. Claimant did not
share what the alleged comments from Respondent were.
• Witness asked Claimant when this alleged conversation occurred and Claimant said it
was after Thanksgiving. Witness stated that Claimant said Claimant told Respondent that
she [Claimant] thought the conversation was inappropriate and the next week he accused
her of cheating.
• Witness stated that Claimant did not volunteer any specific information about her claim.
• Witness directed Claimant to AnneMarie Reed or Claire Shapiro and offered to help her
fill out a complaint form. Claimant told Witness that she and her parents have already
talked to Ms. Reed and Ms. Shapiro.
• Witness stated that the sexual misconduct discussion was then dropped and the discussion
focused on the Honor Council issue.
• Witness called AnneMarie Reed and Ms. Reed stated she did not know anything about
the complaint and asked Witness to submit a report.
• Witness stated that she never observed Respondent acting inappropriately with Claimant
or any student.
When asked if the chemistry professors visit other labs, Witness stated as follows:
• Professors do visit other professor's labs to check on reagents, and see how things are
going with the lab for the week. Witness stated that Respondent likes to see how the lab
is performed before his lab, and would usually only stay for a few minutes. Witness
stated that, when professors visit the lab, students from their lecture section will talk to
them to show them what they are doing.
• Witness stated she does not find it disruptive to have Respondent visit her lab, and did
not find it odd for Respondent to stop in or to talk to Claimant.
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March 27, 2016
Page 11
• Witness stated that there are only 24 people in the room, and she would have noticed any
lingering by Respondent with Claimant. Witness did not notice such lingering. Witness
stated that she never noticed Claimant being uncomfortable when Respondent was
around.
When asked what other information she had related to the Title IX complaint, Witness stated as
follows: ·
• Witness does not remember any additional conversations with Claimant related to the
Complaint. Witness stated she did meet with the Chemistry Department Chair and
Respondent to inform them of the concerns raised. Witness stated that Respondent said
there was one encounter in the Rat where he remembers seeing Claimant's phone and
asking if she was texting her boyfriend, and Claimant said she did not appreciate that.
But that was the only incident Respondent could recall.
The witness read through my interview notes and signed off on their accuracy. The witness was
reminded about the school's prohibition against retaliation and the interview ended.
Interview with Chelsea Dezfuli - Witness
• March 16, 2016 - Rhodes Campus
• In attendance were Coble Caperton, Esq., counsel for witness, and a court reporter.

federal law. Witness stated that she was comfortable that her name be used as part of
this investigation report.
When asked how she knows Claimant, Witness stated they are friends and sorority sisters.
When asked what she knew about Claimant's allegation related to her interaction with
Respondent in July of2015, Witness stated as follows:
• Witness stated that in July of 2015, Claimant told Witness she had a weird interaction
with Respondent. Witness stated that Claimant told her she had talked to her mom about
it but wanted to. get a student's impression.
• Witness stated that Claimant told her that she and Respondent were in a parking lot,
walking together, and Respondent asked her to go out to eat and so they could get to
know each other. Witness stated she does not remember what Claimant's response was.
• Witness stated that she knew Claimant had talked about working with Respondent as a
research assistant and so Witness thought Respondent might just want to get to know her
better.
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March 27, 2016
Page 12
Witness stated she was in Respondent's Organic II class with Claimant.
• Witness stated she never observed any uncomfortable or unusual interaction between
Claimant and Respondent in class.
• Witness stated that she thought Respondent was a "super nice person."
• Witness stated that Claimant took Respondent for Organic I, and Claimant encouraged
Witness to take his Org. II class.
When asked about the alleged incident in the Rat, Witness stated as follows:
• Witness stated that she and Claimant were sitting in the Rat and Respondent came up
behind them and peered over Claimant's shoulders, looking at her phone and asked if that
was Claimant's boyfriend, smiled, then walked off. Witness stated that Claimant had to
move back because Respondent was in her personal space. Witness stated Respondent
did not say anything to Witness.
• Witness stated that Claimant commented on how weird the interaction was and asked
Witness if she should do anything. Witness stated she told Claimant she should talk to
Respondent because he shouldn't be bringing up her boyfriend.
• After lunch Witness stated she and Claimant caught up with Respondent outside the Rat
and Claimant went up to him. Witness stated Claimant told Respondent she was
uncomfortable with his comment [Witness did not actually hear this conversation.]
• Witness stated she observed his reaction as looking at the ground and walking away.
Witness stated that Respondent's body language tensed up.
• Witness stated she did not see Claimant and Respondent together after this incident.
Witness stated that Claimant told her Respondent came in to the lab often and would pester
around her lab station and help Claimant and her lab partner with the experiment. Witness stated
Claimant said in a joking way it was peculiar that Respondent was always coming up to her.
Witness stated she does not know if this was serious.
reminded about the school's prohibition against retaliation and asked to contact Anne Marie Reed
if she had any additional information. The interview ended.
Interview with Lauren Sylwestcr - Witness
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March 27, 2016
Page 13

When asked how she knows Claimant, Witness stated Claimant is one of her best friends.
When asked what she knew about Claimant's allegations related to Respondent's interaction with
Claimant, Witness stated as follows:
• Witness was Claimant's lab partner in Professor Brien's lab.
• Witness was also in the same section of Respondent's Organic II lecture session.
• Witness stated she observed Respondent coming into the lab every week. Witness stated
she did not observe any other professors coming into the lab.
• Witness stated Respondent would come up to Claimant and talk to her, would fiddle with
whatever instrument they were using, and he might walk around the room once.
• Witness stated Respondent did not talk to any other students that she saw, and he might
have talked to her once or twice.
• Witness stated that she could not always hear what Claimant and Respondent were
talking about, but it was usually about the lab. Witness stated she does not remember
them talking about anything personal.
• Witness stated that Claimant did not complain to her or say this made her feel
uncomfortable.
• Witness stated she commented to Claimant about Respondent coming in and said "you
must be his favorite student." Witness stated Claimant just laughed it off and did not say
much.
• Witness stated Claimant never told her she was uncomfortable with the attention or
conversations with Respondent.
When asked what other interactions between Claimant and Respondent she was aware of,
Witness stated as follows:
• Witness stated that she only saw Claimant and Respondent interact in lecture, and she did
not observe anything strange about their interactions in lecture.
• Witness stated that she knows Respondent asked Claimant to do research with him at one
point, maybe spring semester of last year. Witness stated Claimant did not do it and
Witness thought this was strange because it was a research option. Witness does not
know why Claimant did not do the research. Witness did not state how she knew this.
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March 27, 2016
Page 14
When asked when she first learned about Claimant's claims against Respondent, Witness stated
as follows:
• In early January Witness learned Claimant had made a claim against Respondent during
lunch with Claimant, her father, and another friend.
• Witness stated that she [Witness] brought up the fact that Respondent came into lab and
said she [Witness] was shy about going in to office hours, but Claimant did not have a
problem because Respondent liked Claimant [this was Witness's personal opinion].
• Dr. Bose asked Claimant and the other friend to go to the side and talked to Witness in
private. He explained the situation and said that they were pulling Claimant out of
school, making a claim against Respondent because he had been harassing Claimant and
accused her of cheating. Witness stated this was the first time she had heard about this
behavior.
if she had any questions or additional information. The interview ended.
Interview with Emma Barr - Witness

When asked how she knows Claimant, Witness stated Claimant was her roommate sophomore
and junior year (first semester).
When asked what she knew about Claimant's allegations against Respondent, Witness stated as
follows:
• Witness stated she never talked with Claimant about Respondent until around late
November, when Claimant was telling Witness about Respondent and about the incident
in the Rat when Respondent approached Claimant and asked about her boyfriend.
• Witness stated that, based on her conversation with Claimant, she believes Claimant did
tell Respondent she was uncomfortable with the conversation in the Rat.
• Witness stated that Claimant told her that Respondent was "pretty angry" when she told
him she was uncomfortable because Claimant said Respondent stormed off, or walked
away very angrily.
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March 27, 2016
Page 15
• Witness stated that she encouraged Claimant to talk to someone in authority about it.
This conversation between Witness and Claimant would have happened in November or
December.
• Witness stated that she discussed Respondent with Claimant and two other friends around
November through the end of the semester. Witness did not remember any specific
details about those conversations.
• Witness stated she remembers Claimant telling her that on multiple occasions
Respondent made her feel uncomfortable. Claimant did not really share anything specific
(only remembers Rat event) but would say that it was weird. [These conversations
between Witness and Claimant occurred in the November - December time frame.]
• Witness stated she never saw Claimant and Respondent interact personally.
if she had any questions or additional information. The interview ended.
RHODES02070

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Bose V Rhodes College: Bose' Final Title IX Investigation Report

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Case 2:16-cv-02308-JTF-tmp Document 161-12 Filed 07/20/18 Page 1 of 16 PageID

EXHIBIT L TO TRIAL MEMORANDUM –

TO: Claire Shapiro, Title IX Coordinator

FROM: Whitney M. Harmon, Shareholder

DATE: March 27, 2016

RE: Confidential Investigation Report - Bose/Bea

The information contained in this Report is a compilation of information received from

Confidential Investigation Report

I was asked to conduct an investigation into a complaint of sexual harassment by a

My investigation also included interviews of the Claimant, Respondent, the original

Interview with Prianka Bose - Claimant

• Individuals in attendance included attorneys Brice Timmons, Jana Lamanna, Sheerin

• Prior to beginning the interview we discussed confidentiality considerations in

Confidential Investigation Report

Confidential Investigation Report

Confidential Investigation Report

Confidential Investigation Report

Confidential Investigation Report

Interview with Dr. Roberto de la Salud Bea - Respondent

• February 18, 2016- Rhodes HR Conference Room

• We discussed confidentiality considerations in accordance with Rhodes' policy and

Confidential Investigation Report

Confidential Investigation Report

• Respondent stated Claimant asked Respondent for a recommendation letter. In order to

I asked Respondent if he had relevant documents or names of witnesses. Respondent identified

Confidential Investigation Report

• February 18, 2016 - HR Conference Room

• We discussed confidentiality considerations in accordance with Rhodes' policy and

Confidential Investigation Report

Interview with Chelsea Dezfuli - Witness

• March 16, 2016 - Rhodes Campus

• We discussed confidentiality considerations in accordance with Rhodes' policy and

Confidential Investigation Report

Witness stated she was in Respondent's Organic II class with Claimant.

Interview with Lauren Sylwestcr - Witness

• March 16, 2016 - Rhodes Campus

Confidential Investigation Report

• We discussed confidentiality considerations in accordance with Rhodes' policy and

• Witness was Claimant's lab partner in Professor Brien's lab.

Confidential Investigation Report

Interview with Emma Barr - Witness

• March 16, 2016 - Rhodes Campus

• We discussed confidentiality considerations in accordance with Rhodes' policy and

Confidential Investigation Report

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