Monday August 25th 2014 

State here as briefly as possible the facts of your case. Describe how each defendant was 

involved, when the conduct occurred, and any injuries you have suffered as a result. It is not 

necessary to give any legal arguments or cite any cases or statutes. 

Joseph Waite has been the victim of a Title IX violation perpetrated by University of Oregon 

employees. He has been banned from registering for further classes at the UO, effectively 

excluding him from educational programs funded by the federal government for the reason that 

he is being discriminated against based on sex, his gender, which is male, his sexual orientation; 

which his hetero-normal sexuality, & his ethnicity or race; which is white caucasian. 

Joseph Waite is in possession of documentation given to him by UO employees that can prove 

these statements in a court of law. 

The involved parties who perpetrated crimes against Joseph Waite include employees of UO's 

American English Institute (AEI), individuals at the UO's office of Equal Opportunity & Affirmative 

Action, as well as employees of the UO's Office of the Dean of Student Conduct including Paul 

Shang, Carl Yeh, and Chicora Martin. 

These crimes were perpetrated against Joseph Waite over a sustained period of time from an 

unspecified date starting as early as 2006 until as recently as March 2014 and continuing to 

affect his life today as he is currently being exclude him from participating in an educational 

program funded by the federal government; which constitutes a clear title IX violation. 

The Title IX violation has resulted in defamation of his character, subsequent loss of future job 

opportunities & income, and are a direct result of the slanderous & libelous allegations fabricated 

by University of Oregon employees. 

The University of Oregon is to release the registration hold on Joseph Waite's student account 

allowing him to register for post bachelor classes to continue his education and personal 

development unhindered. 

Joseph Waite is seeking restitution from the University of Oregon in the amount of one million 

dollars for the title IX violation, which has resulted in defamation of his character, subsequent 

loss of future job opportunities & income, resulting from the slanderous & libelous allegations 

fabricated by University of Oregon employees. 

Furthermore any Eugene Police Records of Joseph Waite's personal records that have been 

affected by this case such as 'public indecency' or 'public threat' are to be expunged. 

Describe how each defendant was involved. 

As documentation proves: 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 1 of 11
At an undetermined point in time Joseph Waite was the victim of slander & libel perpetrated by 

employees of the UO's American English Institute. Specifically stated in the documented 

investigation of circumstances involving Joseph Waite's case made by UODPS; an AEI English 

tutor made a statement claiming that a few years ago, a group of English tutors in the employ of 

UO's AEI gathered together, composed, and using an official University of Oregon delivery 

system; sent an e-mail to all female asian students associated with the UO "warning them of 

Joseph Waite," that he is a potential threat. 

Later, when Joseph Waite was attempting to practice his major, which is Chinese language, 

he approached a female asian student on campus and greeted her with the word "nihao" which 

means "hello" in Chinese language. It is important to note that Joseph Waite had just exited an 

upper level chinese language immersion class at UO and was on campus as a student 

attending chinese language immersion classes. His greeting which he intended as a gesture of 

friendship was subsequently misinterpreted as a racial slur and Joseph Waite was cursed at by 

the student who made statements such as: : "You are a racist nazi," and "I'm a fucking 

American, I don't speak Chinese." Although Joseph Waite had not intended to upset or offend 

anyone, nor had he intended to approach or contact an individual who wished to be left alone, the 

student later identified as Ms. Wong; made a complaint to the Office of the Dean of Student 

Conduct stating that Joseph Waite had approached her in such a manner at least two or three 

times around campus on separate occasions. Joseph Waite was subsequently charged with 

violating the student conduct code's "unwanted contact" provision. Joseph Waite however was 

not immediately or directly informed of this charge though, rather a registration hold was placed 

on his student account by the Office of the Dean of student conduct. 

Joseph Waite then made an appointment with Carl Yeh to investigate why a registration hold had 

been placed on his account. During their meeting Joseph Waite claims that Carl Yeh made 

statements such as: "Don't you think it is a little creepy for a white male to approach female 

asian students and greet them in Chinese language?" also, "Don't you think it is creepy if a white 

male has a sexual preference or fetish for asian females?" Joseph responded by saying that he 

did not think it is strange for him to be interested in speaking with people from the cultures he 

studies, nor to attempt to practice his language skills in public on UO campus, as his right to do 

so is protected by Freedom of Speech, the First Amendment of the US Constitution. Also 

reaffirmed by other factors such as a plaque fixed to the wall of the University of Oregon's Erb 

Memorial Union (EMU) which states: "Affirmation of Community standards, this is a freedom of 

speech plaza." Joseph Waite would also like to note that such a plaque is really unnecessary 

because the right to freedom of speech is protected by law everywhere in the United States, not 

just in the 'UO's EMU Freedom of Speech Plaza.' 

After his initial meeting with Carl Yeh, in an attempt to defend himself, Joseph Waite at that time 

composed two letters 'To whom it may concern," in the first letter, which was three pages long, 

Joseph attempted to defend his right to freedom of speech. After meeting with the head of his 

department, the Chinese language department's Professor Wu, Joseph composed the second 

letter "To whom it may concern" in which he conceded that his freedom of speech was only valid 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 2 of 11
within the limitation that he not use it to intentionally offend anyone, that to offend anyone was not 

his intention, and included an apology to anyone whom he may have offended by attempting to 

practice the language of his major on UO campus. 

After submitting the two letters, Carl Yeh subsequently made a decision to find Joseph Waite 

"guilty" of violating the "unwanted contact" provision of the UO's student conduct code. Carl Yeh 

told Joseph Waite that a "reasonable person" would have known that female asian students on 

UO campus would not be comfortable with Joseph approaching them and greeting them with an 

Asian language. However, Carl Yeh did lift the registration hold on Joseph's account at this time 

stating something to the effect that the disciplinary action had been resolved with a "guilty" 

verdict, and that Joseph's meetings with Carl Yeh, and subsequent composition of the two 

letters had fulfilled the requirements for Joseph's disciplinary measures. 

It is important to note here that Carl Yeh was the sole individual responsible for making the 

decision to find Joseph "guilty" of violating the "unwanted contact" provision of the UO's student 

conduct code. In other words, there was no oversight; there was no jury, no judge, and no panel 

of individuals made up of community members that determined the "guilty" verdict which would 

later affect Joseph Waite's fate. Furthermore, it is also important to note that Carl Yeh is himself 

a Chinese-American who told Joseph that he (Carl Yeh) cannot speak the Chinese language, 

and it is speculated by Joseph that he (Carl Yeh) shares the same bias as Ms.Wong, a bias 

against a white male who attempts to speak Chinese language to a female asian student in 

public on UO campus. According to Joseph, Carl Yeh told Joseph during their first meeting that 

"Nihao," which means "Hello" in Chinese, is "a racial slur" when said by a white male. 

Carl Yeh ignored the fact that Joseph Waite's major field of study is Chinese language, and also 

speculated that Joseph Waite's intentions were sexual in nature; Carl Yeh made comments to 

that effect such as Carl Yeh telling Joseph in their initial meeting: "Don't you think it is a bit creepy 

for a white male to have a sexual preference for asian women." Joseph would also like to point 

out that during their meeting, Carl Yeh informed Joseph in an attempt to find common ground, 

that Carl is a Chinese-American who is married to a white caucasian American woman. Joseph 

would also like to state here that during their meeting, Joseph told Carl Yeh that he (Joseph) 

enjoys the game "Wei-Qi," which is a board game similar to chess, that involves two players, 

each with either black or white pieces that are placed on the board in an attempt to surround 

each other and control greater and greater amounts of territory. To which Carl Yeh replied that 

China has it's citizens installed in every country in the world. 

As the hold on Joseph Waite's registration had been lifted, Joseph thought that this was the end 

of the incident, but it was not the end. Joseph returned to classes and was able to complete the 

final credit requirements for his graduation during this time. However, Joseph's intentions were 

at this point to start taking computer science classes at UO as he had finished the requirements 

for his Chinese language degree, which is a Bachelor of Arts. Joseph intended either to take 

some computer science classes prior to graduation, or to take the computer science classes as 

a post bachelor, after graduation. However, it was about a year after the first incident when a 

registration hold was once again placed on Joseph Waite's account on 14th May 2013. 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 3 of 11
Joseph made another appointment with Carl Yeh to investigate the reason for the most recent 

hold placed on his registration through his Duckweb account. During the subsequent meeting 

with Carl Yeh Joseph was told that he (Joseph) was in trouble for hitting on two sensitive issues: 

for being suspected of "targeting asians" and for "targeting women," implying that the so called 

"targeting" of female asian students was for dubious sexual reasons, and that this behavior 

constituted a demonstration that Joseph had not learned from the previous disciplinary actions 

as the 'unwanted behavior' had continued after the initial disciplinary actions. 

Joseph told Carl Yeh that he (Joseph) had actually changed his behavior in accordance with the 

previos disciplinary actions. Joseph told Carl that he (Joseph) no longer approached random 

students with greetings in Asian languages. Joseph contended that if he wanted to talk with 

anyone on campus he had changed his greeting to an English one instead. Joseph stated that 

his standard greeting was now a self introduction in English: "Hello, my name is Joseph Waite, I 

am a student of languages, do you speak any other languages?" Joseph stated that he had 

modified his behavior in accordance with the previous disciplinary action to the effect that he 

would only employ a foreign language in conversation once it had already been determined that 

the person he (Joseph) was attempting to communicate with could speak the language, and was 

comfortable conversing in said language with Joseph. 

During the meeting Joseph also told Carl that he (Joseph) believes greeting someone in a public 

place with a language of his choosing is protected speech under the First Amenment of the US 

Constitution. Carl Yeh is on record telling Joseph a statement to the effect: "Actually you don't 

have Freedom of Speech here, and if you think you can say whatever you want to, then we can 

use our methods to make you go somewhere else." And another statement to the effect: 

'If you want to date girls on our campus, then you have to do it our way.' 

According to Joseph, during the meeting with Carl Yeh, Carl was holding a large stack of papers 

which he (Carl) said was the case against Joseph. Joseph at this time told Carl that he (Joseph) 

intended to take some computer science classes at UO, and that he (Joseph) intended to apply 

to the UO for graduate school in the near future. Joseph was told by Carl that the document he 

was holding would prevent him from being able to take any further classes at UO. 

According to Joseph, during this meeting, Carl Yeh did not reveal to him the contents of the 

document or the details of the allegations written within. Joseph says that this meeting with Carl 

Yeh was more like a little inquisition, or which hunt, in which Carl attempted to get Joseph to 

further incriminate himself by Carl asking Joseph leading questions from which he hoped to 

provoke Joseph into making inflammatory comments. At the close of the meeting, Carl Yeh told 

Joseph Waite that a redacted version of the document would be sent to Joseph so that Joseph 

could know the reasons for why he (Joseph) was being excluded from taking any further classes 

at UO. 

Joseph returned home after the meeting confused, bothered, and upset, still unaware of what 

specifically he was being accused of, or what it was that they thought he had done wrong. 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 4 of 11
Joseph continued to endure the stress of the situation, without receiving the redacted version of 

the document promised to him (Joseph) by Carl Yeh. Over a week had passed without Joseph 

receiving anything further from Carl Yeh. It came to the point where Joseph Waite had to send 

an e-mail to Carl Yeh requesting the redacted version of the document as had been promised to 

him a week before. A second week passed and finally after two weeks since their meeting, 

Joseph received the redacted version of the document in the mail. 

The document was an investigation report put together by the UO's Office of Affirmative Action 

and Equal Opportunity in cooperation with the University of Oregon's Department of Public 

Safety (UODPS). It is also important to note that the UODPS had by this time been converted to 

the University of Oregon Police Department (UOPD). 

The details of the document can be read from the document itself, an unredacted version of 

which could be made available to the court through contacting the UO's Office of the Dean of 

Student Conduct. Joseph Waite is also in possession of the redacted version of the report and 

can attach the document and send it to the court upon returning to the United States on January 

first 2015. Joseph Waite is currently out of the country, visiting Taiwan from August 20th 2014 

until January 1st 2015. 

Joseph Waite will here attempt to briefly elaborate on the contents of the document. 

The investigation report made by the UO's Office of Affirmative Action and Equal Opportunity is 

about one hundred pages long, but the information inside repeats details of the same alleged 

incidents over and over again, at least three times each, making it seem as if there were many 

more alleged incidents than the document ultimately states actually occured. 

The majority of the document is simply the documented evidence of Ms. Wong's initial 

complaints, Joseph's previous composed letters in his attempts to defend himself against 

Ms.Wong's accusations, as well as documentation of Carl Yeh's Disciplinary action decision, in 

which he (Carl Yeh) had found Joseph Waite guilty of "unwanted contact" under the UO's 

student conduct code. 

In the document, the initial case involving Ms. Wong, is supplemented with several other very 

similar reports, or complaints, accusing Joseph Waite of being seen around UO campus 

approaching female asian students and speaking to them in an Asian language. 

Some of these reports, or complaints, were apparently made by third party individuals whom had 

observed Joseph in public places around campus. However, these third party individuals were in 

many instances not the individuals whom Joseph had approached and spoken to. Joseph would 

like to point out that such a third party probably misinterpreted his (Joseph's) intentions, such a 

third party observing Joseph probably could not speak the asian language Joseph was 

attempting to communicate with, and therefore could not truly understand the content of 

Joseph's conversations with other students around him, and such a third party could only 

assume being approached in public in such a way might make a student uncomfortable. 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 5 of 11
Joseph also would like to point out the fact that these third parties may have obsevred Joseph 

speaking with his girlfriend, Yu Hua Chen, who is a female asian student at UO majoring in 

psychology. The familiarity between Joseph and Yu Hua could have been misinterpreted by a 

third party as Joseph allegedly behaving in an inappropriate 'overly familiar' way with a female 

asian student with whom he may have been perceived to not actually be familar with, but actually 

is intimately familiar with. 

Furthermore, Joseph is curious as to the reason, or motive, that these third parties have to spy 

on him and report false accusations to the school. It is surmisable that such individuals are 

acting out of malice towards Joseph Waite. Joseph states that such malice maybe the result of 

jealousy over Joseph's substantial language abilities, as he is fluent in Mandarin Chinese, 

Korean language, as well as Japanese language, as a result of his life-long efforts at language 

study. Joseph surmises that people could simply be jealous of his ability to effectively 

communicate with females on campus. 

Joseph would also like to point out that such malice directed towards him could simply be the 

result of untrue rumors, slander & libel, which had taken place as evidenced by the statement 

made by the former English tutor of UO's American English Institute (AEI). As stated above the 

investigation report had revealed that upon being interviewed by UODPS, a former AEI English 

tutor made a statement to the effect that: 'One year the English tutors from AEI got together, 

composed, and used an official UO e-mail delivery system to telling every female asian student 

associated with the UO "warning them of Joseph Waite" as a potential threat.' The existence of 

such an e-mail would certainly wrongly implicate Joseph Waite of crimes which he had never 

actually committed. Also, very interestingly, as stated in the investigation report, even the 

UODPS officer performing the investigation makes a note in the document to the effect: 

'accusations against Joseph Waite are not factual, and the individuals responsible for circulating 

untrue rumors about Waite maybe themselves guilty of harassment of Waite.' 

As most of the names of individuals accusing Waite of various misconducts had been redacted 

by Carl Yeh, it is impossible for Joseph Waite to here state the names of the individuals whom 

were Waite's accusers. Furthermore it is surmisable that any or all of the complaints were 

fabrications made by unknown parties solely for the purpose of intimidating and falsely 

incriminating Waite. Only with a court ordered release by the UO of an unredacted version of the 

document can we know the identities of the parties involved in accusing Waite. 

· Details of the investigation report continue: 

In one instance Waite is accused of entering a female asian student's dorm room without 

permission and it is alleged that Waite attempted to seduce the student while already not being 

welcome in the dorm room. There is a comment attached that makes a statement to the effect: 

'It sounds like he tried to rape her.' Joseph would like to point out that such an incident actually 

never occurred, that he would never enter anyone's dorm room uninvited, and that he (Joseph) 

certainly never 'tried to rape' anyone; furthermore, such a statement is pure speculation, and 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 6 of 11
such a statement attempts to use emotive language such as the word 'rape' to unfairly frame, or 

profile Joseph as a sexual predator, something he is not. 

Joseph again wrote to the UO and included a denial that such an incident had ever occurred in a 

third letter to the UO's Office of the Dean of Student Conduct, in another attempt for him 

(Joseph) to defend himself against such allegations. However Joseph's pleas of his own 

innocence fell on deaf ears and were summarily ignored. 

Elaboration on the contents of the investigation report document continue: 

In another (false) statement found within the document, and offered as evidence to condemn 

Joseph Waite's behavior. He (Joseph) was accused by an unknown party of approaching 

not a female, but a male asian student and asking him for a kiss. 

Again, Joseph Waite denies that such an incident ever actually occured. Joseph Waite will tell 

you the truth, that his sexual orientation is hetero-normal, and states that he would never ask a 

boy for a kiss. Again, this is clearly a fabricated incident intended to intimidate, and incriminate 

Joseph Waite for improper behavior which he did not actually do. Joseph Waite would like to 

point out that such a fabricated story may have been included in the document in an attempt to 

get Joseph Waite upset of being accused of being a homosexual, so that he might make 

inflamatory remarks against homosexuals. Yet a further attempt by his accusers to get Joseph 

to make comments that might self incriminate, further destroying his (Joseph's) good name and 

reputation, and be used against him (Joseph) if he tried to defend himself. Joseph would also 

like to state that some of his best friends are homosexuals, but Joseph is straight-heterosexual. 

Elaboration on the contents of the investigation report document continue: 

There was another important point found within the document which is according to Joseph; 

a completely absurd and ridiculous insinuation, and proves nothing. 

The next claim, or statements, referred to above are elaborated in the following paragraph: 

At an unspecified time, unknown to Joseph Waite, which could have been as early as 2006, but 

the specific time could only be clarified by re-opening the UODPS report. 

A female asian student (again whose identity is unknown to the accused Joseph Waite), 

apparently was told by an American English Institute (AEI) Teacher to file a complaint I report 

against Joseph Waite with UODPS. 

The subsequent report, evidence of which appears in the document, 

is extremely suspicious in nature because although it claims to be an official report, 

it is obviously erroneous and blatantly contradicts itself, stating two completely different versions 

of the same incident which they claim is a real occurrence, and not just another fabrication. 

It reads to the effect: 

The female asian student initially claims to UODPS that: 

'Joseph Waite gave me a drug and had sex with me.' 

However, in the very next sentence this statement is retracted as a translation error, 

notedly because the individual attempting to make the complaint does not speak English. 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 7 of 11
As reinterpreted by a fellow from the same country who apparently accompanied the party, 

(The party now apparently consisting of at least three individuals: 

The AEI student attempting to file a complaint, the AEI teacher who told the student to file the 

complaint, and the fellow countryman of the student who reinterprets the statement for the officer 

attempting to take the complaint.) 

The statement is subsequently changed from: 

'Joseph Waite gave me a drug and had sex with me,' 

to the much more innocent sentiment: 

'Joseph Waite offered me a drug, and asked to have sex with me.' 

Obviously, these are two completely different statements, which kind of contradict each other; 

the first being a horrendous crime, the second not even being a crime. 

It certainly must have been confusing for the officer attempting to take the report, 

and subsequently something about it showed up on Joseph Waite's Eugene Police record; 

'Public Indecency' is found on Joseph Waite's record as provided upon request by the 

Eugene police department on country club road. 

The reason for the existence of such a record of 'Public lndeceny' appearing on his 

personal record are unknown to Waite, and he can only surmise that this (false) report 

may in fact be the reason why it appears that way. 

Furthermore, when and if Joseph Waite wins this case in trial, he would like 

any and all such claims of 'public indecency' or 'public threat' 

to be removed from his personal record as they are all resulting from 

the circumstances of this case. 

In the third letter Joseph Waite wrote to the school in his attempt to defend himself, 

Waite also denied that he had ever offered anyone a drug. Waite stated that this statement 

could only refer to his (Waite's) speaking to students from Asia, explaining the State of 

Oregon's Medical Marijuana Program (OMMP), and only speaking of it when asked. 

Joseph Waite had already composed a third letter "To whom it may concern" at the UO's Office 

of the Dean of Student Conduct, but there was no reply or reconciliatory action taken by the UO. 

In addition to the third letter, Joseph Waite made several appointments with the administrators; 

including several meetings with Carl Yeh, Chicora Martin and Dean Paul Shang. 

In the end, the three administrators of the UO's Office of the Dean of Student Conduct had 

clearly conspired together to form a consensus decision, banning Waite from further classes on 

UO campus. However, as Waite had already spent about ten years as a part time student at UO 

earning all the credits he needed for his B.A. in Chinese language, they could not deny Waite his 

degree. Although Waite wanted to continue his education by taking computer science classes 

as a post bachelor, and eventually enter grad school at UO; Waite was informed that this would 

be impossible, and he was told that he would be forced to apply for graduation now. 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 8 of 11
At the end of one meeting Chicora Martin even told Joseph Waite her opinion that: "I think you are 

a perfectly healthy individual." However in other meetings Chicora Martin told Joseph Waite 

something to the effect that: 'You are a privileged white male in this country." To which Joseph 

Waite was eventually able to respond something to the effect that: "That is just your ideology, 

and it demonstrates your bias against me." Also Joseph asked Chicora why there is such a 

strong hatred of men in her beliefs. Chicora ended the meeting shortly after Joseph defended 

himself with that statement. Chicora Martin is also on record threatening Waite with further 

actions; such as she threatened to attach a letter to his personal transcript from UO; a letter 

attachment to the transcript that would state that 'Dr. Martin' would warn any graduate school 

reviewing Waite's transcript that Waite is an insubordinate disciplinary threat. She claimed that it 

is within her power to do so, in a further attempt to intimidate Waite into silence, to keep him 

from telling anyone what had happened. 

Believing it legally sound to do so, Joseph Waite secretly brought a digital voice recorder 

to at least two of his meetings: one with Carl Yeh, and one with Chicora Martin. 

Joseph Waite states that he is unclear whether it is legal to digitally record someone speaking 

without their knowledge, but he (Joseph) believes that it is legal to record someone without their 

permission in a public place, as long as the recordings are not used for dubious or commercial 

purposes. Joseph Waite states that he believes the inside of a UO administrator's office is a 

kind of public space as it is a public institution funded in part by the federal government. 

Waite will gladly make available to the court all the digital voice recordings of meetings between 

himself and Carl Yeh, as well as a meeting between himself and Chicora Martin; which prove 

many of the above claims. 

Furthermore, Joseph states that he was afraid no one would believe him that officials from the 

University of Oregon would conduct business in such a manner, or say the kind of biased things 

they would say, which could be used as evidence supporting the case that Waite was unfairly 

discriminated against by UO admins based on Sex, his gender, his sexual orientation, his 

ethnicity, or race, as well as his chosen field of study which happened to be Chinese language. 

Joseph Waite would like to point out that he believes none of this would have happened if any of 

the following were the case: If Joseph was a Chinese-American, or a student from China, 

would it be alright for him to mistakenly greet an asian looking student with an asian language, 

if Joseph Waite had been a female, or a homosexual, would his attempts to practice the 

language of his chosen field of study be misinterpreted as the acts of a sexual predator? 

Joseph Waite attempted to clear his name with and through the UO's Office of the Dean of 

Student Conduct. He (Joseph) states that he did everything he could to avoid turning this 

situation into a lawsuit. He (Joseph) states that he likes the UO, and has enjoyed his time there, 

as well as accumulated a lot of valuable knowledge through his daily diligent studies on UO 

campus. Joseph states that the only reason this lawsuit is being filed is because he wishes to 

continue taking classes at UO as a post bachelor, and possibly applying for graduate school, 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 9 of 11
but that despite his countless attempts to clear his name and to clear the registration hold within 

the University's own system, all of his attempts have been in vain, all of his letters attempting to 

defend himself have either fallen on deaf ears, never been replied to by anyone, or even 

remarkable how his first and second letters defending freedom of speech have been used 

against him as by being placed inside the accusing investigation report document as if it were 

evidence to be used against him. 

These are the reasons that Joseph Waite believes he has been the victim of a title IX violation by 

University of Oregon employees. He (Joseph) states that: it wasn't because of anything that I 

actually did wrong that I am now banned from taking further classes at UO, rather it is simply 

because I am a hetero-normal white caucasian male who studies and speaks east asian 

languages falling victim to the bias and discriminatory practices of a few individuals within the 

UO's administration. Consequently the individuals responsible for deciding the fate of Joseph 

Waite have a clear conflict of interest which makes them completely biased against Waite. 

It is because this case which has inherent ethnic, racial, and sexual overtones 

has thus far been decided solely by three administrators. 

Dean Paul Shang and Assistant Dean Carl Yeh's conflict of interest is apparent because they 

are both Chinese-Americans whom according to themselves do not speak Chinese, 

and a third assistant to the Dean: Chicora Martin who is a self declared lesbian; 

who boasts an ideology of hate during office meetings as she explains her views to Waite about 

how being a white man in this country is a privilege. (Apparently privileged white males aren't 

allowed to learn or speak the language of the Chinese according to the Chinese-American 

administrators and the self proclaimed white man hating lesbian). 

Documentation to be made available to the court on January 1st 2015: 

(Joseph Waite is out of the country visiting Taiwan from August 20th 2014- January 1st 2015.) 

Joseph Waite's student transcript 

which shows a curriculum of upper level Chinese and Japanese language classes 

Joseph Waite's UO Degree; B.A. in East Asian Languages and Literatures 

majoring in Chinese language and minoring in Japanese language 

Joseph Waite's admission letter to the UO which states that based on his academic success 

he (Joseph) is welcomed to enroll in classes as a regular student for Spring 2014 (March) 

A print out of a page of Joseph Waite's Duckweb account which shows that there was 

a registration hold on his account in March 2014 which has never been lifted 

A Bill from the University of Oregon for $350. for March 2014 "Matriculation Fee" 

The Investigation Report Document (redacted version) 

made by the UO's Office of Equal Opportunity & Affirmative Action 

Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 10 of 11
The document states at the top: "possible Title IX Case" 

which outlines everything that Joseph Waite was being accused of 

as well as containing comments by the investigating officer 

which state that the officer's opinion was that 

accusations against Waite are not factual 

and the individuals responsible for circulating untrue rumors 

may themselves be responsible for harassment of Waite 

Also included in this document is the interview by UODPS 

of a former AEI employee who stated that: 

'one year the AEI English tutors got together and sent out 

a mass email to all asian female students associated with UO 

"warning them of Waite"; 

which might be considered slander & libel 

as well as the primary cause of all of the subsequent troubles 

The Three Letters: 'To whom it may concern," which Joseph Waite 

wrote to the University of Oregon's Office of the Dean of Student Conduct 

in his attempts to defend himself and resolve these issues through the UO's system 

At least two digital voice recordings and their transcripts: 

one of a meeting between Carl Yeh and Waite 

the other of a meeting between Chicora Martin and Waite 

which prove that these admins handled Waite's case 

in a biased and discriminatory manner. 

~1/I..WW:k 

J o s e..y h l"\cxtl-he..'N Wo..l +e 

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Case 6:14-cv-01400-MC Document 1-3 Filed 08/29/14 Page 11 of 11