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New St. Paul's suit alleges 13-year-old was forced to drop out after alleging sexual assault

New Hampshire Union Leader

May 12. 2018 12:52PM

CONCORD — A new federal lawsuit accuses St. Paul’s School administrators of letting a “hypersexualized culture” exist which permitted a 13-year-old female student to be repeatedly raped and sexually harassed and then forced to leave school after being falsely accused of stealing the clothing of other coeds on campus.

The 31-page civil lawsuit, brought Friday in U.S. District Court, seeks a jury trial, maintaining the school is guilty of six federal counts and should be held liable for at least $450,000 in damages along with “lost wages, interests costs and other relief.”

Concord lawyer Chuck Douglas represents the now 18-year-old woman, referred to as Jane Doe in the complaint. She lives in Maryland.

Unlike many of her former St. Paul’s School peers, who come from wealthy families, Jane Doe’s parents are working-class people, the suit says.

The former St. Paul’s student is biracial with a European father and mother who is from India.

The suit maintained that St. Paul’s heavily recruited the girl and gave her a full scholarship.

The current cost of attendance is nearly $58,000 a year.

“The sexual assaults and harassment J.D. (Jane Doe) endured were sufficiently severe, pervasive and objectively offensive to constitute a hostile educational environment for her at SPS,” the suit maintains.

According to the suit, the girl started a romantic relationship in the fall of 2012 with an 18-year-old senior male student identified only as “M.L.” but there were no sexual relations until he forced himself on her.

The suit alleges the male student forced Jane Doe to perform oral sex on him multiple times.

The girl had to receive “extensive psychiatric treatment” after leaving St. Paul’s and finished high school in a “home and hospital program,” the suit states.

Archibald Cox Jr., president of the St. Paul’s Board of Trustees, said in a statement Friday night the school will soon respond in court to the complaint.

“We are learning about these allegations for the first time this evening. The board takes these allegations very seriously,” Cox said.

“Subject to the approval of, and in cooperation with, the Concord police and New Hampshire Attorney General, the board intends to retain outside counsel to investigate these allegations and take all appropriate actions.”

Attorney General Gordon J. MacDonald’s office is in the midst of a criminal investigation of St. Paul’s following two reports from the school’s own law firms that detail a decades-long history of former faculty and staff who sexually harassed students.

The lawsuit contains new details about the so-called “Senior Salute” that became a major focus of the criminal trial of Owen Labrie, a former student who was convicted of improper use of his computer to pursue female students on campus.


Jane Doe states in her lawsuit that she was in the same class with Chessy Prout, the student who accused Labrie of sexually assaulting her.

Prout has since written a book accusing St. Paul’s of inviting a culture that turned female students into sexual targets.

According to the lawsuit, Jane Doe reported the sexual assaults and harassment by other male students to top administrators, including Rector Michael Hirschfeld and Assistant Dean of Students Chad Green.

“Mr. Green and Rector Mike Hirschfeld forced Ms. Doe to withdraw from the school in the middle of the semester or be expelled,” the suit said.

Shortly after reporting the alleged rapes, administrators accused her of stealing a bag belonging to another student. She was then accused of stealing other items and ordered to undergo “counseling” with Dr. Theresa Ferns, the current vice rector for school life at St. Paul’s.

The suit says Ferns accused Jane Doe of “making up a story about being raped” and pressed her about these theft allegations.

According to the suit, Ferns and other administrators spoke to Jane Doe’s parents about the theft claims but never told them about the rape and sexual harassment complaints.

Saturday night St. Paul's School administrators released a second statement in response to the lawsuit's allegations: "Mr. Hirschfeld vehemently refutes that he ever failed in his responsibility to report an alleged sexual assault to Concord Police. This statement is false. He looks forward to cooperating fully with any investigation into such claims."

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