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Pastimes : Murder Mystery: Who Killed Yale Student Suzanne Jovin?

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To: John A. Sladek who wrote (886)1/26/2001 4:17:23 PM
From: Jeffrey S. Mitchell  Read Replies (2) of 1380
 
Re: 1/12/01 - Complaint: James Van de Velde vs. Quinnipiac University, Paul Steinle, John Morgan and Lynn Bushnell


RETURN DATE: February 13, 2001 : SUPERIOR COURT

JAMES VAN DE VELDE : J. D. OF NEW HAVEN

VS. : AT NEW HAVEN

QUINNIPIAC UNIVERSITY, PAUL STEINLE, : JANUARY 12, 2001
JOHN MORGAN and LYNN BUSHNELL


COMPLAINT

PARTIES

1. Plaintiff James Van de Velde is a resident of Virginia. At all times relevant to this complaint, he was a faculty member at Yale University, and a student enrolled in the Masters in Broadcast Journalism program at Quinnipiac College.

2. Defendant Quinnipiac University, f/k/a Quinnipiac College ("Quinnipiac") is an institution of higher education located in Hamden, Connecticut, offering a variety of undergraduate and graduate educational programs, including a Masters in Broadcast Journalism program.

3. At all relevant times, defendant Paul Steinle was the director of Quinnipiac's Masters in Broadcast Journalism program ("the Program"), acting within the scope of his duties as an agent, servant or employee. As director, he had overall responsibility for students enrolled in that program.

4. At all relevant times, defendant John Morgan was a spokesperson for defendant Quinnipiac, acting within the scope of his duties as an agent, servant, or employee.

5. At all relevant times, defendant Lynn Bushnell was a spokesperson for Quinnipiac, acting within the scope of her duties as an agent, servant or employee.

FIRST COUNT - (Defamation Against Defendants Quinnipiac, Steinle and Morgan)

6. In the summer of 1998, Van de Velde was employed as a faculty member at Yale University, teaching in the field of international relations and diplomacy.

7. In August 1998, Van de Velde enrolled in the Masters in Broadcast Journalism Program at Quinnipiac. Van de Velde entered the program on a part-time basis, enrolling in one class in the Fall 1998 semester while continuing to fulfill his teaching duties at Yale.

8. During the fall 1998 semester, Van de Velde successfully completed all academic requirements of the Program. He was at all times in good academic standing in the Program.

9. As part of his participation in the Program, plaintiff attempted to secure an internship in broadcast journalism at a Connecticut television station. The Program assists students in obtaining such internships, and offers course credit for completion of internships.

10. In August 1998, Van de Velde accepted an internship at WTNH-TV in New Haven.

11. Plaintiff began the WTNH internship on September 1, 1998. At or about that time, plaintiff's teaching duties at Yale also began.

12. When plaintiff's teaching duties began, he quickly learned that both courses he was scheduled to teach were greatly oversubscribed.

13. Because of his concern that he could not fulfill his primary duties to Yale while participating in the WTNH internship, Van de Velde concluded that he should resign the internship position. He notified WTNH of his decision by letter dated September 4, 1998, citing his academic teaching commitments.

14. By mid-September 1998, the course enrollment in plaintiff's Yale classes had been substantially reduced, and his concern lessened about the time commitment of a broadcast journalism internship.

15. In mid-September 1998, Van de Velde was contacted by WVIT-Channel 30, to whom he had also applied in August, and ultimately offered an internship. Plaintiff accepted this position.

16. Plaintiff began the WVIT internship in late September 1998 and successfully completed in on or before December 6, 1998.

17. On December 9, 1998 the New Haven Register reported that the New Haven Police had focused on and questioned a Yale lecturer as the "prime suspect" in the murder of Suzanne Jovin, a Yale student who had been killed on December 4, 1998.

18. Later that day, broadcast media identified Van de Velde as the Yale instructor who had been questioned and identified as a "suspect" in the Register article. Van de Velde denied, and continues to deny, any involvement in Jovin's murder.

19. On December 10, plaintiff was identified in numerous print media, including the Register, as an individual who had been questioned at length in connection with the Jovin murder investigation. When read against the backdrop of the December 9th "prime suspect" article in the Register, it was clear that Van de Velde was the "suspect" referred to in that article.

20. Also on December 10, 1998, defendant Steinle wrote Van de Velde notifying him that he was suspended from the Program effective immediately.

21. The stated basis of this suspension, according to Steinle's letter, was (1) information allegedly received from WVIT that plaintiff's internship had been terminated by the station without comment, and (2) information supposedly received from WTNH that plaintiff's internship with that station allegedly was terminated at their request, contrary to what plaintiff had previously said to Steinle.

22. Both allegations in the Steinle letter were false, and plaintiff, through representatives, informed Steinle of their falsity.

23. On January 11, 1999, Yale University announced that it was relieving Van de Velde of his teaching duties for the Spring 1999 semester. Yale indicated that Van de Velde was, according to the New Haven Police, in a "pool of suspects" in the Jovin murder investigation.

24. This January 11, 1999 action and announcement spawned intense media interest in plaintiff, and all aspects of his life.

25. On January 13, 1999 the Hartford Courant reported for the first time that police allegedly had received complaints about plaintiff from two television reporters -- including a complaint that plaintiff allegedly peered into a reporter's window and called her after the end of a relationship.

26. Also on January 13, 1999, the New Haven Register published a personal profile of Van de Velde. This profile stated, among other things, that Van de Velde was enrolled in the Masters program at Quinnipiac. This fact had not been previously reported to the public.

27. Two days later, on January 15, 1999, the Register reported, through defendant John Morgan, a Quinnipiac spokesman, that plaintiff had been "dropped" from the Program in early December 1998. The article indicated that Morgan would not discuss the reason for the dismissal.

28. The Register further reported that "sources" said that a letter of dismissal referred "to the fact that Van de Velde was terminated from an internship he served at WVIT-Channel 30 and that he also did not complete an internship at WTNH-Channel 8."

29. The letter of dismissal cited in the January 15th Register article was the Steinle letter to Van de Velde of December 10, 1998.

30. On information and belief, the "sources" responsible for this statement in the January 15th Register article were defendant Morgan, defendant Steinle, or another individual acting on behalf of Quinnipiac. Van de Velde did not make the December 10th Steinle letter public. Further, this letter was an academic record required to be kept confidential under federal law, and therefore only plaintiff and Quinnipiac had access to it.

31. The Quinnipiac "sources" knew or should have known that the statement would be published by the Register in written form, and disseminated to a wide audience.

32. The "source" allegations first published in the January 15th article regarding alleged termination of Van de Velde's internships were repeated in subsequent media reports, including a January 16, 1998 article in the Hartford Courant.

33. The January 15th statements reported in the Register regarding Van de Velde's alleged termination of two internships were defamatory, false, and malicious.

34. The January 15th false statements were a pretext, attempting to justify Quinnipiac's suspension of plaintiff after he was publicly linked to a high-profile homicide investigation.

35. The plaintiff, through counsel, on January 19, 1999 notified defendant Steinle of the falsity of the statements, after representatives from both WVIT and WTNH confirmed that Van de Velde had not been terminated from either internship.

36. The defendants failed to retract their false statements regarding plaintiff's internships.

37. Defendants' false statements regarding plaintiff's internships, when read in context with media scrutiny of Van de Velde's alleged relationships with female members of the news media and his status as a murder suspect, implied that plaintiff had engaged in inappropriate behavior at the television stations, and therefore that there might a legitimate basis for suspicion of his involvement in the Jovin murder.

38. As a result of these false, defamatory, and malicious statements, plaintiff has been damaged. His good name, character and reputation have been greatly injured; he has suffered loss of employment and employment opportunity, including a possible career in broadcast journalism; he has been denied employment at institutions of higher education; he has suffered, pain, anxiety, mental anguish, and humiliation, and will continue to suffer such damage in the future.

SECOND COUNT - (Defamation against Quinnipiac and Lynn Bushnell)

1.-38. Paragraphs 1-38 of the First Count are hereby incorporated by reference and re-alleged as Paragraphs 1-38 of the Second Count.

39. Prior to January 1999, plaintiff enjoyed an excellent academic reputation.

40. On January 28, 1999, in an article published in the New York Times, defendant Lynn Bushnell stated, as a spokesperson on behalf of Quinnipiac, that Quinnipiac dismissed Van de Velde for "academic reasons."

41. This statement was defamatory, false, and malicious. Defendant Bushnell knew or should have known (1) that Van de Velde had satisfied all academic requirements for the Fall 1998 semester in the Program, and (2) that the reasons stated for Van de Velde's suspension from the program were false.

42. Bushnell knew or should have known that the statement would be published by the New York Times in written form, and disseminated to a wide audience.

43. Because Van de Velde was employed as an instructor by an institution of higher education, the public statement that he had been dismissed from the Program for "academic reasons" was especially damaging, as it implied academic failure by him.

44. As a result of this false, defamatory, and malicious statement, plaintiff has been damaged. His good name, character and reputation have been greatly injured; he has suffered loss of employment and employment opportunity, including a possible career in broadcast journalism; he has been denied employment at institutions of higher education; he has suffered, pain, anxiety, mental anguish, and humiliation, and will continue to suffer such damage in the future.

WHEREFORE, the plaintiff claims damages.

THE PLAINTIFF,
JAMES VAN DE VELDE

By____________________________________
David T. Grudberg
JACOBS, GRUDBERG, BELT & DOW, P.C.
His Attorney

RETURN DATE: February 13, 2001 : SUPERIOR COURT

JAMES VAN DE VELDE : J. D. OF NEW HAVEN

VS. : AT NEW HAVEN

QUINNIPIAC UNIVERSITY,PAUL STEINLE, : JANUARY 12, 2001
JOHN MORGAN and LYNN BUSHNELL

STATEMENT OF AMOUNT IN DEMAND

The amount in demand, exclusive of interest and costs, is more than Fifteen Thousand
($15,000.00) Dollars.

THE PLAINTIFF,
JAMES VAN DE VELDE

By____________________________________
David T. Grudberg
JACOBS, GRUDBERG, BELT & DOW, P.C.
His Attorney
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