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1. I was employed from April 1, 1985, to January 31, 2002, as Lab Manager and Research Associate Professor at the
Department of Geosciences,
Stony Brook University.2. I have always received the highest evaluations and performed research at the levels that could be rated among the best in the world by any standards of scholarly achievement. This was summarized in the document: “Credentials and Accomplishments” (
E – “D”) and the supporting documentation (E – 61-100).
3. However, for most of my employment, I was subject to a series of hostile actions by my superiors, employees of the University, with the clear intention of making my work difficult and life miserable and thus to force me to leave my employment. This was summarized in the document: “Account of my Persecution” (
E – “A”) and the supporting documentation (E – 1-60).
4. When these actions failed, I was dismissed on January 31, 2002, in gross violation of my true seniority status, under the excuse that “the project has ended” (
E-28).
5. Yet, despite being the most senior and most valuable and accomplished scientist among all scientists participating in the project (
E-29/1), and could be rated as one of the best faculty members (
E-29/2), I was the only one dismissed under this excuse.
6. Although, I retained my position as Research Associate Professor at the Department of Geosciences, the University would not consider me for any employment that could provide a salary.
7. Attempts to secure research funding and salary from the
National Science Foundation (NSF) were sabotaged by my former superiors at the Department (
E-33). This has also become evident from the fact that the NSF stopped sending me research proposal for review immediately following my dismissal (
E-35).
8. My complaints to the Provost (
E-38) and President (
E-40,
E-52) of the Stony Brook University were stonewalled.
9. To obtain an alternative source of income, I completed at the same University a Masters of Art in Teaching (MAT) degree in Earth Science in May 2005, and hoped to start a new career as secondary school teacher (
E-63).
10. I was promised a leave of replacement position at Ralph G. Reed Middle School in Central Islip, following completion of all requirements and satisfactory performance as student teacher between March and May 2005 (
E – “E”).
11. The University promised to expedite the certification process following satisfactory completion of all requirements. Instead, the University delayed issuing a letter to that effect, which resulted in the loss of this employment opportunity (
E – “F”).
12. When I posted, at the end of June 2005, a
Web site summarizing my persecution, the University and the Department retaliated, in violation of the First Amendment, by taking my name off the list of faculty members posted on the departmental Web site, and ordered me to vacate my office at the Department (
E-59).
13. Because this action made it extremely difficult or nearly impossible for me to continue in my efforts to secure research funding, further contribute to the advancement of science, and restart my former career as scientist and professor, I was forced to seek justice through the legal system and filed a complaint at the United States District Court in Central Islip on August 11, 2005 (
E-60).
14. For many years I searched in vain for an explanation for the startling discrepancy between my superior performance and accomplishments as a scientist (
E – “D”), and the indifferent or hostile behavior by my colleagues at the Department of Geosciences (
E – “A”)
15. Several of my colleagues at the Department devoted extraordinary amounts of time and effort to a single goal: forcing me to leave.
16. In the last few years, it has become obvious that most universities and colleges in the United States discriminate against conservative professors in hiring, retention and promotion (
E – “G”,
E – “H”).
17. This fact is based on surveys, voter registration records and voting records (
E – “I”).
18. Stony Brook University has a record of belonging to more extreme of the institutions of higher education in its liberal policies and liberal bias.
19. For example, only 18% of the university employees voted for President Bush in the last presidential elections on November 2, 2004 (
E- “J”).
20. I have never tried to hide my conservative views nor my record of voting for Republican candidates, but cannot name any faculty member or other university professor who is not a liberal.
21. I do not even have the option of pretending to be a liberal, because it is widely known among my peers in the scientific community that I am a refugee from communism; in fact, I am a registered Republican.
22. I believe the forgoing to be the primary reason for the discrimination against me in hiring, retention and promotion, and for the acts of persecution by my colleagues at the Department, university administrators, and other members of the scientific community.
23. The Stony Brook University, by the above-described actions, discriminated against me, dismissed me from employment, and took other adverse personnel actions against me because of my political orientation.
24. By reason of the forgoing, the Stony Brook University is liable for unlawful discrimination against me in violation of the
Right to Free Speech and
Freedom of Association under the First Amendment of the United States Constitution and for violation of 42 U.S.C. sections
1983,
1985-
6.
25. By reason of the forgoing, I suffered, and continue to suffer, loss in employment, loss in wages, have suffered metal anguish, emotional distress and loss of enjoyment of life, and have incurred damages thereby.
26. By reason of the forgoing, the Stony Brook University is liable to me for compensatory damages, attorney’s fees, expenses, and punitive damages.