Watsonville, California References to Rosa Parks in March 2021 - #Michael A. Ayele (a.k.a) W April 2023

14. PUBLIC RECORDS ACT (PRA) REQUEST CASE NO.: 23 - 97 04/13/2023 W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia E-mail: waacl13@gmail.com ; waacl1313@gmail.com ; waacl42913@gmail.com Public Records Act (PRA) Request Case No.: 23 - 97 Hello, I am writing this letter in response to your earlier correspondence, wherein you disclosed certain records about the decision of the City of Watsonville (California) to commemorate Sexual Assault Awareness Month (SAAM) in 2010 and 2007. Please be advised that I have concerns with your processing for my Public Records Act (PRA) request, which you have assigned Case No.: 23 – 97 because of your processing of my PRA request that had been assigned 23 – 76. When disclosing certain records about the decision of the City of Watsonville to commemorate the month of March 2021 as “Women’s History Month,” your local government (for the purpose of PRA Request Case No.: 23 –76) implied that it had “reflected on the often-over-looked achievements of women such as Susan B. Anthony, Rosa Parks, Abigail Adams and Sojourner Truth among countless others.” (Please see the March 2021 proclamation signed by the City of Watsonville Mayor Jimmy Datra, which has been hereby attached for your review). As a representative of the media and a member of the general public, I would like to take this opportunity to remind you that the National Sexual Violence Resource Center (NSVRC) has identified Rosa Parks as a Black woman, who “worked at the intersection of race-based and gender-based violence.” Please see here.: https://www.nsvrc.org/saam/history Because of the statements made by the NSVRC (in 2023) and the statements made by your local government (in March 2021) on the occasion of Women’s History Month, I would again like reiterate the concerns I have about the thoroughness of the search you have performed for my PRA Request you have assigned Case No.: 23 – 76. For instance, your correspondence from April 13th2023 doesn’t address how your local government views Rosa Parks and the work she has done to end the sexual violence that is committed against women even though your local government had in March 2021 stated that it would reflect “on the often-over-looked achievements of women such as Susan B. Anthony, Rosa Parks, Abigail Adams and Sojourner Truth among countless others.” For the purpose of bolstering public confidence in the activities and engagements of the City of Watsonville (particularly given the statements you have made in March 2021), I hope you will perform a more thorough search for responsive records detailing [1] your discussions about Rosa Parks as a Black woman, who “worked at the intersection of race-based and gender-based violence;” [2] your discussions about the decision of Watsonville Mayor Jimmy Datra to direct your local government to “reflect on the over-looked achievements of Rosa Parks;” [3] the formal/informal opinion of the City of Watsonville about Rosa Parks as a Black woman, who worked to put an end on the sexual violence that is committed against women. Date.: April 13th 2023 MICHAEL A. AYELE (A.K.A) W 1

15. PUBLIC RECORDS ACT (PRA) REQUEST CASE NO.: 23 - 97 04/13/2023 I hope you reconsider your response. Be well. Take care. Keep yourselves at arms distance. Michael A. Ayele (a.k.a) W Anti-Racist Human Rights Activist Audio-Visual Media Analyst Anti-Propaganda Journalist MICHAEL A. AYELE (A.K.A) W 2

16. r o c l a m a t i o n r o c l a m a t i o n Women’s History Month March 2021 Women’s History Month is observed annually each March, in celebration of their contributions to history, culture and society; and P WHEREAS, WHEREAS, this month is dedicated to reflecting on the often over-looked achievements of women such as Susan B. Anthony, Rosa Parks, Abigail Adams and Sojourner Truth, among countless others; and women today continue to play a critical role in the world, and in creating a brighter future for generations to come; and WHEREAS, WHEREAS, on this occasion Watsonville recognizes a group of these women, the Alpha Theta Chapter of the Omega Nu Sorority, which was chartered on May 14, 1935; and WHEREAS, each year, Alpha Theta raises funds to give out in the form of scholarships to young women at local high schools to support them in furthering their education; and WHEREAS, Alpha Theta has donated to several organizations, such as Pajaro Valley Shelter Services, Monarch Services, YMCA, Jacob’s Heart and FoodWhat? among various others; and WHEREAS, they also collaborate with Watsonville Police Department to maintain their ‘soft room,’ a safe space where victims who are minors can be interviewed in a more comfortable environment; and WHEREAS, Alpha Theta works with the Santa Cruz County Sheriff’s Office to fund all the equipment and supplies for the SART room at Dominican Hospital, where victims of sexual abuse go for their forensic examination; and WHEREAS, Alpha Theta and Monarch Services’ victim advocates strive to ensure the process is conducted in the utmost supportive, private and respectful manner; and WHEREAS, we are proud to have these and many other extraordinary women as part of our community, and as role models for the younger generations. NOW, THEREFORE, I, Jimmy Dutra, Mayor of the City of Watsonville, in the State of California, on behalf of the City Council hereby recognize March 2021 as Women’s History Month and encourage all citizens to reflect on the generations of women that have made an impact in our history, as well as those who continue making an impact today. IN WITNESS WHEREOF, I have hereunto set my hand and caused the Seal of the City of Watsonville to be affixed this 9th day of March, Two thousand and twenty. _____________________ Jimmy Dutra, Mayor W A T S O N V I L L E , C A L I F O R N I A

17. r o c l a m a t i o n r o c l a m a t i o n Sexual Assault Awareness Month March 11, 2010 sexual assault affects women, children and men of all racial, cultural and economic backgrounds; and P WHEREAS, WHEREAS, in addition to the immediate physical and emotional costs, sexual assault may also have associated consequences of post-traumatic stress disorder, substance abuse, depression, homelessness, eating disorders and suicide; and WHEREAS, sexual assault can be devastating for not only the survivor, but also for the family and friends of the survivor; and WHEREAS, no one person, organization, agency or community can eliminate sexual assault on their own, but we can work together to educate our entire population about what can be done to prevent sexual assault, support victim/ survivors and their significant others, and increase support for agencies providing services to victim/ survivors; and WHEREAS, Sexual Assault Awareness Month provides an excellent opportunity for citizens to learn more about preventing sexual violence; NOW, THEREFORE, I, Luis A. Alejo,Mayor of the City of Watsonville, do hereby proclaim the month of April 2010, as “Sexual Assault Awareness Month”in the City of Watsonvilleand call upon the people of Watsonville to join their fellow citizens across the United States in recognizing and participating in this special observance. IN WITNESS WHEREOF, I have hereunto set my hand and caused the Seal of the City of Watsonville to be affixed this 11th day of March, two thousand and ten. _____________________________ Luis A. Alejo, Mayor W A T S O N V I L L E , C A L I F O R N I A

18. P r o c l a m a t i o r o c l a m a t i o n n Child Abuse Prevention & National Sexual Assault Awareness Month April 2007 WHEREAS, child sexual abuse is a silent epidemic throughout the United States and the world, creating social havoc for children, adult survivors, and society; and WHEREAS, approximately one out of every three girls and one out of every six boys are sexually abused by the age of 18 (U.S. Department of Health and Human Services, 1993); and WHEREAS, decades of research consistently document that adults who were sexually violated as children are negatively impacted as a consequence of the abuse and suffer from depression, anxiety, self- mutilation, low self esteem, eating disorders, interpersonal difficulties, post traumatic stress disorder, and dissociative identity disorder; and WHEREAS, all children deserve the nurturing support of loving adults and have the right be free from harm and to have their physical, emotional, and educational needs met; and WHEREAS, Survivors Healing Center (SHC), a California non-profit organization, has been serving Santa Cruz County since 1987, and they provide education, information, referrals, quality services, and support to survivors of childhood sexual abuse and their allies and their primary goals are to empower those victimized by sexual abuse through a healing process and to prevent abuse of children and youth; and WHEREAS, child abuse prevention requires partnerships among Federal, State, and local governments, faith- based and community-based organizations, schools, law enforcement, and social service agencies; and WHEREAS, all of these organizations must work together with parents to protect children and help build healthy families and communities; NOW, THEREFORE, I, Manuel Quintero Bersamin,Mayor of the City of Watsonville, do hereby proclaim, April as “Child Abuse Prevention & National Sexual Awareness” month in the City of Watsonville, and encourage all residents to come together and join Survivors Healing Center in raising awareness of this important issue and participating in the fight to protect our children. IN WITNESS WHEREOF, I have hereunto set my hand and caused the Seal of the City of Watsonville to be affixed this 21st day of April, two thousand and seven. ______________________________ Manuel Quintero Bersamin, Mayor

19. W A T S O N V I L L E , C A L I F O R N I A

20. REQUEST FOR RECORDS 04/04/2023 W (AACL) Michael A. Ayele P.O.Box 20438 Addis Ababa, Ethiopia E-mail : waacl13@gmail.com ; waacl1313@gmail.com ; waacl42913@gmail.com Request for Records 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 to file a request for records with your office. i The bases for this records request are [1] the commemoration of Sexual Assault Awareness Month(SAAM) in America during the month of April;ii [2] the complaint filed by Teresa Williams in the United States District Court following her sexual coercion as an employee of the Iron Mountain Police Department (IMPD, located in the State of Michigan).iii I) Requested Records What I am requesting for prompt disclosure are records in your possession detailing your discussions about [1] Sexual Assault Awareness Month (SAAM) as a monthly event that (i) began to be commemorated nationally throughout the United States of America (U.S.A) in April 2001, (ii) has sought to prevent and raise awareness on the subject of sexual violence in areas “such as communities, workplaces and college campuses,” (iii) has adopted for a theme this Calendar Year 2023: “Drawing Connections: Prevention Demands Equity;”iv [2] the manner in which your post-secondary academic institution has been commemorating SAAM since April 01st 2001; [3] the decision of the University of Missouri – Kansas City (UMKC) to define the term “sexual coercion” as the “unwanted sexual activity that happens when someone is pressured, tricked, threatened, or forced in a non-physical way;” v [4] the definition in use by your post-secondary academic institution for what constitutes “sexual coercion;” [5] Teresa Williams as the 1st (first) white woman police officer employed for the Iron Mountain Police Department (IMPD in Michigan), who was sexually coerced to (i) kiss her immediate supervisor (Joseph Dumais) not long after she began her employment on October 17th 2017, (ii) perform oral sex on Garth Budek; [6] Teresa Williams as a woman, who (i) has acquiesced to false claims for the purpose of keeping her job with the IMPD, (ii) ended up resigning from her employment with the IMPD after facing a culture ripe with systemic chauvinism, misogyny and sexism, (iii) ended up filing a complaint pursuant to Title VII of the 1964 and 1991 Civil Rights Act on June 13th 2022, (iv) was informed by the Equal Employment Opportunity Commission (EEOC) that her charge of employment discrimination would not be referred to the Department of Justice (DOJ) for prosecution pursuant to Title VII of the 1964 and 1991 Civil Rights Act, (v) does not have the DOJ legally representing her in the complaint she filed with the United States District Court for the Western District Court of Michigan pursuant to Title VII of the 1964 and 1991 Civil Rights Act on February 13th 2023;vi [7] Michael Ayele (a.k.a) W as a Black man, who (i) was previously employed by the Missouri Department of Mental Health (MODMH) Fulton State Hospital (FSH), (ii) was informed by his former employers that 9 (nine) charges of employment discrimination were filed against the MODMH pursuant to Title VII of the 1964 and 1991 Civil Updated.: April 04th 2023 MICHAEL A. AYELE (A.K.A) W 1

21. REQUEST FOR RECORDS 04/04/2023 Rights between January 01st 2010 and December 07th 2021,vii (iii) has reminded the EEOC of the discrepancy they would create in their own system if they would in the future refer a charge of employment discrimination filed against the MODMH (that present similar issues to Charge No.: 28E – 2014 – 00485C) to the DOJ,viii (iv) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and sexual harassment of Lindsey Boylan, Charlotte Bennett, Ana Liss and Alyssa McGrath,ix (v) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and sexual harassment of Tara Cable,x (vi) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and the sexual harassment of Eliza Dushku,xi (vii) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the November 29th 2021 employment related murder of Delfina Pan in Miami Beach (Florida),xii (viii) is very much vexed with the EEOC processing of his FOIA request on the subject of the June 11th 2022 employment related murder of Riley Whitelaw; xiii [8] the 6th (Sixth) Amendment Rights implications of not having a Title VII charge of employment discrimination legally represented in court by (i) the EEOC if the complainant of the charge is/was working for a private organization, (ii) the DOJ if the complainant of the charge is/was working for a local/state U.S government agency. II) Request for a Fee Waiver and Expedited Processing The requested records do/will demonstrate that [1] Sexual Assault Awareness Month (SAAM) is a monthly event that (i) began to be commemorated nationally throughout the U.S.A in April 2001, (ii) has sought to prevent and raise awareness on the subject of sexual violence in areas “such as communities, workplaces and college campuses,” (iii) has adopted for a theme this Calendar Year 2023: “Drawing Connections: Prevention Demands Equity;” [2] the University of Missouri – Kansas City (UMKC) is a post-secondary academic institution, which defines the term “sexual coercion” as “an unwanted sexual activity that happens when someone is pressured, tricked, threatened, or forced in a non-physical way,” [3] Michael A. Ayele (a.k.a) W is a Black man, who has heavily relied on the definition of the UMKC for what constitutes “sexual coercion” when he ultimately became persuaded that Teresa Williams was more likely than not sexually coerced when she engaged in sexual activity that she didn’t consent to during her employment with the Iron Mountain Police Department (IMPD, located in the State of Michigan); [4] Teresa Williams is a white woman, who (i) was employed in a police department that had exclusively white men as members, (ii) was sexually coerced to kiss her immediate supervisor Joseph Dumais not long after she began her employment with the IMPD on October 17th 2017, (iii) was sexually coerced to perform oral sex on Garth Budek, (iv) has gone to extreme lengths for the purpose of keeping her job with the IMPD, (v) ended up resigning from her employment with the IMPD after facing a police culture ripe with systemic chauvinism, misogyny and sexism in the State of Michigan, (vi) ended up filing a complaint pursuant to Title VII of the 1964 and 1991 Civil Rights Act on June 13th 2022, (vii) was legally advised by the EEOC that her charge of employment discrimination would not be referred to the DOJ for prosecution pursuant to Title VII of the 1964 and 1991 Civil Rights Act, (viii) does not have the DOJ legally representing her in the complaint she filed with the United States District Court for the Western District Court of Michigan pursuant to Title VII of the 1964 and 1991 Civil Rights MICHAEL A. AYELE (A.K.A) W 2

22. REQUEST FOR RECORDS 04/04/2023 Act; [5] Michael Ayele (a.k.a) W as a Black man, who (i) was previously employed by the Missouri Department of Mental Health (MODMH) Fulton State Hospital (FSH), (ii) was informed by his former employers that 9 (nine) charges of employment discrimination were filed against the MODMH pursuant to Title VII of the 1964 and 1991 Civil Rights between January 01st 2010 and December 07th 2021, (iii) has reminded the EEOC of the discrepancy they would create in their own system if they would in the future refer a charge of employment discrimination filed against the MODMH (that present similar issues to Charge No.: 28E – 2014 – 00485C) to the DOJ, (iv) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and sexual harassment of Lindsey Boylan, Charlotte Bennett, Ana Liss and Alyssa McGrath, (v) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and sexual harassment of Tara Cable, (vi) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the employment history and the sexual harassment of Eliza Dushku, (vii) is very much vexed with the EEOC response to his FOIA request submitted on the subject of the November 29th 2021 employment related murder of Delfina Pan in Miami Beach (Florida), (viii) is very much vexed with the EEOC processing of his FOIA request on the subject of the June 11th 2022 employment related murder of Riley Whitelaw in Colorado Springs, Colorado. In my judgment, the facts presented in this records request are not the sort to bolster public confidence in the activities of the U.S government overall. As a Black man with a U.S college degree (who has previously filed a charge of employment discrimination pursuant to Title VII of the 1964 and 1991 Civil Rights Act), I would like to take this opportunity to [1] acknowledge the month of April as Sexual Assault Awareness Month (SAAM), [2] condemn sexual coercion as it is defined by the UMKC; [3] condemn the sexual coercion experienced by Teresa Williams during her employment with the IMPD; [4] condemn the sexual harassment experienced by Lindsey Boylan, Charlotte Bennett, Ana Liss and Alyssa McGrath; [5] condemn the sexual harassment experienced by Tara Cable; [6] condemn the sexual harassment experienced by Eliza Dushku; [7] condemn the November 29th 2021 employment related murder of Delfina Pan in Miami Beach, Florida; [8] condemn the June 11th 2022 employment related murder of Riley Whitelaw in Colorado Springs, Colorado; [9] condemn the EEOC processing of the Charge No.: 28E – 2014 – 00485C; [10] condemn any and all type of violence committed against women irrespective of their racial backgrounds, their sexual orientations, their national origins, their religious affiliations, their disability status, their employment history and/or their age groups. The core issues presented in this records request are as follows. 1) Have you had conversations about the manner in which your post-secondary academic institution has historically commemorated SAAM? If yes, will you promptly disclose records? 2) Does your post-secondary academic institution have a history of commemorating SAAM? If yes, will you promptly disclose those records? 3) Have you had conversations about the definition adopted by the UMKC for what constitutes “sexual coercion?” If yes, will you promptly disclose those records? 4) Has your post-secondary academic institution adopted a definition for what constitutes “sexual coercion?” If yes, will you promptly disclose those records? 5) Have you had conversations MICHAEL A. AYELE (A.K.A) W 3

23. REQUEST FOR RECORDS 04/04/2023 about the recently publicized employment history of Teresa Williams with the IMPD? If yes, will you promptly disclose those records? 6) Have you had conversations about the 6th (Sixth) Amendment Rights implication of not having a Title VII complaint represented by the EEOC if the complainant in that charge is employed for a private organization (that is either for-profit or not-for-profit)? If yes, will you promptly disclose those records? 7) Have you had conversations about the 6th Amendment Rights implication of not having a Title VII complaint represented by the DOJ if the complainant in that charge is employed for a local/state government agency of the U.S.A? 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 city/county/state government as well as for-profit and not-for-profit organizations; [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. 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 4

24. REQUEST FOR RECORDS 04/04/2023 Work Cited iPlease be advised that I have previously disseminated a vast number of documents (obtained through records requests) using the means of various digital publishing platforms such as Anyflip.com, Archive.org, Calameo.com, Edocr.com, Fliphtml5.com, Issuu.com, Medium.com, Pubhtml5.com, Scribd.com, Speakerdeck.com, SlideServe.com and YouTube.com. These documents have been made available to the public at no financial expense to them. As a member 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 through the means I have mentioned above or other ones. 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/ iiApril 2023 marks the official 22nd anniversary of Sexual Assault Awareness Month (SAAM). (…) Even before its official declaration, SAAM was about both awareness and prevention of sexual assault, harassment, and abuse. (…) As long as there have been people who care about making the world a better place, there have been individuals advocating for sexual assault prevention. In the United States, movements for social change and equality began to gain traction in the 1940s and 50s with the civil rights era. Although open discussion of the realities of sexual assault and domestic violence were limited at these times, activists for equal rights began to challenge the status quo. Efforts during this time were championed by Black women and women of color. Advocates like Rosa Parks worked at the intersections of race-based and gender-based violence (a framework) that years later in 1989, advocate and professor Kimberle Crenshaw would call “intersectionality”). Wide social activism around the issue of sexual assault continued in the 1970s, bringing with it support for survivors and heightened awareness. The first rape crisis center was founded in San Francisco in 1971, the same city where the first U.S. Take Back the Night event was held seven years later. The following decades mobilized survivors and advocates to call for legislation and funding that would support survivors, such as the Violence Against Women Act of 1992 (VAWA). Monumental changes like VAWA demonstrated that national efforts promoting sexual violence prevention were needed. Even before SAAM was first nationally observed in 2001, advocates had been holding events, marches, and observances related to sexual violence during the month of April, sometimes during a week-long “Sexual Assault Awareness Week.” In an effort to further coordinate awareness and prevention efforts, in 2000, the newly launched National Sexual Violence Resource Center and the Resource Sharing Project polled sexual violence coalitions. They asked organizations about their preferred color, symbol, and month for sexual assault awareness activities. The results showed that those in the movement preferred a teal ribbon as a symbol for sexual assault awareness, and SAAM as we know if was born. (…) In the early 2000s, the primary goal of SAAM was awareness – both raising visibility of the teal ribbon and the meaning behind it. By the mid-2000s, SAAM incorporated prevention more MICHAEL A. AYELE (A.K.A) W 5

25. REQUEST FOR RECORDS 04/04/2023 heavily, focusing on areas such as communities, workplaces, and college campuses. These campaigns discussed ways that individuals and communities can stop sexual assault before it happens by changing behaviors and promoting respect. These two goals of awareness and prevention carried over into the 2010s, laying the groundwork for the SAAM that we see today. While each campaign has a different theme, they all share same common goals: to raise visibility about sexual assault share how it can be prevented, whether that’s through education about healthy sexuality, consent, or bystander intervention. History of Sexual Assault Awareness Month. National Sexual Violence Resource Center.: https://www.nsvrc.org/saam/history iiiPlaintiff Teresa Williams was employed with the Iron Mountain Police Department from October 2017, until she was forced to resign or face termination. On information and belief, Plaintiff was the first and only female officer in the history of the department. During her employment with the IMPD, Plaintiff was groped, sexually harassed, and held to a completely different standard of expectations and treatment than her male counterparts. Her supervisor, Defendant Joseph Dumais, the deputy director, referred to Plaintiff’s hire as the first female officer as a “lawsuit waiting to happen.” Nonetheless, Dumais would grope and force Plaintiff to kiss him within weeks of her employment. Plaintiff was an outcast during her entire employment. She was sexually harassed, belittled, and habitually undermined. When Plaintiff submitted complaints, her abusers found ways to discipline her and threatened her with further discipline for discussing the matter further. When she pressed the issue of sexual harassment, she was ultimately forced to resign or face termination. Teresa Williams v City of Iron Mountain. https://www.documentcloud.org/documents/23722924-teresa-williams-v-iron-mountain- complaint ivEvery April, the National Sexual Violence Resource Center (NSVRC), one of the many leading organization on NO MORE’s steering committee, coordinates the national Sexual Assault Awareness Month (SAAM) campaign for the month of April to educate and engage the public in addressing this widespread issue. The theme of Sexual Assault Awareness Month 2023 is “Drawing Connections: Prevention Demands Equity.” This April’s campaign calls on all individuals, communities, organizations, and institutions to change ourselves and the systems surrounding us to build racial equity and respect. No More Campaigns.: https://nomore.org/campaigns/sexual-assault-awareness-month/ vSexual coercion is unwanted sexual activity that happens when you are pressured, tricked, threatened, or forced in a non-physical way. Coerced sexual behaviors occurs more frequently than forcible sexual assault, and typically involves repeated begging for sex or pressuring someone who is resisting sexual activity until they gin, often to end the coercion or to preserve the relationship. (…) MICHAEL A. AYELE (A.K.A) W 6

26. REQUEST FOR RECORDS 04/04/2023 Sexual coercion is any type of non-physical pressure used to make you feel as though you have no choice but to participate in sexual activity despite your disinterest, unwillingness, or protests. Think of sexual coercion as a spectrum or a range. It can vary from someone verbally egging you on to someone actually forcing you to have contact with them. It can be verbal and emotional, in the form of statements that make you feel pressure, guilt, or shame. You can also be made to feel forced through more subtle actions. Methods of Coercion could include: Wearing you down by asking for sex again and again or making you feel bad, guilty, or obligated. Making you feel like it’s too late to say no Reacting negatively if you say no or don’t immediately agree to something Telling you that not having sex will hurt your relationship Trying to normalize their sexual expectations Giving you compliments that sound extreme or insincere as an attempt to get you to agree to something Making promises to reward you for sex Giving you drugs or alcohol to loosen up your inhibitions Threatening your children or other family members Threatening your job, home, or school career Threatening to reveal your sexual orientation publicly or to family or friends Coercive statements are: “If you really loved me, you’d do it.” “Come on; it’s my birthday.” “You don’t know what you do to me.” “But you’ve already gotten me all worked up.” “You can’t just make someone stop.” “This really pisses me off.” “Sometimes I hate you.” “I can’t believe you’d hold out on me like this.” “Everything’s perfect. Why do you have to ruin it?” “I’ll break up with you if you don’t have sex with me.” “If I don’t get sex from you, I’ll get it somewhere else.” “I need it; I’m a sexual person.” “You should want to have sex with me like I do with you.” “I’ve always had sex this much in a relationship.” “You are the most beautiful woman I’ve ever seen.” “Baby, only you get me excited.” “I can’t focus on anything else but you.” “I’ve never known anyone who can _____ like you.” MICHAEL A. AYELE (A.K.A) W 7

27. REQUEST FOR RECORDS 04/04/2023 “Everyone things we already have, so you might as well.” “I’ll just tell everyone you did it anyway.” “I’ll make it worth your while.” “You know I have a lot of connections.” “You’ll get an A, no problem.” “Here, have another drink. It will loosen you up.” “Smoke with me –you’ll need to relax a little.” “If you won’t, I’ll hurt____.” “Just wait –you won’t have to worry about that dog anymore.” “I really respect you work here. I’d hate for something to change that.” “I haven’t decided yet who’s getting bonuses this year.” “Don’t worry about the rent. There are other things you can do.” “You work so hard; it’d be a shame for you not to get an A.” “If you don’t do this, I’ll feel you’re gay.” “I’m going to make sure your coworkers know you’re trans.” “You have to do it, ‘cause if you don’t, I’m outingyou on Insta.’ (…) One aspect of your life that you should have complete control over is how far you want to take it with your romantic partner, your significant other, your crush, or even someone you’re just hooking up with. When it comes to anything physical, you absolutely have a voice and do not have to do anything you don’t want to do when the person you’re with respects your boundaries. Be clear and direct with your partner if you don’t want to do something. Don’t be embarrassed to say that you don’t want to get physical in whatever way makes you uncomfortable. Be honest and make sure that you are heard. If the other person is not listening to you, leave the situation. It is better to risk a relationship ending or hurting someone’s feelings than to do something you aren’t willing to do. Some possible verbal responses include: “Let’s talk about something else.” “I’m not rejecting you – I just don’t want to _____.” “Idon’t want to do this because of [reason/experience/feeling].” “If you really cared for me, you’ll respect that I don’t want to _____.” “Idon’t owe you an explanation, or anything at all.” “This is not a negotiation.” “I’m into what we’re doing now, but I don’t want to _____.” “You must be mistaken. I don’t want to _____ with you.” “Idon’t think that question is appropriate for you to ask me.” “That is not what this is about, so don’t go there.” “Thanks for the invitation, but no, I don’t want to _____.” “Thank you for asking, but no, I just want to be friends.” “I’m good, but thanks!” “I’m out; have a good night!” “I said no. I don’t want to _____.” MICHAEL A. AYELE (A.K.A) W 8

28. REQUEST FOR RECORDS 04/04/2023 “STOP.” “NO.” University of Missouri – Kansas City (UMKC) on Sexual Coercion.: https://info.umkc.edu/rise/sexual-coercion/ viPlaintiff Teresa Williams (…) is a woman and a member of a protected class based on her gender. Plaintiff began working for the Iron Mountain Police Department (IMPD), a department of Defendant City of Iron Mountain, as a Road Patrol Officer on or around October 17, 2017. Upon information and belief, Plaintiff was the first (and of the date of this Complaint, only) female officer in the history of the IMPD. The IMPD is a small department with approximately fifteen officers total, including supervisors. Notably, the IMPD has a mutual aid agreement/reciprocal relationship with other departments and surrounding agencies within the area – including nearby Florence, Wisconsin. At all relevant time here, in the IMPD was managed and overseen by Director of Police and Fire Services Ed Mattson. Initially, Plaintiff was partnered with Defendant Sgt. Garth Budek. Budek was a senior road patrol officer and Plaintiff’s training officer at nights. Importantly, Budek is very close friends and the “right hand man” of then Sgt. Joseph Dumais. (…) On paper, the IMPD has a harassment policy which states that it has a “commitment to maintaining a working environment for all employees that is free from intimidation, humiliation, or insult, whether it be physical or verbal abuse, or other actions of a sexual, ethnic, racial or religious nature.” As a minority in the department, Plaintiff felt it was important to socialize and become accepted by her colleagues. Early into her employment, Plaintiff was invited to socialize at a local bar with her supervisors Defendants Budek and Dumais. Initially, Plaintiff was extremely excited by their invitations as to her it meant she was being accepted as part of the department. However, Plaintiff eventually learned that this was not the case. On one occasion at Sol Blu, a drinking establishment in Iron Mountain, Dumais told Plaintiff that she had to take a “IMPD shot” with him as part of her “initiation” into the IMPD. Dumais explained that the IMPD shot involved taking a shot of fireball liquor then making out with each other. Upon explanation, Plaintiff refused and said the whole thing was made up. Dumais responded that it was required and that everyone had to do it as standard protocol. To allegedly demonstrate, Dumais took an initial shot along with a former county dispatcher (male) then kissed him. Ultimately, Plaintiff buckled to the pressure and took the “IMPD shot” with Dumais who, as a result, kissed Plaintiff and stated that she was now “officially part of IMPD.” After, Dumais and Plaintiff were talking in the back section of the Solbergs. Dumais attempted to get Plaintiff to take a second “IMPD shot” with him, but she continuously refused. Ultimately, Dumais pressured Plaintiff into taking the second IMPD shot, however this time Dumais put his hand between Plaintiff’s legs and grabbed her genitals. Plaintiff froze in fear. From this point forward, it was clear to Plaintiff that she would be subject to ongoing harassment and treatment by her all male colleagues, however, also struggle to be accepted as a member of the department. For this reason, Plaintiff continued to socialize with Dumais and Budek. MICHAEL A. AYELE (A.K.A) W 9

29. REQUEST FOR RECORDS 04/04/2023 In another incident, Plaintiff drove Budek and Dumais to their homes after a night at a local bar. Plaintiff first dropped off Dumais and proceeded to drop off Budek. As she was approaching a stop sign, Budek instructed Plaintiff to stop so that he could “tell her something.” Upon stopping, Budek shifting Plaintiff’s car into park. Next, Budek proceeded to tell Plaintiff “how hot her ‘ass’ looked in her duty pants” and forcing himself on the Plaintiff. In the process, Budek grabbed Plaintiff’s hand and pulled her closer ultimately placing her hand on his gentiles over his pants. Budek leaned in to kiss Plaintiff, who turned away, so he began kissing her neck. Plaintiff affirmatively told Budek to stop, however, he overpowered her and now placed her hand beneath his pants. At some point, Plaintiff stopped resisting and Budek let her hand go. Once this happened, Plaintiff quickly shifted the car into drive and drove off. Upon arriving at Budek’s home, he thanked her for driving and asked Plaintiff “at least for a hug.” Plaintiff agreed to the hug, but was again met with neck kisses as well as groping over her upper thigh. Plaintiff again told Budek to stop. Budek then apologized and began crying stating that what he did was “not fine” and that he “did not want her mad at him.” In the moment, Plaintiff told Budek it was fine and that he needed to get into his house. Budek agreed and left the vehicle. In another incident, Plaintiff again was tasked with driving Dumais and Budek home after a night at a local bar. As before, Plaintiff dropped off Dumais first. Upon reaching Budek’s home, he stated that it was “difficult to work with her” because he is distracted looking at her and he found it hard to restrain himself. Next, Budek began rubbing Plaintiff’s thighs and said, “how are we going to resolve this issue?” Budek then looked up and down Plaintiff’s body, licked his lips, and asked Plaintiff to move closer. Plaintiff refused. Budek then grabbed Plaintiff’s head with both his hands in attempt to force her to kiss him. She resisted. Ultimately, Budek let her go and exited the car. Similarly, there were countless incident of Budek groping Plaintiff’s butt or thigh, and/or making sexual comments about Plaintiff while working. In another incident, Plaintiff was asked to go out to a drink at a Greenleaf’s Bar with Budek and his wife. Plaintiff felt safe as Budek’s wife was present. After Plaintiff was invited to watch a movie with Budek and his wife. At some point, Budek’s wife excused herself. After, Budek grabbed Plaintiff’s hand and guided her downstairs. Once there, Budek pressured Plaintiff to perform oral sex on him. After, Budek told Plaintiff that she could never tell anyone. From this point forward, the work environment with Budek became extremely hostile. Shortly after, there was an incident during a traffic stop in which Plaintiff and Budek were in disagreement on which turned hostile. Budek screamed at Plaintiff and belittled her while she was driving. Budek called Plaintiff a “B****” and a “c***.” Plaintiff told Budek that he was being “an a******.” Plaintiff drove home in tears. The next morning, Dumais never asked what happened, but informed Plaintiff there was never going to be an incident again. After, the schedule was changed and Plaintiff was assigned a new partner, Officer Hellman. One night while patrolling, the topic of the schedule change came up. Hellman initially stated that he heard it was over an argument between Plaintiff and Budek. After, Hellman began laughing and Plaintiff asked why. Hellman informed Plaintiff that Dumais and Budek made a bet as to which officer would have sex with Plaintiff first after she was hired. Plaintiff was appalled. Following these incidents, Budek would be promoted to sergeant and Dumais would be promoted to the second in command of IMPD. (…) Following the schedule change, Plaintiff rarely worked with Budek. However, he would belittle her every chance he could. Further, Plaintiff turned down overtime opportunities to avoid shifts for which she would be working with Budek. Unfortunately, Plaintiff was also MICHAEL A. AYELE (A.K.A) W 10

30. REQUEST FOR RECORDS 04/04/2023 subject to disparate treatment, scrutiny, and discipline from Defendants. Plaintiff complained about this unequal treatment and harassment but her complaints fell upon deaf ears. On July 15th2018, Plaintiff was forced to respond to a call relating to a “suicidal woman potentially with a knife” while her male partner remained at the station to socialize. Ultimately, Plaintiff obtained assistance from a Dickinson County deputy and a Michigan State trooper. The situation proved extremely dangerous as Plaintiff was required to disarm the knife from the woman. Plaintiff returned to the station to ask why they did not assist her. Rather than validate Plaintiff’s concerns, the male IMPD officers complained to Plaintiff about her “attitude” over the radio following the incident. Later, Dumais met with Plaintiff regarding the incident and agreed that Plaintiff should not have been forced to respond to the call alone, however, issued no warnings or discipline. Instead, Dumais focused on Plaintiff’s radio demeanor. In December 2018, Plaintiff was notified by a lieutenant to “watch her back around Dumais.” Specifically, Plaintiff was told Dumais never wanted her hired and planned to using anything he could against her. Further, Plaintiff was told that Dumais said it was a “lawsuit nightmare” to have a female officer around. In or around March 2019, Dumais was promoted from Lieutenant to the Deputy Director position – second in command of the IMPD. Concurrently, Budek was promoted to Sergeant. The ongoing sexual harassment of Plaintiff continued both verbally and in writing, including but not limited to Dumais texting Plaintiff “if I was in your pants you would know it.” In January 2020, Plaintiff received a call from an acquaintance, Mike Milan, who asked if Plaintiff was still employed with the IMPD. Plaintiff responded that she was actually on her way to work. According to Milan, Dumais had been telling folks outside of the department that Plaintiff was not going to be along much longer. Milan also stated that Dumais was commenting about Plaintiff’s relationship and significant other. Upon arriving at work, Plaintiff approached Defendant Mattson and asked if she was being terminated. Mattson responded no. Plaintiff informed Mattson of Dumais alleged comments and how it is a violation of policy. (…) Mattson dismissed Plaintiff’s concerns and said was probably “bar talk.” On or around October 18, 2020, Dumais commented to Plaintiff in a pretention manner that he had heard Plaintiff was “getting married and that is something she should be happy about” and should be “telling everyone.” Plaintiff responded that she preferred to keep her personal life to herself. After, Dumais made Plaintiff stay past the end of her shift, unpaid, to complete a form that he waited until ten minutes before the end of her shift to mention. From that point forward, Dumais would exclaim that Plaintiff was “too good to hang out with us anymore.” From this point forwarded, Defendants relentlessly targeted Plaintiff for discipline. Importantly, her male colleagues were held to completely different standard and were never disciplined for similar conduct as alleged of the Plaintiff. On October 27th 2020, Plaintiff was asked to meet Dumais in his office with the door closed. Plaintiff vocalized to Dumais that she did not feel comfortable meeting him alone with the door closed and asked if she could have someone with him in the room. Dumais responded that Plaintiff couldn’t have anyone in the room. Dumais proceeded to berate Plaintiff saying he was “sick and tired of hearing her pity story” and that he outranks her. Plaintiff was brought to tears. Dumais next stated he “was done” and told Plaintiff to leave. Shortly after, Plaintiff received an unpaid suspension for alleged unprofessional activity and for failing to answer her radio in response to a “two officer call” involving a “hit and run” accident. The officer, Officer MICHAEL A. AYELE (A.K.A) W 11

31. REQUEST FOR RECORDS 04/04/2023 Opolka, had only been on the job for a little over a year, however, it is the type of matter that and other officers routinely handle alone. Comparatively, the circumstances as they relate to the dangerous knife situation on July 15th 2018 involving Plaintiff. Despite requesting backup for the dangerous call, Plaintiff received no assistance from her male colleagues and no officers were disciplined. Instead, Plaintiff was lectured about her attitude. On November 04th 2020, Plaintiff returned from her suspension. Upon her arrival, Plaintiff was notified that she was again being suspended this time for alleged insubordination relating the meeting with Dumais on October 27th 2020. On November 10th 2020, Plaintiff was targeted and suspended again. This time was for Plaintiff allegedly not taking the faster route to a call and, as a result, was two minutes slower than they believed she should have arrived. Additionally, Plaintiff was reprimanded for being defiant with the officer who groped and harassed her, Dumais. On November 18th 2020, the Plaintiff met with her union representatives, including Sgt. Solka, Sgt. Ray, and union representative Hal Telling, and advised them that she felt she was being discriminated against. Plaintiff also discussed the hostile work environment she was being subjected to. She stated that she was afraid of getting disciplined for things men routinely do. Further, that Defendant Mattson was wrongfully letting everyone know of her private discipline in violation of policy. Next, Plaintiff was advised against being a “whistleblower” and that she would be terminated if it was determined to be unfounded. Plaintiff was told that nothing could be done about the release of private information. Solka and Ray suggested that Plaintiff should make sure to document every conversation on a body camera or email – something no male counterpart had to do. Plaintiff questioned whether anyone else needed to do this. Finally, Plaintiff was told that officers would be disciplined if it ever happened again. As before, Plaintiff felt hopeless and pressured by the Defendants and her union to agree to a lower discipline. On around March 09th 2022, Plaintiff met with the Defendants Mattson and Dumais, now Deputy Director of Police, to discuss several issues including, but not limited to, officers discussing her discipline outside of the department, switching her schedule, and her ongoing harassment – including her past sexual harassment, During the conversation, Mattson stated that Budek was “struggling emotionally” and wanted to “come clean to his wife.” Mattson continued that he understood the work-related incident to be “fully clothed touching” and that he “didn’t care about anything that happened elsewhere.” Mattson continued that he was discussing this with her to help Budek (as opposed to addressing the sexual harassment and assault of an officer on a subordinate at all). Mattson stated that it was not a “disciplinary issue” for her. Plaintiff responded that the portrayal was “f**** up.” Plaintiff continued stating that, among other things, Budek was her senior officer and would be the one subject to discipline. Mattson responded that there will be no discipline for anyone. Next, Plaintiff stated that Budek previously calling her a “cunt” would have been grounds for termination at most jobs. Mattson inquired why Plaintiff didn’t say anything to which Plaintiff responded that she was scared of continued retaliation even from the current conversation, as Budek is close friends with both officers. Plaintiff elaborated that things are terrible with Budek ever since. Further, that she had been telling them about Budek’s hostile treatment for years but these complaints have been ignored. Rather than taking the matter into his own hands, Mattson asked Plaintiff what it is he should do. Plaintiff, scared of further retaliation, said she “didn’t know.” Around this point, Defendant Dumais requested Plaintiff provide them with an answer by the end of her shift so they could “move on.” During the meeting, Mattson was adamant that “no one” hear about the harassment MICHAEL A. AYELE (A.K.A) W 12

32. REQUEST FOR RECORDS 04/04/2023 by Budek against Plaintiff. At the end of Plaintiff’s shift, she notified Defendants that she planned to speak with an attorney as to what she should do. On March 21st 2022, Mattson sent an email to Plaintiff which confirmed the conversation, but completely misrepresented the statements during the meeting. (…) On or around April 21st2022, Ed Mattson and Dumais held an “investigative” meeting with Plaintiff. Under threat of imminent termination, Plaintiff resigned her employment from IMPD. (…) On June 13th 2022, Plaintiff timely filed a charge of discrimination and harassment based on sex and retaliation with the Equal Employment Opportunity Commission (EEOC). (…) Upon learning of Plaintiff’s protected EEOC Charge, Defendants intentionally inflicted severe emotional distress upon the Plaintiff. Within months, Defendants intentionally inflicted severe emotional distress upon the Plaintiff. Within months, Defendants would go on to defame, target, and retaliate against Plaintiff, as well as her children. On July 26th2022, Plaintiff’s criminal charges became front page news in the local and regional media, despite the charges pending for some time. (…) Plaintiff’s youngest minor son was charged with destruction of property relating to alleged accidental damage to a picnic table at a public park. Despite multiple children being present, only Plaintiff’s son was charged with a crime. Notable, the police report indicates that another individual caused damage but was not charged. Further, countless comparable incidents have occurred in which no one has been charged with a crime. Subsequently, these charges were dropped. In late 2022, an unidentified IMPD officer contacted the Michigan State Police Department to report a “tip” that Plaintiff’s oldest chil was allegedly seen with a pistol at school. The claims were completely baseless. As a result, Michigan State Police visited Plaintiff’s house to question her and investigate. In December 2022, Plaintiff applied for a concealed pistol license (“CPL”) with the Dickinson County Clerk’s office but was rejected without justification or explanation. On information and belief, the rejection was due to the involvement of the Defendants. On February 07th 2023, Plaintiff was issued her right to sue letter relating to her claims of gender discrimination, sexual harassment, hostile work environment, and retaliation. (…) As a direct proximate result of Defendants’ unlawful actions, Plaintiff has sustained injuries and damages including, but not limited to, loss of pay, loss of vacation and sick days, loss of career opportunities, humiliation and embarrassment, mental anguish and emotional distress, loss of professional reputation and loss of the ordinary pleasures of everyday life, including the right to pursue gainful occupation of choice and has incurred attorney fees. Teresa Williams v City of Iron Mountain. https://www.documentcloud.org/documents/23722924-teresa-williams-v-iron-mountain- complaint viiIn October 2021, there were 5276 (five thousand two hundred and seventy-six) employees working for the MODMH. Of those, 3752 (three thousand seven hundred and fifty-two) employees were women and 1502 (one thousand five hundred and two) employees were men. While 64% (sixty four percent) of the MODMH employees identified as White, 31% (thirty one percent) identified as Black. Michael A. Ayele (a.k.a) W was previously employed for the MODMH. He has in 2013 filed a MICHAEL A. AYELE (A.K.A) W 13

33. REQUEST FOR RECORDS 04/04/2023 charge of employment discrimination with the Equal Employment Opportunity Commission (EEOC) against the MODMH. The charge of employment discrimination filed by Michael A. Ayele (a.k.a) W with the EEOC was previously assigned Case No.: 28E – 2014 – 00485C. The charge of employment discrimination filed by Michael A. Ayele (a.k.a) W with the EEOC has been subject of intense scrutiny for various reasons. Michael A. Ayele (a.k.a) W has recently been informed by his former employers that 9 (nine) charges of employment discrimination have been filed against the MODMH between January 01st 2010 and December 17th 2021. Of those, the MODMH opted to engage in the alternative dispute resolution (ADR) program offered by the EEOC on 4 (four) separate occasions. They also declined to engage in the ADR program offered by the EEOC on 5 (five) separate occasions. As of this writing, it remains unclear for the Association for the Advancement of Civil Liberties (AACL) why the MODMH opted to engage in certain ADR sessions offered by the EEOC, while refusing to do so for others. The AACL unequivocally denounces discrimination on the bases of gender, racial background, sexual orientation, national origin and religious affiliation. The AACL also unequivocally denounces discrimination against people with disabilities (PWD). The AACL has decided to publish this information to members of the general public because of the language used by the EEOC to describe their processing of Charge No.: 28E – 2014 – 00485C and also because of the EEOC frequent reference to this charge of discrimination. The AACL has effectively put the EEOC on notice that given their processing of Charge No.: 28E – 2014 – 00485C, they have forfeited their rights to represent Missouri State employees who [1] have opposed discriminatory practices in the service of healthcare pursuant to the Health Insurance Portability and Accountability Act (HIPAA); [2] have been subjected to racially motivated internal investigations (and were afterwards cleared of that investigation); [3] have been fired from their jobs as retaliation; [4] have been arrested for demanding the payment of their salary for the job they have performed. About the Employment Practices of the Missouri Department of Mental Health (MODMH). Michael A. Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/09/11/the-missouri-department-of-mental-health- modmh-disclose-records-documenting-their-total-number-of-employees-on-the-bases-of-gender- and-racial-background-w-aacl-michael-a-ayele/ viii Michael A. Ayele (a.k.a) W was a former employee of the Fulton State Hospital (FSH): a state agency, which is a component of the Missouri Department of Mental Health (MODMH). Between October 26th 2013 and November 20th 2013, Michael A. Ayele (a.k.a) W was subject of an internal state investigation after a complaint of “employee misconduct” was filed against him. In a letter hand-delivered to him on (or around) November 21st 2013, the-then Chief Operating Officer (COO) of the FSH informed Michael A. Ayele (a.k.a) W that he was “cleared” of any and all wrongdoing related to the October 26th 2013 incident. As a former employee of the MODMH (FSH), Michael A. Ayele (a.k.a) W has initiated contact with his former employers as well as the Equal Employment Opportunity Commission (EEOC) to obtain pertinent information about the complaint filed against him on October 26th 2013. Michael A. Ayele (a.k.a) W has also initiated contact with his former employers as well as the MICHAEL A. AYELE (A.K.A) W 14

34. REQUEST FOR RECORDS 04/04/2023 EEOC to obtain information about the investigation he was supposedly “cleared” of on (or around) November 21st 2013. Unfortunately, however, Michael A. Ayele (a.k.a) W has thus far been unsuccessful to obtain these records either from his former employers and/or the EEOC. In the judgement of the Association for the Advancement of Civil Liberties (AACL), the decision of the MODMH to withhold these records were not consistent with their obligations pursuant to Title VII of the 1964 and 1991 Civil Rights Act. The decision of the MODMH to withhold these records were not consistent with Missouri state laws including but not limited to 1 Missouri Sunshine Law (Section 630.140, RSMO) as well as Missouri Senate Bill 26 (Section 590.030 & Section 590.502, RSMO). Missouri Revised Statutes (RSMO) Section 590.502 specifically states for instance that law enforcement officers (who have passed a criminal background check with the Department of Justice Federal Bureau of Investigation) who “reasonably believe he or she is under investigation which could lead to disciplinary action, demotion, dismissal, transfer of placement that could lead to economic loss” [1] shall be informed in writing of the existence and nature of the alleged violation and who will be conducting the investigation; [2] shall be provided a “written statement outlining the complaint;” [3] shall be informedthat “he or she is being ordered to answer questions under threat of disciplinary action and that the (…) answers to the questions will not be used (…) in a criminal proceeding;” [4] shall be “questioned by up to two investigators and shall be informed of the name and rank of each questioning officer.” For the reasons mentioned above, the AACL regrets the decision of the MODMH to withhold records of Michael A. Ayele (a.k.a) W employment with the FSH between October 26th 2013 and November 21st 2013. Fulton State Hospital (FSH) is located approximately 2 (two) miles away from Westminster College (Fulton, MO). Michael A. Ayele (a.k.a) W has been an alumnus of Westminster College (Fulton, MO) since Saturday, December 31st 2016. Michael A. Ayele (a.k.a) W is exploring all legal avenues to obtain these records and other (just and appropriate) legal relief. Michael A. Ayele (a.k.a) W has absolutely no regrets whatsoever about not filing a complaint with the judicial branch of the U.S government (the courts) pursuant to Title VII of the 1964 and 1991 Civil Rights Act with a “Right to Sue” letter. Michael A. Ayele (a.k.a) W has read the settlement agreement concluded between Tara Cable and the Village of Suffern (New York) after she filed a complaint of employment discrimination with the United States District Court for the Southern District of New York (SDNY) without initiating contact with the EEOC. Michael A. Ayele (a.k.a) W has also read the August 03rd 2021 report published by the New York Attorney General Office of Letitia James, which made numerous references to Title VII of the 1964 and 1991 Civil Rights Act. About Michael A. Ayele (a.k.a) W October 26th 2013 at the Fulton State Hospital (FSH) now defunct Biggs Forensic Center (BFC) New Outlook Program (NOP). Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/10/28/october-26th-2013-at-the-fulton-state- hospital-index/ Despite operating facilities like the Sexual Offender Rehabilitation & Treatment Services (SORTS) and having concluded contracts with Missouri Girls Town, the Missouri Department of Mental Health (MODMH) have failed to make clear whether they consider sexual violence as a factor that has the potential to increase the risk of suicide. They have also failed to make clear MICHAEL A. AYELE (A.K.A) W 15

35. REQUEST FOR RECORDS 04/04/2023 whether the personal health information (PHI) of an individual similarly situated to Catherine Daisy Coleman would reflect that risk. As of this writing, it remains unclear for the AACL what the obligations of the MODMH pursuant to the Americans with Disabilities Act (ADA) and the Health Insurance Portability & Accountability Act (HIPAA) actually are. The MODMH were extremely vague to requests submitted by the AACL on the subject of [1] whether they have in the past disclosed the PHI of an individual in circumstances, where discrimination was at play (for the purpose of remedying the discrimination); [2] whether they were in the past required to disclose the PHI of an individual either to the Equal Employment Opportunity Commission (EEOC) and/or the courts (for the purpose of remedying the discrimination). According to the MODMH, “when someone you know is in emotional pain, ask them directly: ‘are you thinking about killing yourself?’ Research suggests acknowledging suicide may reduce rather than increase suicidal ideation. Asking the question in a direct, unbiased manner communicates that you are open to speaking about suicide in a non-judgmental and supportive way. Other questions you can ask include, ‘How can I help?’ and ‘what can we do about this?’ Asking these questions can open the door to honest communications to learn what next steps need to be taken. Often, we don’t know the challenges others face on a day-to-day basis.” Michael Ayele (a.k.a) W was a previous employee of the MODMH. He has in 2013 worked for the Fulton State Hospital (FSH): a component of the MODMH. FSH is located approximately two miles away from Westminster College (Fulton, Missouri). The FSH and Westminster College have concluded an affiliation agreement. Michael Ayele (a.k.a) W is an alumnus of Westminster College. As you may be aware, World Suicide Prevention Day (WSPD) is an event that was established in 2003 by the International Association for Suicide Prevention (IASP). Suicide accounts for 1% (one percent) of deaths globally. An estimated 703,000 (seven hundred and three thousand) people a year take their life around the world. For every suicide, there are likely 20 (twenty) other people making a suicide attempt and many more have serious thoughts of suicide. On the occasion of World Suicide Prevention Day/Month, the AACL very much encourages productive and constructive conversations on the subject of mental health and suicide. About the Commemoration of World Suicide Prevention Day (WSPD) in the Missouri Department of Mental Health (MODMH). Michael Ayele (a.k.a) W Official Website on WordPress: https://michaelayeleaacl.wordpress.com/2022/09/24/suicide-after-sexual-assault-and-hipaa-in- missouri-index/ The Association for the Advancement of Civil Liberties (AACL) has obtained limited responsive documents concerning the suicide of Catherine Daisy Coleman, which took place on August 04th 2020. Among documents that were disclosed to the AACL are contracts concluded between the Missouri Department of Mental Health (MODMH) and Missouri Girls Town: a facility, where Catherine Daisy Coleman is reported to have stayed in for a period of 90 (ninety) days before her permanent departure to the State of Colorado from the State of Missouri. According to the MODMH, Missouri Girls Town is a “time-limited placement resource for children requiring active coordinated and professional intervention in a highly structured environment by virtue of MICHAEL A. AYELE (A.K.A) W 16

36. REQUEST FOR RECORDS 04/04/2023 a demonstrated inability to function in any less restrictive setting. Children requiring residential treatment services exhibit a severe mental illness and/or persistent mental disorder as diagnosed according to the DSM-IV. These children may be unable to function consistently in an open, public school setting, may present a chronic runaway risk, and may present a history of showing rage, including physical aggression toward self and others.” Michael Ayele (a.k.a) W was a previous employee of the MODMH. He is also an alumnus of Westminster College (Fulton, MO). As an alumnus of Westminster College, who has previously worked for the Fulton State Hospital (a component of the MODMH), Michael Ayele (a.k.a) W doesn’t know if the MODMH accept as a matter of fact the reality that sexual assault could lead a woman who has experienced it to commit suicide. Michael Ayele (a.k.a) W is very much a proponent of reviewing the personal health information (PHI) of Catherine Daisy Coleman. Michael Ayele (a.k.a) W is very much concerned about the circumstances which led Catherine Daisy Coleman to leave the State of Missouri for the State of Colorado. Michael Ayele (a.k.a) W is also concerned about the things Catherine Daisy Coleman is reported to have gone through in the State of Colorado before her suicide on August 04th 2020. The MODMH have concluded an affiliation agreement with Westminster College. As a matter of principle, the AACL unequivocally denounces violence committed against women irrespective of their racial backgrounds, their sexual orientations, their national origins, their religious affiliations and/or their disability status. The AACL has recently expressed grave concerns about women being placed in circumstances encouraging the commission of suicide after having reported an incident of sexual harassment/sexual assault/rape to the authorities. The AACL unequivocally condemns malicious efforts to put women in circumstances encouraging the commission of suicide as a form of retaliation for having reported an incident of sexual harassment/sexual assault/rape. About the August 04th 2020 Suicide of Catherine Daisy Coleman and Michael A. Ayele (a.k.a) W October 26th 2013 at the Fulton State Hospital (FSH) now defunct Biggs Forensic Center (BFC) New Outlook Program (NOP). Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2021/12/10/catherine-daisy-coleman-january-2012-and- august-2020-in-review-affirmative-and-effective-consent-audrie-taylor-pott-michael-ayele-aacl- w-index/ ixThe Equal Employment Opportunity Commission (EEOC) have withheld records about [1] the discussions they had with the New York Attorney General (NYAG) in terms of their obligations pursuant to Title VII of the 1964 and 1991 Civil Rights Act given the findings of their August 03rd 2021 report; [2] the circumstances, which have in the past convinced them to refer a Charge of Employment Discrimination filed by state government employees to the Office of the Attorney General. According to the NYAG, former New York Governor Andrew Cuomo “sexually harassed a number of State employees through unwelcome and unwanted touching, as well as by making numerous offensive and sexually suggestive comments. (…) Such behavior by the Governor was part of a pattern that extended to his interactions with women outside of State government, and MICHAEL A. AYELE (A.K.A) W 17

37. REQUEST FOR RECORDS 04/04/2023 was enabled and facilitated by a culture (…) of secrecy, loyalty to the Governor, and fear, as well as the normalization of inappropriate comments and interactions by the Governor. (…) The Executive Chamber’s response to a number of sexual harassment allegations constituted unlawful retaliation.” The Association for the Advancement of Civil Liberties (AACL) unequivocally denounces violence committed against women irrespective of their racial backgrounds, their sexual orientations, their national origins, their religious affiliations, their disability status and/or their age group. The AACL is gravely concerned with the way that the EEOC processed the Charge of Employment Discrimination they had previously assigned Case No.: 28E – 2014 – 00485C. The AACL is also gravely concerned about the reasons why the sexual harassment experienced by Lindsey Boylan, Charlotte Bennett, Alyssa McGrath, Ana Liss and other women was not referred to the Department of Justice (DOJ) if such referral was indeed appropriate. The AACL has declined to initiate contact with the DOJ about the NYAG report published on August 03rd 2021 even though the EEOC have suggested it. The AACL wishes the named and unnamed women in the August 03rd 2021 report (published by the NYAG) all the best in their future endeavors. About the Employment History and the Sexual Harassment Experienced by Lindsey Boylan, Charlotte Bennett, Alyssa McGrath, Ana Liss & Other Women Who Were Subject of an August 03rd 2021 Report Published by the New York Attorney General (NYAG). Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/09/22/employment-history-and-sexual- harassment-of-charlotte-bennett-et-al-index/ xEven though Tara Cable has never filed a charge of employment discrimination pursuant to Title VII of the 1964 and 1991 Civil Rights Act, the Equal Employment Opportunity Commission (EEOC) have refused to confirm or deny whether they have had discussions about [1] the sexual harassment she experienced between 2018 and 2020 (for a period of two years) during her employment with the Village of Suffern (New York); [2] her so-called “promotion to the position of full-time police officer” with the Village of Suffern (New York); [3] the emotional distress she experienced as a direct consequence of her employment with the Village of Suffern (New York); [4] the complaint she has filed with the United States District Court for the Southern District of New York. After thoroughly reviewing the documents filed by Tara Cable with the United States District Court for the Southern District of New York (which are on the Internet’s public domain), the Association for the Advancement of Civil Liberties (AACL) was gravely concerned about Tara Cable’s so-called “promotion to the position of full-time police officer” with the Village of Suffern (New York). The AACL was shocked to learn that no news media outlet filed a New York Freedom of Information Law (FOIL) request to find out whether Tara Cable was subject of very inappropriate discussions in the police department of the Village of Suffern, New York prior to her so-called “promotion.” In the judgment of the AACL, Tara Cable really needs to watch her six o’clock. The AACL unequivocally denounces violence committed against women irrespective of their racial backgrounds, their sexual orientations, their religious affiliations, their national MICHAEL A. AYELE (A.K.A) W 18

38. REQUEST FOR RECORDS 04/04/2023 origins and/or their disability status. About the Employment History and the Sexual Harassment of Tara Cable. Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/10/14/employment-history-and-sexual- harassment-of-tara-cable-index/ xiThe Equal Employment Opportunity Commission (EEOC) confirmed on February 17th 2022 that they haven’t held any conversations whatsoever about Eliza Dushku’s employment history as well as her forced arbitration after she was sexually harassed. In the testimony she provided to the legislative branch of the U.S government, Eliza Dushku had made the following statements: “To this day, whenever my career, my life’s work is referenced, my accomplishment as an actress are ignored. I’ve been reduced to being Eliza Dushku: the actress who was paid off for allegedly being harassed on a T.V series. As I hope you can understand, this was not the outcome I desired nor ever expected. But because of binding arbitration, there will never be real justice for me and countless other victims of sexual harassment and assault. (…) I’m getting to break that silence today. Countless others who are bound by arbitration are not so fortunate.” The core issues, which the EEOC has failed to address in the records request that had been assigned Case No.: 820 – 2022 – 001897 are the following. 1) What was the extent of the EEOC’s involvement in the bipartisan bill, which was approvedby Congress called “Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021” (a.k.a) H.R 4445? 2) Had the EEOC been in contact with members of Congress such as Cheryl Lea Bustos or other ones for the purpose of ending forced arbitration in employment cases, which involve sexual assault and harassment? About Eliza Dushku Forced Arbitration Following Sexual Harassment at the Workplace. Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2021/12/11/employment-history-and-sexual- harassment-of-eliza-dushku-index/ xiiIn response to the records request submitted about the November 29th 2021 murder of Delfina Pan, the Association for the Advancement of Civil Liberties (AACL) has managed to obtain [1] the arrest affidavit, which has been assigned by the Floridian Courts Case Number.: F2102875; [2] the ordinance of Miami Beach, Florida that may have been filed in Case No.: F2102875; [3] the work-sharing agreement concluded between the Equal Employment Opportunity Commission (EEOC) and the Florida Commission on Human Relations (FCHR). The AACL continues to be concerned about several issues, which have not been addressed following the murder of Delfina Pan. These issues include but are not limited to [1] whether Delfina Pan was made aware by Kansas Bar & Grill (her former employers) on her rights to file a complaint of employment discrimination denouncing sexual harassment; [2] whether Delfina Pan ever made her wishes clear on what she wanted to happen in the event she passed away on the territory of the United States of America (USA); [3] whether the Department of Homeland Security (DHS), the EEOC and the FCHR should bear any legal responsibilities (pursuant to Title VII of the 1964 & 1991 Civil Rights Act) following the murder of an immigrant working and paying taxes within the borders of the U.S.A; [4] whether the DHS, the EEOC and the FCHR should bear any legal responsibilities (pursuant to Title VII of the 1964 & 1991 Civil Rights MICHAEL A. AYELE (A.K.A) W 19

39. REQUEST FOR RECORDS 04/04/2023 Act) following the murder of an immigrant, which can be directly tied to her previous employment workplace; [5] whether the City of Miami Beach (Florida) should bear any legal responsibilities for the murder of Delfina Pan particularly given the way their police department published extremely misleading information about her (initially refusing to acknowledge that her murder was employment related). As a matter of principle, the AACL unequivocally condemns violence committed against women irrespective of their racial backgrounds, their sexual orientations, their national origins, their religious affiliations and/or their disability status. About the November 29th 2021 Employment Related Murder of Delfina Pan in Miami Beach, Florida. Michael Ayele (a.k.a) W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/09/27/employment-history-and-sexual- harassment-of-delfina-pan-leading-to-murder-index/ xiiiWhen disclosing very limited records about the extent of their agency participation in the Equal Employment Opportunity Commission (EEOC) July 14th 2022 workshop on the subject of “Proactively Combating Workplace Harassment,” the Colorado Civil Rights Division (CCRD) have refused to be entirely transparent about their obligations to prevent in the future similar employment related murders such as the one committed against Riley Whitelaw on June 11th 2022 at the Walgreens store in Colorado Springs (Colorado). The Association for the Advancement of Civil Liberties (AACL) continues to be shocked by several aspects of the gruesome murder Riley Whitelaw was victim of on June 11th 2022. In the judgment of the AACL, the June 11th 2022 murder of Riley Whitelaw could have been prevented if [1] management personnel at Walgreens had taken the concerns of Riley Whitelaw seriously at the time she told them that she was being sexually harassed by Joshua Taylor Johnson (in Calendar Year 2021); [2] management personnel at Walgreens didn’t make Riley Whitelaw choose between extra-shifts with Joshua Taylor Johnson or limited amount of shifts at Walgreens in the absence of Joshua Taylor Johnson; [3] management personnel at Walgreens didn’t make Riley Whitelaw choose between extra-money while working with Joshua Taylor Johnson or a cut in her monthly stipend; [4] management personnel at Walgreens had in good-faith improved the working conditions of Riley Whitelaw by terminating the employment of Joshua Taylor Johnson; [5] management personnel at Walgreens were in good faith engaged in “proactively combatting workplace harassment.” As a matter of principle, the AACL unequivocally denounces violence committed against women irrespective of their racial backgrounds, their sexual orientations, their national origins, their religious affiliations, their disability status and/or their age groups. The AACL regrets the fact that more was not done to prevent the tragic June 11th 2022 murder of Riley Whitelaw at the Walgreens store in Colorado Springs (Colorado). The AACL also regrets the fact that more is not being done to prevent (in the future) similar tragedies to the one that transpired on June 11th 2022 at the Walgreens store in Colorado Springs (Colorado). It is the opinion of the AACL that Walgreens, the CCRD and the EEOC should bear some responsibility for the June 11th 2022 murder of Riley Whitelaw. For your information (FYI), the CCRD has concluded a work-sharing agreement with the EEOC, which they have previously disclosed to the AACL. About the June 11th 2022 Employment Related Murder of Riley Whitelaw at Walgreens. Michael Ayele (a.k.a) MICHAEL A. AYELE (A.K.A) W 20

40. REQUEST FOR RECORDS 04/04/2023 W Official Website on WordPress.: https://michaelayeleaacl.wordpress.com/2022/12/06/riley- whitelaw-sexual-harassment-before-11-june-2022-murder-title-vii-of-the-civil-rights-act/ MICHAEL A. AYELE (A.K.A) W 21