A pair of former students at John Jay College of Criminal Justice, a prominent educator of law enforcement officials, have sued the school and four of its staff members over an environment they say fosters rampant sexual coercion, discrimination, and abuse of students by their teachers.

The complaint reiterates a number of violations Naomi Haber, 25, and Claudia Cojocaru, 39, have previously outlined in interviews with the NY Post and the NY Times. Haber and Cojocaru contend that Ric Curtis, an anthropology professor who's been with John Jay for over three decades; Anthony Marcus, who chaired the anthropology department; Barry Spunt, who chaired the sociology department; and Leonard Dominguez, formerly an adjunct professor, created a kind of boys' club in their offices located in an annex of a 54th Street building, an area they called "the swamp."

The men allegedly used their influence to leverage vulnerabilities in the women's backgrounds—Haber came from a Hasidic community; Cojocaru was sex trafficked for years—the suit says, creating "a cesspool of sexism, misogyny, sexual harassment and illegal drug use" in the swamp, one that pervaded John Jay. That atmosphere, the suit continues, was "fueled by professors who used their positions of trust, seniority and inherent power-imbalance to prey upon female students' vulnerabilities and manipulate them to satiate their own sexual desires."

The swamp also served as a sort of drug den, according to the plaintiffs, where Curtis would sell and use drugs—including marijuana, cocaine, heroin, and LSD—to and with students and other faculty members.

All four defendants have previously denied the allegations.

The lawsuit catalogues the derogatory language Haber and Cojocaru allegedly heard the professors use in regards to the women they taught and worked with: "Cunts," "Bitches," "Stupid Bitches," "Lesbian Bitches," "Sluts," "Stupid Sluts," "Idiots," "Crazy," and "Psychotic." They allegedly branded women who were known to have made rape allegations as liars. The men reportedly bantered about how they would "tap that" or "hit that" if a woman "hadn't gotten fat," with one boasting that he "fucked [another student] so hard that she vomited," according to the lawsuit.

After the allegations initially came out in September 2018, the state opened an investigation into the professors; many of the points outlined in Tuesday's complaint will be familiar to readers who followed those reports. Namely, Haber and Cojocaru contend that Curtis, as the ringleader, plied students with alcohol and drugs in order to make them more receptive to his conduct, and pressuring them to perform sexual favors for his colleagues. He made inappropriate advances on both Haber and Cojocaru when they were students, the suit says, drunkenly grabbing Cojocaru from behind at a sociology professor's party and thrusting his erect penis into her back. Curtis and Dominguez allegedly urged the plaintiffs to have a threesome with Marcus, telling them "to show up at Mr. Marcus's apartment dressed in raincoats and with only lingerie underneath, as a reward to Mr. Marcus given that he had been working so hard," according to the suit.

In September, Haber told the Post that Marcus raped her at a conference, after publicly forcing himself on her at a department party. In the lawsuit, Cojocaru alleges that Curtis "groped, touched, and sexually assaulted her" at the Swamp in 2015, after encouraging her to drink to the point where she became "dizzy and nauseous." Additionally, the lawsuit says, Marcus assaulted Cojocaru in a hotel in October 2017, visiting her room under the pretense of picking up a copy of their presentation. While there, he jumped on her bed and when she tried to get away from him, she says, he grabbed her and started punching her in the head. "You all have this smart mouth," he allegedly told her, apparently referencing women as a monolith. "You fucking bitches. You think you're so smart."

Haber says she began complaining to the college about Curtis's and Marcus's conduct in 2015, only to have her reports go ignored. In 2016, when Haber and Cojocaru again tipped off a faculty member about the situation in the swamp, they say the response was, "I do not want to hear it." When each filed Title IX complaints with John Jay in 2018, the school and the independent investigators it retained deliberately misrepresented the Title IX reporting process, the lawsuit says. The administration allegedly subjected Cojocaru and Haber to multiple rounds of unnecessary testimony that obligated them to repeatedly rehash the offenses over the course of many months, while discouraging them from engaging legal counsel.

John Jay prohibits sexual relationships and sexual contact between faculty and students, and ultimately, as President Karol Mason explained in a May letter, its investigation did substantiate a number of Haber and Cojocaru's claims. Mason explained that she would be "seeking to terminate the three professors" involved (Dominguez was no longer at John Jay), but they continue to receive pay while on leave, per the terms of their union. In a statement to Gothamist, John Jay's director of media relations, Richard Relkin, said: "John Jay will promptly, thoroughly, and fairly investigate any allegations of misconduct and hold accountable anyone—without exception—who is found to violate our policies."

Read the full civil complaint here:

Complaint Against John Jay ... by on Scribd