About Chanel Miller’s Memoir and the San Francisco Public Library (SFPL) - #Michael Ayele (a.k.a) W 2016 Habeas Corpus

12. REQUEST FOR RECORDS 09/05/2023 W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia E-mail : waacl13@gmail.com ; waacl1313@gmail.com ; waacl42913@gmail.com Date.: September 05th 2023 Hello, This is Michael A. Ayele sending this message though I now go by W. You may call me W. I am writing this letter for the purpose of filing a request for records with your office.i The bases for this records request are [1] the September 2016 rumored Brock Turner “college speaking tour” on the subject of “alcohol and promiscuity” after he had spent 90 (ninety) days in county jail for sexually assaulting Chanel Miller while she was unconscious;ii [2] the dissenting opinion issued by Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson in the Students for Fair Admissions v University of North Carolina as well as President and Fellows of Harvard College case. iii Request for Records I) Records Requested What I am requesting for prompt disclosure are records in your possession detailing your discussions about [1] Brock Allen Turner as a Caucasian man, who (i) began attending Stanford University as a Freshman student sometime in (or around) the month September 2014; (ii) was more likely than not informed what constitutes “affirmative and effective consent” in healthy sexual relationships when he was a Freshman undergraduate student of Stanford University;iv (iii) was on (or around) January 10th 2015 accused of being sexually inappropriate with a female student who was (also) attending Stanford University;v (iv) was on (or around) January 18th 2015 arrested for sexually assaulting Chanel Miller behind a dumpster (on the campus of Stanford University) while she was unconscious;vi (v) was on (or around) March 30th 2016 found guilty of sexually assaulting and sexually penetrating Chanel Miller while she was unconscious despite his claims that he had not done so;vii (vi) was not remanded to custody on (or around) March 30th 2016 even though he had been found guilty of sexually assaulting Chanel Miller while she was unconscious; viii (vii) was on June 02nd 2016 sentenced to 6 (six) months of county jail for the sexual assault he perpetrated on Chanel Miller; (viii) has gone on to be released from the Santa Clara county jail on (or around) September 02nd 2016 after serving 90 (ninety) days of the six months jail sentence; (ix) was in the month of September 2016 reported to have seriously considered going on a “college speaking tour” to warn young people of the risks associated with “alcohol drinking and promiscuity;” [2] Chanel Miller as a woman of Asian descent, who (i) was very much vexed by the 6 months jail sentence handed to Brock Turner on June 02nd 2016;ix (ii) believes that her life is worth significantly more than the 90 day prison sentence Brock Turner ended up serving after he had sexually assaulted her;x (iii) has had a very unpleasant phone call MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 1

13. REQUEST FOR RECORDS 09/05/2023 with a probation officer in Santa Clara, California following the conviction of Brock Turner on March 30th 2016;xi [3] the decision of Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson to note that “it is not a stereotype to acknowledge the basic truth that young people’s experiences are shaded by a societal structure where race matters;”[4] fear of public speaking (or glossophobia) ranking as one of American’s greatest fears. xii II) Request for a Fee Waiver and Expedited Processing The requested records do/will demonstrate that [1] Michael A. Ayele (a.k.a) W is a Black man, who has never denied (i) having come to the United States of America (U.S.A) on an F-1 Visa in the month of December 2009 for the purpose of obtaining a Bachelor of Arts (B.A) Degree from Westminster College (Fulton, Missouri); (ii) having been informed what constitutes “affirmative and effective consent” in healthy sexual relationships during Calendar Year 2010 when he was an undergraduate student of Westminster College (Fulton, Missouri); (iii) having been informed about the April 05th 1986 rape and murder of Jeanne Ann Clery during Calendar Year 2010 when he was an undergraduate student of Westminster College (Fulton, Missouri); (iv) having taken issue with manner in which he was informed about the rape and murder of Jeanne Ann Clery as well as the way he was informed about “consent;” (v) having initiated contact with the Department of Justice (DOJ) Federal Bureau of Investigation (FBI) as well as the Central Intelligence Agency (CIA) about the April 05th 1986 rape and murder of Jeanne Ann Clery;xiii (vi) having become a member of the San Francisco Public Library (SFPL) sometime in the months of November/December 2014; (vii) having initiated contact with the SFPL about Chanel Miller’s memoir entitled: “Know My Name;”xiv[2] Chanel Miller is a woman of Asian descent, who (i) was on January 18th 2015 sexually assaulted (by Brock Turner) behind a dumpster on the campus of Stanford University; (ii) is an alumna of the University of California, Santa Barbara (UCSB); (iii) became an alumna of the UCSB after having been traumatized by the May 23rd 2014 horrific incident near that campus; (iv) recommended for Brock Turner to seek mental health counseling because she was afraid that he might do something similar to what Elliot Rodger did on May 23rd 2014;xv (v) who has never explicitly opposed the 6 (six) year prison sentence recommended by Alaleh Kianerci after Brock Turner was found guilty of sexually assaulting and sexually penetrating her; [3] Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson are women, who have (during the month of July 2023) been subjected to extensive media interest for writing (in part) that “it is not a stereotype to acknowledge the basic truth that young people’s experiences are shaded by a societal structure where race matters.” In my judgment, the facts presented in my request for a fee waiver and expedited processing are not the sort to bolster public confidence in the activities, the engagements and the priorities of the U.S government (overall), but more particularly in those of the U.S judicial branch of government. As a Black man with a U.S college degree, who was in January 2010 informed what constitutes “affirmative and effective consent” in healthy sexual relations, I would like to take this opportunity to [1] condemn violence committed against women irrespective of their racial MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 2

14. REQUEST FOR RECORDS 09/05/2023 backgrounds, their sexual orientations, their national origins, their religious affiliations and/or their disability status; [2] condemn the rape and murder Jeanne Ann Clery was victim of on April 05th 1986 when she was an undergraduate student of Lehigh University (located in the State of Pennsylvania); [3] condemn the sexual assault Chanel Miller was victim of on January 18th 2015 on the campus of Stanford University (located in the State of California); [4] express in writing the outrage I felt upon learning (sometime) in June 2016 that Brock Allen Turner was very likely going to be spending 90 (ninety) days in county jail even though he was on March 30th 2016 found guilty of sexually assaulting and sexually penetrating Chanel Miller on the campus of Stanford University; [5] condemn the discrimination, the racism, the sexism and the many double standards I have had to (i) bear witness to and/or (ii) experience in person; [6] condemn gun related violence committed in the United States of America (U.S.A) and/or elsewhere around the globe; [7] condemn the horrific incident perpetrated on May 23rd 2014 near the UCSB by the sexist involuntary celibate (incel) Elliot Rodger. The core issues presented in this records request are as follows. 1) Have you ever had conversations about Americans fear of public speaking? If yes, will you promptly disclose those records? 2) Have you ever had conversations about the privilege and the entitlement a person is born into if that person feels audacious enough to go on a “college speaking tour” for the purpose lecturing young people on subjects such as “alcohol drinking and promiscuity” after having registered as a sex-offender? If yes, will you will promptly disclose those records? 3) Have you ever had conversations about the privilege and the entitlement a person is born into if that person feels audacious enough to go on a “college speaking tour” for the purpose of lecturing young people on subjects such as “alcohol drinking and promiscuity” after having been found guilty of sexually assaulting a woman of color? If yes, will you promptly disclose those records? 4) Have you ever had conversations about the 90-day jail sentence Brock Allen Turner served between June 02nd 2016 and September 02nd 2016 after he had been found guilty of sexually assaulting Chanel Miller (while she was unconscious)? If yes, will you promptly disclose those records? 5) Have you ever had conversations about the reasons why Brock Allen Turner spent 90 days in county jail after he was found guilty of sexually assaulting Chanel Miller (while she was unconscious)? If yes, will you promptly disclose those records? 6) Have you ever had conversations about the strong likelihood that Brock Allen Turner was informed what constitutes “affirmative and effective consent” when he was an undergraduate student of Stanford University during Calendar Years 2014 – 2015? If yes, will you promptly disclose those records? 7) Have you ever had conversations about the reasons why female undergraduate students continue to suffer sexual violence (at alarming rates) even though the men are informed what constitutes “affirmative and effective consent” during the course of their First (1st) year of post-secondary academic education/training (related to Title IX sessions)? If yes, will you promptly disclose those records? 8) Have you ever had conversations about “consent” being a politically contentious issue when it’s being addressed/dealt with by a Black man similarly situated to Michael A. Ayele (a.k.a) W? If yes, will you promptly disclose those records? 9) Have you ever had conversations about the dissenting opinion issued by Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson in the matter of Students for Fair MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 3

15. REQUEST FOR RECORDS 09/05/2023 Petition v University of North Carolina as well as Presidents and Fellows of Harvard College? If yes, will you promptly disclose those records?10) Have you ever had conversations about the decision of Supreme Court Justices Sonia Sotomayor, Elena Kagan and Ketanji-Brown Jackson to note that “it is not a stereotype to acknowledge the basic truth that young people’s experiences are shaded by a societal structure where race matters?” If yes, will you promptly disclose those records?11) Have you ever had conversations about the May 23rd 2014 shooting and stabbing incident that was perpetrated by sexist incel Elliot Rodger near the UCSB? If yes, will you promptly disclose those records? 12) Have you ever had conversations about the reasons why Chanel Miller recommended for Brock Allen Turner to seek mental health therapy taking into account that she’s an alumna of UCSB who was traumatized by the May 23rd 2014 incident near that campus? If yes, will you promptly disclose those records? 13) Have you ever had conversations about the reasons why the Santa Clara County Probation Department never asked Chanel Miller (in their discussions with them) if she was objecting to the 6-year prison sentence that had been recommended by District Attorney Alaleh Kianerci after Brock Turner was on March 30th 2016 found guilty of sexually assaulting Chanel Miller? If yes, will you disclose those records? 14) Have you ever had conversations about the decision of the State of California to (i) expand the legal definition of rape and (ii) impose mandatory minimum sentences following the 90 days of county jail served by Brock Turner for the sexual assault of Chanel Miller? xvi If yes, will you promptly disclose those records? This records request should be expedited because it puts into question the government’s integrity about the way that people are treated in the U.S.A on account of their gender, their racial backgrounds, their national origins and their disability status. My request for a fee waiver should be granted because [1] I have identified operations and activities of the federal government in concert with U.S local/state government; [2] the issues presented are meaningfully informative about government operations or activities in order to be ‘likely to contribute’ to and increase public understanding of those operations or activities; [3] this records request is being filed for non-commercial purposes and any records you disclose to me could be made available to the general public at no financial expense to them. Under penalty of perjury, I hereby declare all the statements I have made to be true and accurate. Be well. Take care. Keep yourselves at arms distance. W (AACL) Michael A. Ayele Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 4

16. REQUEST FOR RECORDS 09/05/2023 Work Cited i Please be advised that I have previously disseminated a vast number of documents obtained through records request using the means of various digital publishing platforms. As a representative of the media, I would like to take this opportunity to inform you that the records you disclose to me could be made available to the general public at no financial expense to them. This records request is being filed for non-commercial purposes. As previously noted, any records disclosed to me could be made available to the general public at no financial expense to them. On December 10th 2021, I have launched a website on Wordpress.com for the purpose of making the records previously disclosed to me by the U.S government further accessible to members of the general public interested in the activities of their elected and non-elected representatives. You can find out more about the recent publications of the Association for the Advancement of Civil Liberties (AACL) here.: https://michaelayeleaacl.wordpress.com/ ii September 09th 2016 Conversation Between Cenk Uygur and Ana Kasparian on the Subject of Rapist Brock Turner “College Speaking Tour” Ana Kasparian.: As if the injustice involved in the Brock Turner case couldn’t get any worse, there are now reports that he could possibly tour high-school campuses in order to give speeches to students about the negative impact of alcohol and promiscuity. (…) So, during this case, and for those of you who might have missed this story, Brock Turner was the former Stanford University swimmer who was caught raping a woman who was unconscious behind a dumpster. He was found guilty and he got a six months jail sentence that was cut short to only three months because of “good behavior.” According to Mediaite, “there was talk during the trial of him launching a speaking tour during which he would visit high schools and give lectures on ‘drinking and promiscuity,’ and now that idea is back in the spotlight.” This story is now in the spotlight because a Stanford University professor (Ruth Starkman) just wrote an opinion piece in the Huffington Post in which she very correctly stated: “Until Brock Turner apologizes, he should not be allowed to speak on campuses. Any campus appearance must be conditioned on his taking full responsibility for his actions, apologizing to the victim, and condemning sexual assault.” He has refused to do all three things even after his convictions. (…) Cenk Uygur.: To me, the most unbelievable part of the story (…) is the drinking part. It seems like he’s saying: “Don’t drink too much. Otherwise, you will go on to rape women behind a dumpster.” Ana Kasparian.: Yeah, there are plenty of people who drink, get drunk and aren’t immediately convinced that it’s a good idea to go rape people. Cenk Uygur.: It seems like he didn’t get it at all. (…) It definitely sounds as though he’s looking MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 5

17. REQUEST FOR RECORDS 09/05/2023 to go around campuses saying that she (Chanel Miller) wasn’t raped. (…) She was being promiscuous. Ana Kasparian.: That’s exactly right! Cenk Uygur.: Oh my God! (…) Ana Kasparian.: He could possibly do this speaking tour and get paid for it! (…) His message is a really bad message that rewards bad behavior. (…) Cenk Uygur.: The bigger injustice is that he gets a lenient sentence while others do not. We have an unequal justice system. I don’t want people coming away from this thinking: “We’ve got to be harsher on all defendants.” We just want an equal justice system. Either treat everybody like Brock Turner or treat everyone harshly, but have one system, not unequal justice. That’s the main point. Rapist Brock Turner College Speaking Tour?The Young Turks. YouTube.: https://www.youtube.com/watch?v=oRTwp0vnbbo&t=96s iiiThe Equal Protection Clause of the Fourteenth Amendment enshrines a guarantee of racial equality. The Court long ago concluded that this guarantee can be enforced through race- conscious means in a society that is not, and has never been colorblind. In Brown v Board of Education, (…) the Court recognized the constitutional necessity of racially integrated schools in light of the harm inflicted by segregation and the “importance of education to our democratic society.” For 45 years, the Court extended Brown’s transformative legacy to the context of higher education, allowing colleges and universities to consider race in a limited way and for the limited purpose of promoting the important benefits of racial diversity. This limited use of race has helped equalize educational opportunities for all students of every race and background and has improved racial diversity on college campuses. Although progress has been slow and imperfect, race conscious college admission policies have advanced the Constitution’s guarantee of equality and have promoted Brown’s vision of a Nation with more inclusive schools. Today, this Court stands in the way and rolls back decades of precedent and momentous progress. It holds that race can no longer be used in a limited way in college admissions to achieve such critical benefits. In so holding, the Court cements a superficial rule of colorblindness as a constitutional principle in an endemically segregated society where race has always mattered and continues to matter. The Court subverts the constitutional guarantee of equal protection by further entrenching racial inequality in education, the very foundation of our democratic government and pluralistic society. Because the Court’s opinion is not grounded in law or fact and contravenes the vision of equality embodied in the Fourteenth Amendment, I dissent. Equal educational opportunity is a prerequisite to achieving racial equality in our Nation. From its founding, the United States was a new experiment in a republican form of government where MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 6

18. REQUEST FOR RECORDS 09/05/2023 democratic participation and the capacity to engage in self-rule were vital. At the same time, American society was structured around the profitable institution that was slavery, which the original Constitution protected. The Constitution initially limited the power of Congress to restrict the slave trade, (…) accorded Southern States additional electoral power by counting three fifth of their enslaved population in apportioning congressional seats, (…) and gave enslavers the right to retrieve enslaved people who escaped to free States (…). Because a foundational pillar of slavery was the racist notion that Black people are a subordinate class with intellectual inferiority, Southern States sought to ensure slavery’s longevity by prohibiting the education of Black people, whether enslaved or free. (…) Thus, from this Nation’s birth, the freedom to learn was neither colorblind nor equal. (…) With time, and at the tremendous cost of the Civil War, abolition came. More than two centuries after the first African enslaved persons were forcibly brought to our shores, Congress adopted the Thirteenth Amendment to the Constitution, which abolished “slavery” and “involuntary servitude, except as a punishment for crime.” (…) “Like all great historical transformation,” emancipation was a movement, “not a single event” owed to any single individual, institution or political party. (…) The fight for equal educational opportunity, however, was a key driver. Literacy was an “instrument of resistance and liberation.” (…) Education “provided the means to write a pass to freedom” and “to learn of abolitionist activities.” (…) It allowed enslaved Black people “to disturb the power relations between master and slave,” which “fused their desire for literacy with their desire for freedom.” (…) Put simply, “the very feeling of inferiority which slavery forced upon Black people fathered an intense desire to rise out of their condition by means of education.” (…) Racially integrated schools improve cross-racial understanding, “break down racial stereotypes,” and ensure that students obtain the “skills needed in today’s increasingly global marketplace…through exposure to widely diverse people, culture, ideas and viewpoints.” (…) More broadly, inclusive institutions that are “visibly open to talented and qualified individuals of every race and ethnicity” instill public confidence in the “legitimacy” and “integrity” of those institutions and the diverse set of graduates they cultivate. That is particularly true in the context of higher education, where colleges and universities play a critical role in “maintaining the fabric of society” and serve as “the training ground for a larger number of our Nation’s leaders.” (…) It is thus an objective of the highest order, a “compelling interest” indeed, that universities pursue the benefits of racial diversity and ensure that the “diffusion of knowledge and opportunity” is available to students of all races. This compelling interest in student body diversity is grounded not only in the Court’s equal protection jurisprudence but also in principles of “academic freedom,” which “long have been viewed as a special concern of the First Amendment.” In light of the “important purpose of public education and the expansive freedoms of speech and thought associated with the university environment,” this Court’s precedents recognize the imperative nature of diverse student bodies on American college campuses. Consistent with the First Amendment, student body diversity allows universities to promote “the robust exchange of ideas which discovers truth out of a multitude of tongues rather than through any kind of authoritative selection.” Indeed, as the Court recently reaffirmed in another school case, “learning how to tolerate diverse expressive activities has always been ‘part of learning how live in a pluralistic society’” MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 7

19. REQUEST FOR RECORDS 09/05/2023 under our constitutional tradition. (…) In short, for more than four decades, it has been this Court’s settled law that the Equal Protection Clause of the Fourteenth Amendment authorizes a limited use of race in college admissions in service of the educational benefits that flow from a diverse student body. From Brown to Fisher, this Court’s cases have sought to equalize educational opportunity in a society structured by racial segregation and to advance the Fourteenth Amendment’s vision of an America where racially integrated schools guarantee students of all races the equal protection of the laws. Today, the Court concludes that indifference to race is the only constitutionally permissible means to achieve racial equality in college admissions. That interpretations of the Fourteenth Amendment is not only contrary of precedent and the entire teaching of our history, (…) but is also grounded in the illusion that racial inequality was a problem of a different generation. Entrenched racial inequality remains a reality today. That is true for society writ large and, more specifically, for Harvard and the University of North Carolina (UNC), two institutions with a long history of racial exclusion. Ignoring race will not equalize a society that is racially unequal. What was true in the 1860s, and again in 1954, is true today: Equality requires acknowledgment of inequality. (…) These opportunity gaps “result in fewer students from underrepresented backgrounds even applying to” college, particularly elite universities. (…) “Because talent lives everywhere, but opportunity does not, there are undoubtedly talented students with great academic potential who have simply not had the opportunity to attain the traditional indicia of merit that provide a competitive edge in the admission process.” (…) Put simply, society remains “inherently unequal.” (…) Racial inequality runs deep to this very day. That is particularly true in education, the “’most vital civic institution for the preservation of a democratic system of government.’” Plyler v Doe. (…) As I have explained before, only with eyes open to this reality can the Court “carry out the guarantee of equal protection.” Both UNC and Harvard have sordid legacies of racial exclusion. Because “context matters” when reviewing race-conscious college admissions programs, (…) this reality informs the exigency of respondents’ current admissions policies and their racial diversity goals. For much of its history, UNC was a bastion of white supremacy. Its leadership included “slaveholders, the leaders of the Ku Klux Klan, the central figures in the white supremacy campaigns of 1898 and 1900, and many of the State’s most ardent defenders of the Jim Crow and race-based Social Darwinism in the twentieth century.” (…) The university excluded all people of color from its faculty and student body, glorified the institution of slavery, enforced its own Jim Crow regulations, and punished any dissent from racial orthodoxy. (…) It resisted racial integration after this Court’s decision in Brown, and was forced to integrate by court order in 1955. (…) It took almost 10 more years for the first Black woman to enroll at the university in 1963. (…) Even then, the university admitted only a handful of underrepresented racial minorities, and those students suffered constant harassment, humiliation, and isolation. (…) UNC officials openly resisted racial integration well into the 1980s, years after the youngest Member of this Court was born. During that period, Black students faced racial epithets and MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 8

20. REQUEST FOR RECORDS 09/05/2023 stereotypes, received hate mail, and encouraged Ku Klux Klan rallies on campus. (…) To this day, UNC’s deep-seated legacy of racial subjugation continues to manifest itself in student life. Buildings on campus still bear the names of members of the Ku Klux Klan and other white supremacist leaders. Students of color also continue to experience racial harassment, isolation and tokenism. Plus, the student body remains predominantly white: approximately 72% of UNC students identify as white, while only 8% identify as Black. These numbers do not reflect the diversity of the State, particularly Black North Carolinians, who make up 22% of the population. (…) UNC is not alone. Harvard, like other Ivy League universities in our country, “stood beside church and state as the third pillar of a civilization built on bondage.” (…) From Harvard’s founding, slavery and racial subordination were integral parts of the institution’s funding, intellectual production, and campus life. Harvard and its donors had extensive financial ties to, and profited from, the slave trade, the labor of enslaved people, and slavery-related investments. (…) Harvard’s leadership and prominent professors openly promoted “’race science,’” racist eugenics, and other theories rooted in racial hierarchy. Activities to advance these theories “took place on campus,” including “intrusive physical examinations” and “photographing of unclothed” students. The university also “prized the admission of academically able Anglo- Saxon students from elite backgrounds –including wealthy white sons of the South.” By contrast, an average of three Black students enrolled at Harvard each year during the five decades between 1890 and 1940. (…) Those Black students who managed to enroll at Harvard “excelled academically, earning equal or better academic records than most white students,” but faced the challenges of the deeply rooted legacy of slavery and racism on campus. (…) Meanwhile, a few women of color attended Radcliffe College, a separate and overwhelmingly white “women’s annex” where racial minorities were denied campus housing and scholarships. (…) Women of color at Radcliffe were taught by Harvard professors, but “women did not receive Harvard degrees until 1963.” (…) Today, benefactors with ties to slavery and white supremacy continue to be memorialized across campus through “statues, buildings, professorships, student houses, and the like.” (…) Black and Latino applicants account for only 20% of domestic applicants to Harvard each year. “Even though those students of color who beat the odds and earn an offer of admission” continue to experience isolation and alienation on campus. (…) For example, Harvard has reported that “far too many Black students at Harvard experience feelings of isolation and marginalization,” (…) and that “student survey data showed that only half of Harvard undergraduates believe that the housing system fosters exchanges between students of different backgrounds.” (…) These may be uncomfortable truths to some, but they are truths nonetheless. “Institutions can and do change,” however, as societal and legal changes force them “to live up to their highest ideals.” (…) The majority’s true objection appears to be that a limited use of race in college admission does, in fact, achieve what it is designed to achieve: It helps equalize opportunity and advances respondents’ objective by increasing the number of underrepresented racial minorities on college campuses, particularly Black and Latino students. This is unacceptable, the Court says, because racial groups that are not underrepresented “would be admitted in greater numbers” without these policies. (…) Reduced to its simplest terms, the Court’s conclusion is MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 9

21. REQUEST FOR RECORDS 09/05/2023 that an increase in the representation of racial minorities at institutions of higher learning that were historically reserved for white Americans is an unfair and repugnant outcome that offends the Equal Protection Clause. It provides a license to discriminate against white Americans, the Court says, which requires the courts and state actors to “pick the rights races to benefit.” Nothing in the Fourteenth Amendment or its history supports the Court’s shocking proposition, which echoes arguments made by opponents of Reconstruction era laws and this Court’s decision in Brown. (…) In a society where opportunity is dispensed along racial lines, racial equality cannot be achieved without making room for underrepresented groups that for far too long were denied admission through the force of law, including at Harvard and UNC. (…) By singling out race, the Court imposes a special burden on racial minorities for whom race is a crucial component of their identity. Holistic admission requires “truly individualized consideration” of the whole person. (…) Yet, “by foreclosing racial considerations, colorblindness denies those who racially self-identify the full expression of their identity” and treats “racial identity as inferior” among all “other forms of social identity.” (…) In a single paragraph at the end of its lengthy opinion, the Court suggests that “nothing” in today’s opinion prohibits universities from considering a student’s essay that explains “how race affected that student’s life.” (…) This supposed recognition that universities can, in some situations, consider race in application essays is nothing but an attempt to put lipstick on a pig. The Court’s opinion circumscribes universities ability to consider race in any form by meticulously gutting respondents’ asserted diversity interests. (…) Yet, because the Court cannot escape the inevitable truth that race matters in students’ lives, it announces false promise to save face and appear attuned to reality. No one is fooled. (…) In the end, the Court merely imposes its preferred college application format on the Nation, not acting as a court of law applying precedent but taking on the role of college administrators to decide what is better for society. The Court’s course reflects its inability to recognize that racial identity informs students viewpoints and experiences in unique ways. The Courts goes as far as to claim that Bakke’s recognition that Black Americans can offer different perspectives than white people amounts to a “stereotype.” (…) It is not a stereotype to acknowledge the basic truth that young people’s experiences are shaded by a societal structure where race matters. Justice Sonya Sotomayor Dissenting in the Matter of Students for Fair Admissions, Inc., v President and Fellows of Harvard College and University of North Carolina. https://www.supremecourt.gov/opinions/22pdf/20-1199_hgdj.pdf iv According to the January 30th 2018 report published by the National Council on Disability (NCD), [1] “affirmative and effective consent” is being taught to college/university students of the United States of America (U.S.A) during the course of their Freshmen Year; [2] college/university students are informed about “healthy sexual relationships” during the course of their 1st (first) year of post-secondary academic education; [3] 20% (twenty percent) of women were sexually assaulted in a college/university setting by the time they reached their Senior year in Calendar Year 2005; [4] 32% (thirty two) percent of women with a disability were sexually assaulted during Calendar Years 2014 and 2015 in a college/university setting; [5] sexual assault is a “public health and public safety concern with far reaching implications;” [6] sexual assault is a “deeply personal violation,” which leaves “physical and emotional impacts that change the lives of victims;” [7] sexual assault causes “long term physical, psychological, MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 10

22. REQUEST FOR RECORDS 09/05/2023 and emotional effects, including depression, post-traumatic stress, thoughts of suicide, flashbacks, and sleep disorders.” About “Affirmative and Effective Consent” on U.S College Campuses. Michael A. Ayele (a.k.a) W. Association for the Advancement of Civil Liberties (AACL).: https://michaelayeleaacl.wordpress.com/2022/11/02/affirmative-and-effective- consent-in-healthy-sexual-relationships-on-college-campuses-index/ vBrock Turner wrote: “Before this happened, I never had any trouble with law enforcement and I plan on maintaining that.” On November 15th 2014, three months before my assault, Deputy Shaw spotted a few young men walking through Stanford campus with beer cans. When apprehended, they ran. One guy was caught and detained, confessed the guy who escaped was Brock Turner. He was summoned back. The police noted: He returned wearing a bright orange tuxedo and Deputy Shaw smelled the odor of alcohol on him…He had a black backpack on with Coors Lights beers inside, as well as a beer and knew he was not supposed to have it because he was not 21 years old. He stated that when he saw Deputy Shaw approach, he made the decision to run. While running, he heard the verbal commands to stop, but continued evading. He said it was a split-second decision and he regretted making it. Deputy Shaw would be the one to photography my body three after this incident. Six months after my assault, two young women found Detective Kim and reported they’d encountered Brock at the Kappa Alpha (KA) fraternity the weekend before I was assaulted. The police report noted: He put his hat on her and she took it off. He then started to dance behind her and tried to turn her around to face him. She felt uncomfortable and tried to turn her body away so that he would not be directly “behind” her. He became really “touchy” and put his hands on her waist and stomach. He even put his hands on her upper thighs. She felt more exceedingly uncomfortable and got down off of the table. She said the Defendant “creeped” her out because of his persistence. Chapter 10. Chanel Miller: Know My Name. September 2014: Turner starts attending Stanford University on a swimming scholarship. November 15th 2014: Turner and several teammates are chased by police after officers see the group walking on campus drinking beer. The group had been on its way to a football game when they scattered after an officer shouted for them to stop. Two officers chase the teens through campus, finally catching one. The detained swimmer calls Turner and told him to return and talk with police. Turner, who was wearing an orange tuxedo, returns and apologizes for running away. He receives and ticked for being a minor in possession of alcohol. (…) January 10th 2015: Turner attends a party at Kappa Alpha fraternity house. A female Stanford student who lived in Turner’s dorm building introduces a friend to him. The friend later tells police Turner “creeped her out” and was “grabby” with her because he was placing his hands on her waist, stomach and thigh while they were dance. The friend says she didn’t invite Turner to dance with her nor did she seek his physical attention. She tells police she left the dance floor to get away from Turner. Timeline of significant dates in the life of Brock Turner. Associated MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 11

23. REQUEST FOR RECORDS 09/05/2023 Press.: https://apnews.com/general-news-962a8de554994637afce94a22afb78e9 viI clicked back to the news of my homepage, saw Stanford athlete, saw raping, saw unconscious woman. I clicked again, my screen filled with two blue eyes and a neat row of teeth, freckles, red tie, black suit. I had never seen this man before. Brock Turner. I read he had been charged with five felony counts: rape of an intoxicated person, rape of an unconscious person, sexual penetration by a foreign object of an intoxicated woman, sexual penetration by a foreign object of an unconscious woman, assault with intent to commit rape. Too many words, jumbled together. Read it again, slower. I typed into Google, what is a foreign object. The panic was quiet and slow. It was defined as an object that intrudes where it should not be, as into a living body or machinery. Examples include: a speck of dust in the eye, splinter, wood chip, fishhook, glass. What intruded into me. The article mentioned the victim had been digitally penetrated. My mind went to digital cameras. I Googled that too. Digital, Latin root digitalis, from digitus “finger, toe.” He must have fingered her, me. Google finally sat me down and broke the news. (…) The news linked to a police report, I clicked, scrolling, looking for victim, victim, victim. I found the deputy’s carefully written notes. I found the female subject, later identified as VICTIM. I found her on the ground behind the dumpster. I found her wearing a black, skin tight dress. I found her dress had been pulled up to about her hips, and was gathered near her waist. Her entire buttocks were uncovered, and she was not wearing any underwear. I found her lower abdomen and pubic area was visible. I found her vagina and butt. I found her long hair was disheveled, knotted and completely covered in pine needles all throughout. I found her lying in a position with her feet and legs bent in a 45 – 90-degree angle (fetal position) and her arms were in front of her chest with her hands on the ground near her face. I found her dress stretched down over both shoulders, bra pulled out. I found it was only covering her right breast. I found the necklace wrapped all the way around her neck so that the pendant portion was now centered on her back. I found a pair of white with black polka-dot panties lying bunched up on the ground about 6 inches in front of VICTIM’s stomach. I found her silver iPhone on the ground behind her buttocks. There was a blue cell phone case that was approximately 4 inches away, separated from the iPhone. I found she was wearing brown boots that were still laced, with the laces tied in a bow. (…) So on that January morning in 2015, reading the story of the Stanford assault on the news was like being read a letter. Sorry to inform you, impersonal and flat. (…) It was about a sad and strange rape on a local campus, a body found stripped and disheveled. This time, it was my name. (…) Chapter 2. Chanel Miller: Know My Name. viiStanford swimmer denies alleged rape. I almost choked, felt I’d been slapped hard in the chest. This article had a trigger warning, this version more graphic, I brushed it aside, clicked the police report, eyes sliding back and forth. Throughout the night, Turner hooked up with a few girls. In the report, all the people he’d kissed were named girls, but because he’d assaulted me, I was never called girl, only victim. He stated that he kissed VICTIM while on the ground. He took off the VICTIM’s underwear andfingered her vagina. He also touched the VICTIM’s breasts. MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 12

24. REQUEST FOR RECORDS 09/05/2023 (…) Turner does not know the identity of VICTIM. He never got her name and was not able to really describe her. He stated that he probably would not be able to recognize victim if he saw her again. (…) He was having a good time with VICTIM and stated that she also seemed to enjoy the activity. Enjoy. I stared at this word, a little thing I did not recognize. (…) I called my DA, Hey! Did you see this? He said I liked it! How is that even possible? I can’t believe this; can you believe this? What is this? I was half laughing, incredulous. But she did not match my tone. I know, she said. I know. She sighed the way you do before you begin a sentence with unfortunately or regrettably. She explained that pleading not guilty was a predicted formality. This was to be expected. But I’m telling you now, I said, I didn’t enjoy it. I don’t know who he is. He doesn’t even know what I look like. Chapter 2. Chanel Miller: Know My Name. On Wednesday, a jury found former Stanford swimmer Brock Turner guilty of sexually assaulting an unconscious and intoxicated young woman outside a fraternity house. 20-year-old Turner was arrested Jan. 18, 2015, after two graduate students found him on top of an unmoving woman outside Kappa Alpha fraternity at approximately 1 a.m. Turner subsequently withdrew from Stanford and was charged with five felony counts, later reduced to three: assault with intent to commit rape of an intoxicated or unconscious person, sexual penetration of an intoxicated person and sexual penetration of an unconscious person. Turner has been convicted on all counts. Brock Turner found guilty on three felony counts. The Stanford Daily.: https://stanforddaily.com/2016/03/30/brock-turner-found-guilty-on-three-felony-counts/ A lawyer for Brock Turner, the former Stanford student convicted of sexually assaulting an unconscious woman, argued in court during an appeal hearing that his client was seeking “outercourse” with his victim. The attorney’s appeal of the high-profile case, which led to international outrage after Turner received a lenient sentence in 2016, advanced in a California court this week, with an unusual legal claim that experts said was shocking and hurtful to survivors of sexual violence. Turner was originally convicted of assault with intent to commit rape of an intoxicated woman and penetration of an unconscious person after passerby spotted him thrusting on top of a motionless woman outside of a fraternity house in 2015. But his lawyer Eric Multhaup argued in court Tuesday that his client was not attempting rape, but was seeking “outercourse,” which he said was sexual contact while clothed and a “version of safe sex.” The language and claims at the hearing, which came a month after voters recalled the judge who gave Turner six months in jail, stunned legal scholars and activists. (…) Numerous legal experts said they had never before heard the term “outercourse” used by defense attorneys in sexual assault cases, though some noted it was common for lawyers to argue that the accused had different intentions than charges suggested. (…) Anne Coughlin, a University of Virginia law professor (…) said that “outercourse,” as Multhaup appeared to be defining it, would still be a criminal act, adding that it was an “ugly play on words” that “seems to be an effort to undercut the terrible harm Turner caused to this woman.”Brock Turner sought ‘outercourse’ with victim, says lawyer for ex-Stanford student. The Guardian.: https://www.theguardian.com/us- news/2018/jul/25/brock-turner-stanford-swimmer-sexual-assault-outercourse MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 13

25. REQUEST FOR RECORDS 09/05/2023 viiiThe People of the State of California, Plaintiff, versus Brock Allen Turner, Defendant, Information No. B1577162. (…) We, the jury, find the defendant, Brock Allen Turner, guilty of a felony, a violation of California Penal Code section 220 (a)(1), assault with intent to commit a rape of an intoxicated or unconscious person. Dated March 30th 2016 by foreperson, Juror No. 5. (…) My DA requests that Brock be remanded. But the handcuffs never touch him, his attorney arguing he should remain out on bail. Chapter 8. Chanel Miller: Know My Name. ixYou said, During the trial I didn’t want to victimize her at all. That was just my attorney and his way of approaching the case. Your attorney is not your scapegoat, he represents you. Did your attorney say some incredulously infuriating, degrading things? Absolutely. He said you had an erection, because it was cold. I have no words. You said, you are in the process of establishing a program for high school and college students in which you speak about your experience to “speak out against the college campus drinking culture and the sexual promiscuity that goes along with that.” Speak out against campus drinking culture. That’s what we’re speaking out against? (…) Not awareness about campus sexual assault, or rape, or learning to recognize consent? (…) Drinking culture and the sexual promiscuity that goes along with that. Goes along with that, like a side effect, like fries on the side of your order. (…) You should never have done this to me. Secondly, you should have never made me fight so long to tell you, you should have never done this to me. But here we are. The damage is done, no one can undo it. (…) When I read the probation officer’s report, I was in disbelief, consumed by anger which eventually quieted down to profound sadness. My statements have been slimmed down to distortion and taken out of context. I fought hard during this trial and will not have the outcome minimized by a probation officer who attempted to evaluate my current state and my wishes in a fifteen-minute conversation, the majority of which was spent answering questions I had about the legal system. The context is also important. (…) I told the probation officer I do not want Brock to rot away in prison. I did not say he does not deserve to be behind bars. The probation officer’s recommendation of a year or less in county jail is a soft time-out, a mockery of the seriousness of his assaults, and of the consequence of the pain I have been forced to endure. I also told the probation officer that what I truly wanted was for Brock to get it, to understand and admit to his wrongdoing. Unfortunately, after reading the defendant’s statement, I am severely disappointed and feel that he has failed to exhibit sincere remorse or responsibility for his conduct. I fully respected his right to a trial, but even after twelve jurors unanimously convicted him of three felonies, all he has admitted to doing is ingesting alcohol. Someone who cannot take full accountability for his actions does not deserve a mitigating sentence. It is deeply offensive that he would try and dilute rape with a suggestion of promiscuity. By definition rape is the absence of promiscuity, rape is MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 14

26. REQUEST FOR RECORDS 09/05/2023 the absence of consent, and it perturbs me deeply that he can’t even see that distinction. The probation officer factored in that the defendant is youthful and has no prior convictions. In my opinion, he is old enough to know what he did was wrong. (…) The seriousness of rape has to be communicated clearly, we should not create a culture that suggests we learn that rape is wrong through trial and error. The consequences of sexual assault need to be severe enough that people feel enough fear to exercise good judgment even if they are drunk, severe enough to be preventative. The fact that Brock Turner was a star athlete at a prestigious university should not be seen as an entitlement to lenience, but as an opportunity to send a strong cultural message that sexual assault is against the law regardless of social class. The probation officer weighed the fact that he has surrendered a hard-earned swimming scholarship. If I had been sexually assaulted by an un-athletic guy from a community college, what would his sentence be? If a first-time offender from an underprivileged background was accused of three felonies and displayed no accountability for his actions other than drinking, what would his sentence be? How fast he swims does not lessen the impact of what happened to me. The probation officer has stated that this case, when compared to other crimes of similar nature, may be considered less serious due to the defendant’s level of intoxication. It felt serious. That’s all I’m going to say. He is a lifetime sex registrant. That doesn’t expire. Just like what he did to me doesn’t expire, doesn’t just go away after a set number of years. It stays with me, it’s part of my identity, it has forever changed the way I carry myself, the way I live the rest of my life. Excerpt of Chanel Miller June 02nd 2016 Victim Impact Statement. xThey tell you that if you’re assaulted, there’s a kingdom, a courthouse, high up on a mountain where justice can be found. Most victims are turned away at the base of the mountain, told they don’t have enough evidence to make the journey. Some victims sacrifice everything to make the climb, but are slain along the way, the burden of proof impossibly high. I set off, accompanied by a strong team, who helped carry the weight, until I made it, the summit, the place few victims reached, the promised land. We’d gotten an arrest, a guilty verdict, the small percentage that gets the conviction. It was time to see what justice looked like. We threw open the doors, and there was nothing. It took the breath out of me. Even worse was looking back down to the bottom of the mountain, where I imagined expectant victims looking up, waving, cheering, expectantly. What do you see? What does it feel like? What happens when you arrive? What could I tell them? A system does not exist for you. The pain of this process couldn’t be worth it. These crimes are not crimes but inconveniences. You can fight and fight for what? When you are assaulted, run and never look back. This was not one bad sentence. This was the best we could hope for. At the very start of the sentencing, the judge said that the question he had to ask himself was, Is incarceration in state prison the right answer for the poisoning of Chanel’s life? I thought it had been strange the way he’d phrased it. To him, my lost job, my damaged hometown, my small savings account, my stolen pleasures, had all amounted to ninety days in county jail. MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 15

27. REQUEST FOR RECORDS 09/05/2023 I wondered if, in their eyes, the victim remained stagnant, living forever in that twenty-minute time frame. She remained frozen, while Brock grew more and more multifaceted, his stories unfolding, a spectrum of life and memories opening up around him. He got to be a person. Where was her redemption story? Nobody talked about the things she might go on to do. I had laid my suffering bare, but I lacked a key element. The judge had given Brock something that would never be extended to me: empathy. My pain was never more valuable than his potential. There would be no transformation. Behind bars or not, the judge had set him free, let him return to the recesses of his mind where he could do no wrong. So what was the meaning of all this? What’s the objective, the end game? Not once was he forced to imagine the life of the human on the receiving end of his actions. If anything, the fight had cemented Brock inside his distortions, fortified his need to hold his ground. I wondered if I was waking up to a truth that I had been the last one to realize; you are worth three months. A smarter part of me knew this was not right, but I could not pretend to know better. At that moment there was nothing to do but give in. I accepted that this would be one of the most painful nights of my life. (…) I opened up by notebook. I stared at the empty page. Then I wrote, You are worth more than three months. Again. You are worth more than three months. My face crumpled, twisted my hand trying to outrun my mind. Listen to what your body is trying to tell you. You are worth more than three months. What are you going to do? I will draw, I will speak. You are worth more than three months. I am not a burden. I am not limited, I am ever expanding. Your suffering means something. You are worth more than three months. They could never truly have rejected me since they had never fully known me. You are worth more than three months. The assault was never all of me. I could feel myself fighting, driving the pen into the page. You are worth more than three months. My hand tensed, struggling, then softening. The light in my room was gray, I parted my blinds to peek through, outlines of trees and cars emerging. I put down my pen. Sleep. Chapter 9. Chanel Miller. Know My Name. xiBrock Turner three felonies added up to a maximum of fourteen years in prison. My DA recommended six years. She asked me to write a victim impact statement, two to three pages about how this experience affected me. If I wanted to read it aloud they’d buy me a ticket home. If I didn’t want to read it, my advocate could read it for me. I had to submit it by the end of May so the judge had ample time to look it over beforehand. (…) Through all my years of writing classes, teachers told us that if a topic felt too raw you put it aside for a later time. Create distance. But this deadline had been created for me. I had also never encountered an assignment like this, to write up a list of emotional damages. The prompt was depressing. Why should I document the ways I might be irreversibly ruined? I had a “Making a Victim Impact Statement” brochure that suggested questions: How do you feel when you wake up in the morning? How often do you cry? How much of each day do you feel sad? Have you thought about suicide? MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 16

28. REQUEST FOR RECORDS 09/05/2023 One afternoon, I received a call from an unknown number. I let it go to voice mail. In the message, a woman identified herself as an officer from the Probation Department. I had learned to be wary. I called my DA, asking if I was allowed to talk to this woman. My DA said the officer wanted my input about the upcoming sentencing and I should call her and tell her I was writing a statement I could share. I was surprised the officer called me. I was used to being voiceless, my opinion rarely requested. I assumed there were minimum sentences for each felony. I imagined this would be her nice way of letting me contribute my two cents and I expected my words to literally be worth pennies, wishful coins thrown into a fountain. I told the probation officer I was writing a statement. But she began asking me questions. (…) I told her I had survived a school shooting carried out by a man who never got the help he needed. I didn’t want Brock Turner to slip off the rails and punish more women, needed to be sure he was in therapy, taking classes in jail. So you want no more than a year, she said. I was confused. I had never said that. She explained that I had said “jail” and county jail has a one-year maximum. Prison has no maximum. Oh, I said. Well, do they offer classes in prison? I wondered why no one had explained this to me. Most importantly I wanted Brock to own up to what he had done. I asked if she had spoken to him and she said no, but she would be meeting with him the following week. I said it was hard for me to fully answer her without hearing what he had to say. You want him to get it, she said. She said she understood. The conversation had been brief. I told her I was working on a statement and I’d be more comfortable emailing it to her when I was done. But she said my oral statement had been fine, she’d jotted down a few notes, and that wouldn’t be necessary. You did great, she said. We both hung up. I felt a lingering discomfort. I wished somebody else had been there for the conversation. I told myself I was being paranoid, she would take care of things. Days later I received a call from my DA, her voice fraught. Can you tell me what you said to her? (…) She explained the probation officer had offered a lenient sentence, had said I only cared about treatment, not incarceration, suggesting Brock didn’t belong in prison. I wondered how I had finally been given a voice, but it had not been the one I wanted. Laws exist, I thought. How is it possible for me to blow it at this point? I told her I’d call the probation officer back, but my DA said it was too late, the report had been filed. She would send me the probation officer’s recommendation along with Brock’s statements so I could respond to them in my own statement. Distraught, I opened the report. The probation officer had given my input a single paragraph. She had taken my words but constructed her own sentences, shaving all context away. I just want him to get better, it said. She gave me a voice of forgiveness and submission, the agony neatly paved over. She’d reduced my suffering to the line, I don’t experience joy from this. She’d drawn her own conclusions: He doesn’t need to be behind bars. This woman, who had been absent for the entire battle, had arrived to take the victory away. For months I had been climbing out of this hole, my hands MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 17

29. REQUEST FOR RECORDS 09/05/2023 finally gripping the edge. Now I watched the dirt turn to mud beneath my fingers as I slipped down again. The officer noted she had been struck by the victim’s ability to objectively digest the gravity and ramifications of the defendant’s behavior. That word, digest. She had mistaken my strength for digestion. Perhaps she’d expected a hysterical victim, the weeping and scathing kind. She could not hear how my muscles had tensed, did not know the way Lucas found me laying mute on the couch after the call, exhausted from the resurgence of memories. As a woman, I’d tried asserting my opinion without coming off as self-serving or overcontrolling. So I repressed pissed-off victim. Now I wondered if I had handled it too gracefully, my composure a signal that what he’d done was of little consequence. When I’d advocated for him to take classes and be in therapy, she mistook it as a nurturing passivity, gentle absolution. What I meant was take note of his mental health, because in my experience, when men were upset, lonely, or neglected, women were killed. A moderate county jail sentence, formal probation, and sexual offender treatment is respectfully recommended. It sunk me. Moderate suggested his crime was of low quality, low intensity, tolerable. It was diminishing: This case, when compared to other crimes of similar nature, may be considered less serious due to the defendant’s level of intoxication. She had interviewed Brock, reported, the defendant expressed sincere remorse and empathy for the victim. I wondered if her suggestion had been light because Brock had finally taken responsibility. I opened that PDF: “I swear I never would have done any of this if she wasn’t willing… We were just in the heat of the moment. If at any time I thought she was not responding, I would have stopped immediately…I never meant to treat her like anything else than an exceptional person…During the trial I didn’t want to victimize her at all. That was just my attorney and his way of approaching the case…I have to sacrifice everything…things can go from fun to ruined in just one evening.” He explained he’d been working on a program where he speaks out against the college campus drinking culture and the sexual promiscuity that goes along with that. (…) There was another form filled out by the officer I had spoken to. Under victim’s race, she had checked white. Never in my life have I checked only white. You cannot note my whiteness without acknowledging I am equal parts Chinese. The single check mark was a testament to how little time she’d taken to know me, making the assumption I was white over the phone without bothering to ask. Chapter 9. Chanel Miller. Know My Name. xiiA 2001 Gallup poll that asked adults what they were afraid of reveals that more people – 51% -- fear snakes than any other suggested possibility, including speaking in front of an audience (40%) and heights (36%). And while children are reputed to fear the dark, only 5% of surveyed adults do. Just 11% of adults fear thunder and lightning. Snakes Top List of American’s Fears. Gallup.: https://news.gallup.com/poll/1891/snakes-top-list-americans- MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 18

30. REQUEST FOR RECORDS 09/05/2023 fears.aspx#:~:text=GALLUP%20NEWS%20SERVICE&text=A%20recent%20Gallup%20poll% 20that,%25)%20and%20heights%20(36%25). xiiiThe rape and murder of Jeanne Ann Clery continues to leave several key questions about Title IX of the Education Amendments Act of 1972 unaddressed. These questions include but are not limited to the following. 1) What are/were colleges/universities in the U.S.A obligations pursuant to Title IX of the Education Amendments Act of 1972? Were colleges/universities throughout the U.S.A required by law to denounce violence committed against women irrespective of their racial backgrounds, their sexual orientations, their religious affiliations, their disability status and their national origins following the enactment of Title IX of the Education Amendments Act of 1972? If yes, were colleges/universities required to inform their students what constitute appropriate sexual boundaries pursuant to Title IX of the Education Amendments Act of 1972? 2) Did colleges/universities throughout the U.S.A begin informing their students what constitute “affirmative and effective consent” following the enactment of Title IX of the Education Amendments Act of 1972? If not, when did colleges/universities begin to inform their incoming freshmen/transfer students about the concepts of “affirmative and effective consent?” Did colleges/universities throughout the U.S.A begin teaching the concepts of “affirmative and effective consent” to their incoming freshmen/transfer students following the rape and murder of Jeanne Ann Clery (dated April 05th 1986)? If yes, why have colleges/universities throughout the U.S.A fixated on the rape and murder of this Caucasian woman by a Black/African American man to inform their incoming freshmen/transfer students about what constitutes “affirmative and effective consent?” 3) Are colleges/universities discussions pertaining to what constitutes “affirmative and effective consent” consistent with Title IX of the Education Amendments Act of 1972 if they are first informing their incoming/freshmen students about the rape and murder of Jeanne Ann Clery? Are colleges/universities discussions pertaining to what constitutes “affirmative and effective consent” consistent with their academic integrity policy if they are first informing their incoming freshmen/transfer students about the rape and murder of Jeanne Ann Clery? 4) Were there forces out there in the 1970s and the 1980s looking for a case where a Black/African American man rapes and murders a Caucasian woman for the purpose of enacting a law similar to the Jeanne Clery Act? Was the enactment of the Jeanne Clery Act the result of racist and sexist individuals coming together for the purpose of [a] preventing racial minorities from climbing the social ladder through academic education; [b] cracking down on interracial relationships particularly between a Caucasian woman and a Black/African American man; [c] not applying the same standards in circumstances where a Caucasian man sexually assaults a woman from a racial minority (as in the case of Brock Turner and Chanel Miller following her rape on January 18th 2015 at the campus of Stanford University)? Approximately 5 (Five) Months After the April 05th 1986 Rape and Murder of Jeanne Ann Clery: August 29th 1986 at Westminster College (Fulton, Missouri). Federal Bureau of Investigation (FBI) Actions on June 11th 1992 on the Case of Jeanne Ann Clery. Michael A. Ayele (a.k.a) W. Association for the Advancement of Civil Liberties (AACL).: https://michaelayeleaacl.wordpress.com/2021/12/10/jeanne-ann-clery-case-updated-june-11th- 1992-index/ MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 19

31. REQUEST FOR RECORDS 09/05/2023 xivIt is regrettable that the consequences for sexually assaulting a woman of color (Chanel Miller) ended up equating for Brock Turner the maximum sentence he would have served in the State of Maryland had he been arrested and charged for the petty offense of Trespass: 90 days. About Chanel Miller and the San Francisco Public Library (SFPL). Michael Ayele (a.k.a) W May 20th 2016. Habeas Corpus. Scribd.: https://www.scribd.com/document/534418446/About- Chanel-Miller-the-San-Francisco-Public-Library-SFPL-Michael-Ayele-a-k-a-W-May-20th- 2016-Habeas-Corpus# xvOn a Friday night in college, graduation a few weeks away, I was walking to a friend’s house when two police cars tore past me. I thought nothing of it. It was common to hear sirens in Isla Vista: it was a town on the ocean bluffs inhabited solely by eighteen to twenty-two-year-olds, every street lined with shabby wooden houses, bikes abandoned on lawns, overcrowded balconies, orchids growing out of recycled Franzia boxes. On sunny days you’d see beautiful girls in swimsuits holding large rafts over their heads, like ants beneath a crumb, walking down the street to the water. Guys biked with surfboards tucked under one arm, their wetsuits peeled halfway off like a banana. Isla Vista was a network of couches to sleep on, a friend a block away in any direction. A wild, sunny village we called home. But by the time I reached her apartment, the sirens had stacked, blossomed, erupted. When I walked in the door, all five of my friends were quiet, listening. We received an email from UCSB Emergency: Shots fired in IV 2 detained, investigation ongoing, That was it. A single line that dropped off with a comma. Texts began circulating; maybe it was gang related, a robbery, a drug deal gone wrong, a drive-by, no a shootout, a bomb, firecrackers, drunk driver. He was Persian, no Asian? It was two guys, one guy, in a car, a black one. Someone may have died, one person, possibly three, maybe none and this was all a sick prank. There was a video going around, someone said it was a guy, the guy, so we huddled around the phone, and there he was, sitting in the driver’s seat, face saturated in orange from the setting sun. Hi, Elliot Rodger here…I don’t know why you girls aren’t attracted to me but I will punish you all for it. I’ll take to the streets of Isla Vista and slay every single person I see there… I will take great pleasure in slaughtering all of you… Panic erupted, one of us screamed to turn it off, one was convulsively crying on the floor, jerking as if her stomach were being yanked by a string. He was still speaking, contaminating our air. I shook my head, refusing to hear it. He is coming to Isla Vista to kill girls, we are girls in Isla Vista, but we can’t be who he is talking about. You denied me a happy life and in turn I will deny all of you life, it’s only fair. I hate all of you. We denied you a happy life? Hate fucking who? I was livid. I grabbed the phone, walked out of the room, set it on the bathroom counter, and walked out, firmly closing the bathroom door behind me. I felt I had trapped him in there, the video still playing, him speaking into the darkness to no one. MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 20

32. REQUEST FOR RECORDS 09/05/2023 The next email told us to remain indoors. We bolted the locks, closed the blinds, got away from the window. Our phones kept chiming. Claire’s housemate had been shot. Nothing pieced together. At three in the morning, we stared at the news on TV, heard mass murder. The word seven was displayed in tall, white letters at the bottom of the screen. It seemed wrong to group the dead. It was not seven; it was one and one and one and one and one and one and one. Each an entire life, each with a name. The morning light never came, the air unmoving and still. On days like these, the fog slipped in from the ocean, erasing the water, the shore, engulfing our little houses. We blinked, exhausted, wondering if it was safe to leave. We kneeled on the couches and carefully parted the blinds. (…) Rumors circulated there’d be copycat crimes, some men glorifying ElliotRodger’s actions, hailing him as their leader, the supreme gentleman. (…) When we finally stepped outside, it was eerily quiet. On the street people traveled in tight groups, divided into herds and packs. The atmosphere was hushed, no one strolling, longboarding, no thumping music leaking from houses. The press conference was scheduled for 4:00 P.M. Before it began, we separated to privately unravel in our showers, to put on clean clothes. We regrouped inside the apartment, our safe house, refusing to be alone. Elliot Rodger had lived in a brown apartment building, a block away from Sweet Alley, where I’d frequently buy bags of sour watermelon candies for long nights at the library. On Friday evening, he killed three people in the apartment, two Chinese roommates and their visiting friend; 142 stab wounds in total, bloodstains in the hallway, bodies dragged and covered in towels. He carried his knives and handguns into his black BMW, drove to the Alpha Phi sorority house, knocking hard on the door. When no one answered, he shot three women outside, two bled to death in the grass. He sped off, fired through the glass window of Isla Vista Deli, one male slid to the floor dead inside. He crashed his car on Del Playa, the main street, the nose of his car crunching in, before pressing his gun to his temple. Police found him with his head blown out, blood painting the curb. The ambulances were backlogged, students kneeled beside bleeding students. Bullet casings littered the street alongside sprinkled glass, large shards of window. The police found 548 rounds of unspent ammunition inside his car that he never had time to use. Six classmates had been stolen from us, Elliot Rodger the seventh. I do not include the victims’ names here, for names are sacred, and I do not want them identified solely by what he did to them. (…) I never forgot one of the opening lines of Elliot Rodger’s 137-page manifesto: This is a story of how, I, Elliot Rodger, came to be…This tragedy did not have to happen… but humanity forced my hand. His cruelty had a narrative arc. He spoke like he had never wanted to do what he did, he was pushed to. And it was women who had made him suffer, who left him no choice but to execute his Day of Retribution. In his video, he’d said, I’ve been forced to endure an existence of loneliness, rejection and unfulfilled desires all because girls have never been attracted to me. His hostility was born of entitlement, self-pity. I will punish all females for the crime of depriving me of sex. In Elliot’s world, the unspoken law MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 21

33. REQUEST FOR RECORDS 09/05/2023 was that women owed him sex, we existed only to receive him. Those were the rules, that was our purpose. Sex was his right and our responsibility. The punishment in his world for breaking his laws, for rejecting sex, was death. (…) College is the time when everyone experiences those things such as sex and fun and pleasure, Elliot Rodger said. In those years I’ve had to rot in loneliness, it’s not fair…You forced me to suffer all my life, now I will make you all suffer. Chapter 4. Chanel Miller. Know My Name. xviGov. Jerry Brown on Friday signed legislation that expands the legal definition of rape and imposes new mandatory minimum sentences on sexual assault offenders – measures inspired amid national outcry over the sexual assault case of former Stanford swimmer Brock Turner. The decision comes as heated debate raged this year over the mishandling of sexual assault investigations on U.S college campuses by police agencies and courts. But increasing punishment for sex offenders posed a challenge for Brown, as the state has been undertaking a broader effort to move away from a focus on prison sentences. (…) Assembly Bill 2888, authored by Assemblyman Evan Low (D-Campbell) and Assemblyman Bill Dodd (D-Napa), will prohibit judges from giving convicted offenders probation when they sexually assault someone who is unconscious or intoxicated. Assembly Bill 701 by Assemblywomen Cristina Garcia (D-Bell Gardens) and Susan Talamentes Eggman (D-Stockton), will expand the legal definition of rape so it includes all forms of nonconsensual sexual assault. (…) Rape has previously been defined as “an act of sexual intercourse” under certain conditions of force, duress or lack of consent. Other types of sexual assault, like penetration by a foreign object, were categorized as separate offenses. California expands punishment for rape after Brown signs bills inspired by Brock Turner case. Los Angeles Times.: https://www.latimes.com/politics/essential/la-pol-sac-essential-politics-updates-california- expands-punishment-for-rape-1475260488-htmlstory.html MICHAEL A. AYELE (A.K.A) W – ASSOCIATION FOR THE ADVANCEMENT OF CIVIL LIBERTIES (AACL) 22

34. EXHIBIT 1.

35. 12/3/23, 6:46 AM Gmail - Public Records Act Request Michael Ayele <waacl13@gmail.com> Public Records Act Request Williams, Mona <mona.williams@cco.sccgov.org> To: "waacl13@gmail.com" <waacl13@gmail.com>, "waacl1313@gmail.com" <waacl1313@gmail.com>, "waacl42913@gmail.com" <waacl42913@gmail.com> Mon, Sep 18, 2023 at 7:44 PM Dear Mr. Ayele (W), The County of Santa Clara (“County”) has designated the Office of the County Counsel as the office responsible for receiving and coordinating public record requests, and as such, I am providing an initial response to your September 7, 2023, California Public Records Act (“CPRA”) request, which is attached. Pursuant to California Government Code section 7922.535(b) and (c)(1), the County extends its time for responding to your request by an additional 14 days to search for and collect requested records from offices other than the Office of the County Counsel. The County will provide a response to your request by Monday, October 2, 2023. Thank you, Mona Mabengi Williams | Deputy County Counsel Office of the County Counsel, County of Santa Clara 70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110 Office: (408) 299-5922 | Mobile: (669) 235-1956 mona.williams@cco.sccgov.org | counsel.sccgov.org NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system. Records Request on Brock Turner Sept 2016 College Speaking Tour After 90 Days in County Jail for Sexual Assault of Chanel Miller.pdf 1968K https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1777394507752700387&simpl=msg-f:1777394507752700387 1/1

36. 12/3/23, 6:48 AM Gmail - Public Records Act Request Michael Ayele <waacl13@gmail.com> Public Records Act Request Williams, Mona <mona.williams@cco.sccgov.org> To: "waacl13@gmail.com" <waacl13@gmail.com>, "waacl1313@gmail.com" <waacl1313@gmail.com>, "waacl42913@gmail.com" <waacl42913@gmail.com> Mon, Oct 2, 2023 at 7:18 PM Dear Mr. Ayele (W), Attached please find the County’s production in response to your September 7, 2023, CPRA request, which is attached. Please note that the County redacted information that is not subject to disclosure in response to a CPRA request; information for which the public interest in not disclosing the information clearly outweighs the public interest in disclosure; and other information that is non-responsive to your request or constitutes the private personal information of third parties. (See Gov. Code, § 7922.000; Evid. Code, § 1040; Cal. Const., art. 1, § 1.) This production completes the County’s response to your request under the CPRA; the County will be closing out your request. Kind regards, Mona Mabengi Williams | Lead Deputy County Counsel Office of the County Counsel, County of Santa Clara 70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110 Office: (408) 299-5922 | Mobile: (669) 235-1956 Pronouns: she/her/hers mona.williams@cco.sccgov.org | counsel.sccgov.org NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system. From: Williams, Mona Sent: Monday, September 18, 2023 9:45 AM To: waacl13@gmail.com; waacl1313@gmail.com; waacl42913@gmail.com Subject: Public Records Act Request Dear Mr. Ayele (W), https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1778661207308023564&simpl=msg-f:1778661207308023564 1/2

37. 12/3/23, 6:48 AM The County of Santa Clara (“County”) has designated the Office of the County Counsel as the office responsible for receiving and coordinating public record requests, and as such, I am providing an initial response to your September 7, 2023, California Public Records Act (“CPRA”) request, which is attached. Pursuant to California Government Code section 7922.535(b) and (c)(1), the County extends its time for responding to your request by an additional 14 days to search for and collect requested records from offices other than the Office of the County Counsel. Gmail - Public Records Act Request The County will provide a response to your request by Monday, October 2, 2023. Thank you, Mona Mabengi Williams | Deputy County Counsel Office of the County Counsel, County of Santa Clara 70 West Hedding Street, East Wing, 9th Floor | San José, CA 95110 Office: (408) 299-5922 | Mobile: (669) 235-1956 mona.williams@cco.sccgov.org | counsel.sccgov.org NOTICE TO RECIPIENT: The information in this email is confidential and may be protected by the attorney-client and/or work product privileges. If you received this email in error, any review, use, dissemination, distribution, or copying of it is strictly prohibited. Please notify Administration, Office of the County Counsel, of the error immediately at 408-299-5900 and delete this communication and any attached documents from your system. 2 attachments 9.7.2023_Brock-Turner.pdf 1930K B.Turner_Report of Probation_redacted.pdf 6882K https://mail.google.com/mail/u/0/?ik=be10e4fd3f&view=pt&search=all&permmsgid=msg-f:1778661207308023564&simpl=msg-f:1778661207308023564 2/2