My response to Interim Dean Lopes affidavit in support of opposition to motion for preliminary injunction for the Student Trustee (“Ms. Heather Dawood”).

Interim Dean Lopes (“Ms. Lopes”) states that she has been working with me (“Mr. Laraway”) to resolve conflicts with other students. What is she referring to? What is the scope of this remark?Lopes Aff. 2.

Ms. Lopes states that she believes the stem of the conflict originated about a view of differences about an ombudsman position initiative. She believes that Ms. Dawood supported one viewpoint and Mr. Laraway another. She believes “from that point, the dispute evolved from political differences to individual attacks.” Lopes Aff. 3. Where is she getting this information? Her beliefs are not germane to this issue.

Ms. Lopes states that Ms. Dawood and I had an individual meeting prior to the conflict resolution with all parties. Lopes Aff. 4. I never met with Ms. Lopes for conflict management mediation prior to the conflict resolution on October 30, 2002.

Ms. Lopes states, “Despite [her] own best efforts, and the efforts of others, problems persisted. Finally, mediation was required for all parties involved. At a mediation session on October 30, 2002, we attempted to help them develop a resolution to the conflicts.” Lopes Aff. 4. Could Ms. Lopes define “them”? What is the real issue here?At the end of Mr. Laraway’s session on November 15, 2002, Ms. Lopes gave Mr. Laraway a hug. Is this acceptable behavior for an Interim Dean? This is unacceptable and unwarranted behavior from Ms. Lopes. Did Ms. Lopes give Mr. Garner or Ms. Dawood a hug after their sessions? If Ms. Lopes had been a man and Mr. Laraway had been a women (a) it never would have happened or (b) [the University], [Dean Janey], and Interim Dean Lopes [“Ms. Lopes”] would have a major sexual harassment lawsuit to deal with.

Dean Stephanie Janey [“Ms. Janey”] replied on October 19, 2002, stating “It is unfortunate that you felt uncomfortable by assistant dean [Interim] dean Lopes’ gesture. I have discussed this incident with her, and I am confident that her intention was not to offend or cause any undo distress. Dean Lopes is a very caring individual and a highly competent student advocate. Her hug was simply a gesture of goodwill and closure to your session. Please feel free to discuss this matter further with her. She is receptive to feedback.” Apparently, sexual harassment does not apply to this University.

Ms. Lopes states that Mr. Laraway has asked, repetitively, for only one solution to the conflict between Ms. Dawood and himself. Aff. 5. Ms. Lopes is deceitful. Mr. Laraway not only asked for Ms. Dawood’s removal as student trustee and from the student senate but also asked Ms. Lopes for other solutions; such as, to tell Ms. Dawood to stop harassing [intimidating] Mr. Laraway, to let Ms. Dawood know that this is serious, and to leave Mr. Laraway alone. Mr. Laraway asked Ms. Lopes, “How many times do I have to come into your office before this is taken seriously?” Ms. Lopes replied, “How many times do you want to come into the office?”

Ms. Lopes and the University state they “know of no fact or evidence which warrant Ms. Dawood’s removal. Aff. 6. Ms. Lopes is being mendacious. During the October 30, 2002 conflict resolution, Mr. Laraway acquired information about Ms. Dawoods’ behavior towards Mr. Garner. Mr. Laraway and other administration personnel who were present; namely, Ms. Lopes, were told that Ms. Dawood had sexually harassed and sexually assaulted Mr. Garner. Did Ms. Lopes know about this information prior to this conflict resolution? Does this not provide facts and/or evidence which warrant Ms. Dawood’s removal? Mr. Laraway points out that the student handbook clearly states sexual harassment is unacceptable behavior and a violation of federal and state law (Student Handbook, “Sexual Harassment”, June 2002 – August 2003, pg. 169). Mr. Laraway also points out that there is currently nothing in the student handbook defining the recourse for sexual assault.

CONCLUSION

Clearly Interim Dean Lopes [“Ms. Lopes”] and the University are and were aware of Ms. Dawoods’ inappropriate behavior and Ms. Dawoods’ pattern of behavior before the October 30, 2002 conflict resolution session.

Mr. Laraway submitted a letter on October 24, 2002, addressed to Ms. Lopes stating, “[Mr. Laraway] feel[s] that this has been a pattern of behavior for Trustee Dawood. When speaking with her, she often seems to be out of control, threatening, and detached from reality. For instance, in the situation yesterday [October 23, 2002], Trustee Dawood came to me in a hallway, made accusations that were unfounded, openly insulted my integrity, and then threatened to use these unfounded allegations as a means of undermining my position within the SGA. When [Mr. Laraway] declined to speak with her any further [Ms. Dawood] replied, ‘Now you are threatening me?’.” Who’s threatening who? Is this what the University wants in a student leader? Is this what the University wants to protect and make an example to the university students?

I am a recipient of [the] Richard L. Storinger Award–honoring a student for courageously upholding academic integrity in the face of adversity. May it be highly regarded that I am also trying to upholded the University’s integrity in the face of adversity. I am an integritous, incorruptible, moral and abiding student at the University of Massachusetts Boston.

It is perceptible that the University and Ms. Lopes must protect their best interests at all costs no matter what the consequences are to the other parties involved.

Where is the justice? The integrity? The utilitarianism?

The next time you have an appointment with Interim Dean Lopes make sure you know that what ever you say to her can and will be used against you for the protection of UMass Boston.

“A single lie destroys a whole reputation of integrity.” By Baltasar Gracian