NEWARK, N.J. (CN) — After suffering a brutal on-campus rape, a female victim took Ramapo College of New Jersey and its Pi Kappa Alpha International Fraternity chapter to task for not protecting her from her attackers.
Jane Jones, a pseudonym, says she was repeatedly raped at 19 by several perpetrators who were also students on the night of Nov. 14, 2014.
In her federal lawsuit filed Oct. 21 in New Jersey, Jane says the college's conduct and policies created a hostile educational environment for female students before her rape occurred.
"Ramapo College had actual notice of (and itself created) a longstanding severely hostile educational environment for female students that was condoned and completely unaddressed by the college," Jane says in her 61-page complaint.
Jane also blames the college for deliberate indifference before the sexual assaults occurred since it did not enforce its sexual harassment policies even though multiple incidents had occurred on campus, the complaint continues.
"An official policy of deliberate indifference to sexual assaults and sexually hostile behavior, directly supporting, acquiescing in, maintaining and controlling environments for students that encouraged underage drinking and fostering this hostile sexual environment," Jane says in the complaint.
In addition to suing the college, several officials and the Pi Kappa Alpha International Fraternity, Jane is suing numerous other defendants, including the students who either raped her or stood by and watched the violence.
According to Jane, the Pi Kappa Alpha Fraternity held a Date Night theme party in a student's apartment with the fraternity's knowledge of underage drinking.
Jane says she was not originally invited to the party, but members of a PIKE fraternity chapter began to openly recruit students to come to their party at the insistence of a 24-year-old Mu Zeta chapter pledge of Pi Kappa Alpha since the party was turning out to be a dud. (L12)
At the party, Jane says she noticed several PIKE fraternity members were tasked with pushing alcoholic drinks on women - including Jane - to get them drunk.
Jane says she was then lured into Pi Kappa Alpha sergeant at arms John Hogan's bedroom once she was completely drunk. Hogan is a defendant in the complaint.
While she lay on a bed completely intoxicated and passed out, a male student identified in the complaint as "CL" and fraternity member defendant Joshua Newman played the juvenile game of "rock, paper, scissors" outside the door to see who got to rape her first, Jane claims.
After becoming aware of the ongoing sexual assault, Hogan kicked CL and Jane out of the party rather than taking in steps to protect her. CL then took Jane without her jacket, shoes or underwear to the freshman dormitory across campus, according to the complaint.
Jane says she should not have been permitted to enter another hall on campus since she did not have ID to show at campus security checkpoints.
Arriving at the freshman dorm, student defendants Christopher Rainone and Justin Sommers agreed to give CL and another perpetrator, identified in the complaint as "NG," their dorm room knowing she was going to be raped, Jane claims.
In fact, not only did they know she was going to be raped, the two students along with student defendant Jordyn Massood took turns watching by the door and cheering while she was being raped, Jane says in her complaint.
The students "found the entire incident extremely humorous and entertaining as it has been reported that they were falling down laughing, hysterically, while also videotaping the sexual assault upon [Jane] with one of their cellphones," the complaint continues.
Jane says that from the point when she was enticed to attend the party to the final result of her being repeatedly raped and sexually assaulted, no one intervened on her behalf - including campus representatives, security officers or pledged fraternity members.
Alleging negligence and violations of Title IX, the federal law prohibiting sex discrimination in education, Jane seeks reimbursement for numerous expenses and both compensatory and punitive damages.
Jane is represented by Patrick J. Whalen of Trenton, New Jersey. In an emailed comment, Whalen said, "I would just emphasize to you that an untold number of victims never report these incidents, and universities and colleges have been slow in complying with the federal laws designed to protect victims and to shine the light on this epidemic. We believe this is an important case, one which will hopefully expose the intertwined problems of underage drinking, fraternities and sexual assault."
The university's vice president of institutional advancement Cathy Davey did not reply to a request for comment.
Jane says in her complaint that though she and her mother visited several other colleges, they selected Ramapo College after being told the campus was safe and that it had top-notch security.
She says she was told "there was no need to worry about safety while on campus."
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