The Lindsay Shepherd Affair: Update

Many of you will no doubt remember Lindsay Shepherd. She was the teaching assistant in the department of communications at Wilfrid Laurier University who was subjected to a three-member panel of inquiry after she showed a video taken from Canadian public television of me debating the compelled speech legislation introduced in Federal Bill C-16. She showed my discussion with Nicholas Matt, who held the opposite position. Here is part of the discussion in question:

"What do we do?"

The three-member panel included professors Nathan Rambuchana, her supervisor Herbert Pimlott, in charge of the master's program, and Adria Joel, manager of gendered violence and sexual assault prevention. Shepard taped the meeting and released it publicly, producing what I think was the biggest scandal that ever enveloped a Canadian university and certainly the only one in living memory that became news internationally.

"The thing is, can you shield people from those ideas? Am I supposed to comfort them and make sure that they are insulated away from this? Like, is that what the point of this is? Because to me, that is so against what a university is about. So against it."

I was not taking sides; I was presenting both arguments. So the thing is about this is if you're presenting something like this, you have to think about the kind of teaching climate that you're creating. These arguments are counter to the Canadian Human Rights Code. Ever since I know that you've talked about C-16, ever since this passed, it is discriminatory to be targeting someone due to their gender identity or gender expression.

"So bringing something like that up in class not critically, and I understand that you're trying to like—"

"It was critical."

"How so?"

"Like I said, it was in the spirit of debate."

"Okay, and the spirit of the debate is slightly different than being like, 'Okay, this is a problematic idea that we want to unpack,' but that's taking sides."

"Yes, like it's taking sides for me to be like, 'Oh look at this guy, like everything that comes out of his mouth is BS, but we're gonna watch anyway.'"

"Okay, so I understand the position that you're coming from and your positionality, but the reality is that it has created a toxic climate for some of the students. You know, it's how many—it’s great—like how many?"

"Okay, one."

"Yeah, it may speak."

"I have no concept of how many people complained, like what their complaint was. You haven't shown me the complaint."

"Yes, I understand that this is upsetting, but there's also confidentiality. At the end, confidentiality matters."

The number of people's confidential.

"Yes, although the university apologized publicly for its treatment of Shepherd, as did Rambuchana, it is not clear at all that the powers that be, so to speak, learned their lesson, and the mistreatment of Shepherd not only continued but arguably intensified. So she decided to press her case legally and presented a statement of claim against the three and Wilfrid Laurier early in the second week of June. It lists in painful detail the many ways that this situation was mishandled during and after the initial inquisition."

I also discussed the situation with Howard Levitt, Shepherd's lawyer. I decided that Wilfrid Laurier had learned very little from its public embarrassment and that Shepherd's claims were valid, justifiable, and necessary, including her statement that her future lack of employability in academia was improbable to say the least.

"I've been on hiring committees, and I can tell you that even then, the slightest whiff of scandal is enough to disqualify a candidate."

In consequence, not only did I decide to read and post the entirety of Shepherd's claims, which I will do in a few minutes, I also decided to launch a claim of my own against the same defendants. I thought that two lawsuits might make the point better than one. I'll read some of my claim after Shepherd's, and you can all make up your own minds about the suitability of this course of action.

Ontario Superior Court of Justice
Between: Lindsay Shepherd, Plaintiff
And: Nathan Rambuchana, Adria Joel, Herbert Pimlott, and Wilfrid Laurier University, Defendants

Statement of Claim:

1. To the defendant, a legal proceeding has been commenced against you by the plaintiff. The claim made against you is set out in the following pages. If you fail to defend this proceeding, judgment may be given against you in your absence and without further notice to you.
2. Nathan Rambuchana and to Adria Joel and to Herbert Pimlott and to Wilfrid Laurier University claim the plaintiff claims the following against the defendants, individually and cumulatively:
   • Five hundred thousand for the tort of harassment.
   • Five hundred thousand for the tort of intentional infliction of nervous shock.
   • Five hundred thousand for the tort of negligence.
   • One hundred thousand for constructive dismissal.
   • Aggravated damages in the amount of five hundred thousand.
   • General damages in the amount of five hundred thousand.
   • Punitive damages in the amount of a million dollars.

The plaintiff resides in the town of Waterloo in the province of Ontario. The defendants, Herbert Pimlott and Nathan Rambuchana, are professors at the defendant Wilfrid Laurier University. Pimlott was the coordinator for the master's program of the university, and Rambuchana, at the relevant time, was the professor for the course which Shepherd was a teaching assistant for. Both had considerable influence over the plaintiff's employment as a teaching assistant and her status as a master's student.

The defendant Adria Joel was at all relevant times acting manager of the university's diversity and equity office in charge of gender violence prevention. The defendant university is a creature of statute created pursuant to the provisions of the Wilfrid Laurier Act. The university is vicariously liable for all of the conduct of the individual defendants referred to herein and at all relevant times created an environment supporting, facilitating, acquiescing to, and implicitly, and sometimes explicitly, endorsing that conduct.

The constituent statute of the university, the Wilfrid Laurier Act 1973 as amended 2001 and 2016, in providing the fundamental jurisdiction and authority for the university to operate states as its object in section four that the objects of the university are for the pursuit of learning through scholarship, teaching, and research within a spirit of free inquiry and expression. The university has no other object and no jurisdiction to operate otherwise.

The university has no other object and no jurisdiction to operate otherwise. Pursuant to section five, powers of the university, the Act further states that the university has all powers necessary and incidental to the satisfaction and furtherance of its objects as a university. The constituent statute creating and empowering the university provides it with no other power or authority.

Shepherd was, at all relevant times, a student in the university master's program pursuing her master's degree and employed as a teaching assistant for a course under Rambuchana and, following that, under Professor Judith Nicholson. As a teaching assistant, Shepherd supported a class taught by Professor Rambuchana. She was generally responsible for teaching two groups of approximately 25 students, was assigned topics, and was entitled, pursuant to the policies of the university and of Rambuchana, to devise her own curriculum.

She was an indifferent mentor who had only met with Shepherd twice about his course and only then briefly. Ironically, given his complaint against her, as delineated below, he provided her with very limited direction as to the content to provide to her students in his classes.

The topic for one of her communication classes held on November 1st, 2017, was grammar. She taught three classes that day. Shepherd introduced the topic of the grammatical correctness of gender-neutral language in the evolution of various languages and to facilitate discussion on the subject, showed a few minute extract from a TV Ontario program moderated by Stephen Pakin consisting of a debate between Professor Jordan Peterson of the University of Toronto psychology department and Nicholas Matt from the University of Toronto's sexual diversity studies program.

Peterson and Nicholas Matt were debating compelled gender pronouns. Peterson argued against being required to use these new words, which he argued had not developed organically. Matt took an opposing position. Shortly following that class, Rambuchana ordered her to attend a meeting the very next day with himself, Pimlott, the program coordinator for the entire master's program, and Adria Joel, acting director of the diversity and equity office.

Both Rambuchana and Pimlott had considerable authority over Shepherd's fate at the university, and apparently so did Joel. Shepherd had never been called into such a meeting. Indeed, Rambuchana to that point had barely acknowledged her existence. At this session, all three lambasted Shepherd, viciously attacking her personally, falsely alleging that there had been a complaint or complaints about her tutorial, and insisting that by playing the TV Ontario clip, she had been threatening to her students.

Rambuchana claimed that her showing this TV Ontario clip breached the Charter of Rights and Freedoms and Federal Bill C-16, which does not even govern provincially regulated universities, created an unsafe learning environment, and was illegal. Shepherd was accused of targeting trans folks, even though she had chosen no side, had up till that point disagreed with what she understood to be Peterson's perspective, and presented the arguments in the debate neutrally.

Rambuchana attacked and slandered Peterson, claiming that he was part of the alt-right, and that playing a clip of Peterson without first providing any previous context to the students was like neutrally playing a speech by Adolf Hitler. Shepherd argued that doing as he asked would be taking sides and that was not her role. She was then further rebuked for taking that position.

At various points during that almost hour-long vicious and abusive attack, Shepherd was reduced to tears. Ironically, rather than being a present-day personification of Adolf Hitler, as Rambuchana implied, Jordan Peterson has spent decades educating his students about the evils of the Holocaust and specifically, as part of his psychological teachings, has studied and taught how individuals degenerate ethically to the point where they take part in atrocities.

During the meeting, Shepherd was effectively attacked as a protege and supporter of Peterson. Pimlott continued to libel Peterson, explaining that people like him live in a fantasy world of false conspiracy, and accusing Shepherd of being an agent of those ideas because she had neutrally shown this video with its opposing viewpoints. Rambuchana falsely but imaginatively claimed that Shepherd herself was targeting people based on their gender identity or gender expression and, in doing so, had violated the Federal Human Rights Code of Bill C-16, although Shepherd's conduct was in no way violent of that or any law.

Shepherd asked the individual defendants whether her job as a teaching assistant was to shield her students from debate and ideas. Rambuchana asserted that it was, and then accused her of targeting students due to their gender expression and identity. When Shepherd pointed out that she had not taken sides in this debate, the three rebuked her for creating a toxic climate. The three refused to advise Shepherd what the complaint was or who complained, claiming that even the number of complaints was confidential.

As was subsequently ascertained, there had been no complaint at all. Shepherd protested that she did not understand how her teaching methods constituted any disservice to the university since the ideas in the video were already part of social currency. Joel responded, without any foundation, accusing her of spreading transphobia. Rambuchana added to Joel's attack by essentially comparing her actions to white supremacy.

Contrary to the allegations of the defendants at this meeting, Shepherd conducted herself at this seminar precisely as her role required and singularly represented the principles of the Wilfrid Laurier University Act. For this, she was viciously attacked by Rambuchana, Pimlott, and Joel. They continued to abuse her even after she began sobbing, accusing Shepherd of causing harm to unnamed students.

Shepherd apologized for crying during the meeting, pleading, "I am stressed out because, to me, this is wrong. So wrong," noting that the very spirit of the university is to challenge ideas that you already have and reminding them that she had not taken any side or position.

The meeting concluded with Shepherd being advised, even after she promised to show no further videos of Peterson or anything of the like, that she now had to run all of her seminar notes past Rambuchana to obtain specific approval for any future clips of anyone that she intended to show and that Rambuchana might have to sit in on her future classes. She was prohibited from showing any further videos. Finally, they suggested to her that her job might be in jeopardy.

The conduct of the defendants was objectively outrageous and flagrant. They had reckless disregard for the fact that the foreseeable consequences of their conduct would cause Shepherd to suffer emotional stress, which it did. There are various policies of the university which constitute a contract between the university and its members, including Shepherd. Article 1.01 of the procedures relating to the prevention of harassment and discrimination policy 6.1 of the university notes that informal resolution possibilities, as well as emotional, academic, and departmental supports, will be explored. None of this occurred.

It also noted in Article 1.02 of the procedures relating to the prevention of harassment and discrimination policy 6.1 that if the concern falls outside of this policy's jurisdiction or could be more appropriately dealt with elsewhere, the individual will be referred to the appropriate office. That also did not occur. Under Article 3.02 of Policy 6.1, the office of dispute resolution and support will determine whether a complaint may go forward. Article 3.04 states that the office is available to provide guidance on the preparation of a complaint or response to a complaint; that guidance was not provided to Shepherd.

Article 5.01 of policy 6.1 states that an investigation may be required when other efforts to resolve the complaint have not been successful or not appropriate. In the complaint by Jackson referred to below, no other efforts to resolve the complaint were considered before proceeding to the formal investigation of Shepherd.

Article 8.03 of policy 6.1 states that Wilfrid Laurier University's prevention of discrimination and harassment policy is not intended to inhibit academic freedom; it was used by Rambuchana, Joel, and Pimlott for precisely that purpose. Article 8.05 notes that the university may take disciplinary action against those who make allegations of harassment or discrimination which are reckless, malicious, or not in good faith. Although Pimlott, Rambuchana, and Joel had acted recklessly, maliciously, and in bad faith, and it was ultimately determined by the university that this meeting never should have occurred, no action has been taken by the university against them, and Shepherd was provided no protection from their predations.

The prevention of harassment and discrimination policy provides in Article 1.02 that each member of the campus community is responsible for helping to create an environment that promotes mutual respect and understanding for the dignity and rights of others. This policy was violated by Rambuchana, Pimlott, and Joel. The prevention of harassment and discrimination policy defines workplace harassment in Article 2.04 as engaging in a course of vexatious comment or conduct against a worker in the workplace that is known or ought reasonably to be known to be unwelcome, or workplace harassment. This provision too was violated by Rambuchana, Pimlott, and Joel.

Article 2.07 defines a poisoned environment as where harassing or discriminatory behaviors are severe and/or pervasive and cause unreasonable interference with a person's study or work environment. A poisoned environment may be created; a poisoned work or learning environment is one that is intimidating, hostile, and/or offensive. A poisoned environment can arise even from a single incident. It may be created by the comments or actions of any person, regardless of his or her status. Rambuchana, Pimlott, and Joel created a poisoned work environment for Shepherd and thereby breached the university's contractual obligations to Shepherd.

Article 4.04 states that the university will take appropriate steps to fairly investigate and respond to allegations of discrimination and/or harassment in accordance with the procedures relating to this policy. No such steps were taken. Instead, Shepherd was wrongly attacked by the members of the administration until public and alumni outcry forced the university to retreat from its position.

Following this meeting being publicized, McClatchy, president of the university, was interviewed on The Agenda by Steve Pakin, the same show from which the clip of the debate between Dr. Peterson and Matt was taken. She was repeatedly asked by Pakin whether Shepherd had done anything wrong by showing this clip from his earlier show; McClatchy effectively defended the conduct of Rambuchana, Joel, and Pimlott. She refused to acknowledge that Shepherd had not acted improperly, despite Pakin's continuing to press her on this.

Shepherd had the foresight to tape her inquisition when it began, and after the outrage from the public and alumni erupted, the president of the university, Deborah McClatchy, and Rambuchana issued apologies. In Rambuchana's forced apology, he continued to lie—still insisting that there had been a complaint and that he had been doing his duty by addressing it. It was only when public and alumni outrage grew that McClatchy was ultimately forced to admit that what happened to Ms. Shepherd in the meeting was shameful and that the material she showed was entirely appropriate.

That was a quote. This was only after an investigator found that there never had been any complaint, formal or informal, and that Rambuchana, Pimlott, and Joel's statements to the contrary were false and deceitful. The university admitted in this statement from its president that this meeting never should have happened at all. No formal complaint, nor even an informal concern relative to university policy, had been registered as to the screening of the video.

The president, only when besieged, acknowledged that these errors in judgment were compounded by the misapplication of the university's policies and procedures. The basic guidelines and best practices on how to appropriately execute the roles and responsibilities of staff and faculty were ignored or not understood. The procedures on how to apply university policies and under what circumstances were not followed, and that the institutional failure allowed this to happen.

The president noted that, as there was institutional failure, the responsibility ultimately started and ended with her. She further acknowledged that Ms. Shepherd was targeted with vitriol by members of the university. McClatchy admitted that Shepherd was involved in absolutely no wrongdoing and publicly stated that the university was taking action to ensure that this did not occur again, a claim that was and remains entirely false.

Shepherd has never received redress of any kind, nor has she been consulted about the input that this treatment has had on her and her career prospects. Instead, she was subjected to continuing abuse and a toxic climate from the university and its representatives, as described below.

In McClatchy's apology on November 21, 2017, she states that, "supports were in place to support student involvement in a situation who are targeted with extreme vitriol through the situation." Yet she and the university offered Shepherd no such support.

In McClatchy claiming to be troubled by the way "everyone" involved in the situation was targeted with extreme vitriol, she showed the same and equal concern for Shepherd's predators as for Shepherd herself. The president also acknowledged that the rationale for invoking the gender and sexual violence policy did not exist, that it was misapplied, and that this was a significant overreach.

Shepherd relies on McClatchy's admissions herein. McClatchy claimed that "Laurier is committed to the abiding principles of freedom of speech and freedom of expression." Her conduct throughout entirely betrayed that goal. In Rambuchana's disingenuous apology to Shepherd on November 21, 2017, he stated, "Well, I still cannot discuss the student concerns raised about the tutorial." But no student concern had even been raised about the tutorial prior to his and his co-defendants bullying of Shepherd.

He acknowledged that his meeting with a panel of three people would be an intimidating situation for Shepherd and would not have invited a productive discussion. Rambuchana's apology claimed that he "did not do enough to try to support her, Shepherd," when he did absolutely nothing at all but instead attacked her. Following the public outcry, the next time Shepherd met with her students, the chair of the department of communications, Peter Urquhart, attended that tutorial and offered Shepherd's students, but not Shepherd, emotional support, suggesting that they would be welcome to go to the campus wellness center.

He sat at the back of the room for the entire tutorial, effectively shutting down any discussion on the issue and undermining Shepherd's role in her classroom. Urquhart proceeded on behalf of the university to publicly insult Shepherd. When asked by email by Maclean's magazine why he appeared in her class on that day, he responded, "I assume she recorded it; why not ask her for the recording?" He then sent Maclean's a second email: "Sorry, you're a pro; I should have assumed that you've already heard that particular recording."

Using his position of power and authority over Shepherd to intimidate and embarrass her publicly, Professor Alicia Slowinski, who Shepherd was taking a master's course from, asked in front of the class for Shepherd to put away her laptop and then said in front of other master students that she gave this instruction because she did not want to be recorded, even when Shepherd assured her that she was not recording the class, further alienating and creating a toxic environment for Shepherd.

Following these events, Rambuchana's course ended, and Shepherd was assigned to be the teaching assistant to Professor Judith Nicholson, a professor of communication who had publicly taken a negative position against Shepherd prior to Shepherd being assigned to her. Before that semester even started, Nicholson had signed an open letter supporting Pimlott and Rambuchana. This made the university assigning Shepherd to her tutelage entirely inappropriate, created a poisoned environment for Shepherd, and made it impossible for her to succeed.

Shepherd's apprehensions about Nicholson's lack of objectivity toward her were quickly borne out. On three occasions during their relatively brief dealings, Nicholson, without provocation, harassed and abused Shepherd and deliberately created difficulty for her. From the outset of their meeting, Nicholson told Shepherd that it was her "academic freedom" and that no one is permitted to make the university look bad, implying that Shepherd had improperly done so.

On the second occasion, she sent out a course syllabus with a territorial acknowledgement, i.e., a reference to the Aboriginal tribe that had once been on the land which Wilfrid Laurier was on. Shepherd, considering this irrelevant to the syllabus and a ludicrous act of political correctness and virtue signaling, cut out that part of the note and tweeted it, noting that such acknowledgements were now even on the syllabus of university courses.

Nicholson demanded in front of the other teaching assistants that she delete her tweet. When Shepherd protested that all she was tweeting was the university logo with the course name and territorial acknowledgement, Nicholson threatened to take her to the dean if she did not remove it. Nicholson also absurdly claimed that this territorial acknowledgement was her intellectual property. She proceeded to complain to the dean about Shepherd's tweet in an attempt to further endanger Shepherd's position in the university.

The dean informed Nicholson that the acknowledgement was not her intellectual property and called an urgent meeting with the two departments with which Shepherd was associated—the communication studies and the cultural analysis and social theory departments—at least in part to discuss these issues. It was clear that if Shepherd had tweeted positively about the land acknowledgement, she would not have been in difficulty with Nicholson.

The third occasion was in March 2018 when Shepherd needed to reschedule her last class of the year and utilize polling software with a link to available alternate days for her class to fill out their available alternate dates. When Shepherd found times that all of her students were available to meet, she emailed Nicholson to seek her approval for the new dates. Nicholson reprimanded her, copying two deans, claiming falsely that Shepherd had moved these classes without Nicholson's consent in advance, even though the letter was just such a request and the request on its face was premised on Nicholson's consent.

When Shepherd advised Nicholson that she never had any intention of changing the date without Nicholson's approval, which was why her letter explicitly requested that approval, Nicholson canceled Shepherd's tutorial entirely. This was despite the fact that alternate dates were available for Shepherd and her students to attend. Nicholson instructed Shepherd's students to attend sessions of the other teaching assistants on dates which were largely coincident with dates which Shepherd and her students had arranged. Since this was to have been Shepherd's last class, she never saw her students again.

Ethan Jackson, a transgender activist who has attacked Shepherd throughout the events described herein, launched a formal, patently frivolous harassment complaint against her, to which even after Ms. Shepherd had completed her coursework at the university, so she would not see Jackson again. The university responded by proceeding with a formal investigation despite its inherently vexatious, bad faith, and frivolous allegations, which, pursuant to the applicable policies, the university should not have proceeded with. Jackson had an online crowdfunding page seeking a sex change operation, which was initially denied because of his mental health issues.

Additionally, Jackson was banned from the University of Waterloo campus in 2013 for protesting and de-platforming a member of parliament who was to give a speech on abortion by dressing up as a giant vulva and yelling. Jackson was invariably hostile to Shepherd.

Jackson's allegations against Shepherd were that a) she was on her telephone during one class and purportedly disengaged from participation in that class; b) Ms. Shepherd had made four tweets with screenshots from Jackson's controversial social media account; c) Shepherd responded to Jackson walking into the printing room and angrily ordering her to leave the room and cease using the communications department printer, which she required for her communications coursework, by referring to him as "petty and pathetic"; d) when Shepherd and two others were putting up posters for a Laurier Society for Open Inquiry meeting, he claimed that they had followed him and his colleague as they were walking around the halls, and that Shepherd's posters had signage which he found offensive, posters which he acknowledges removing from the walls without authorization.

The complaint of Jackson was made maliciously after classes were over for the year at a time when he and Shepherd would not ever be interacting again, since Shepherd is not enrolled in Laurier courses for the following session. Despite Jackson's complaint being inherently self-contradictory and ludicrous, the university not only proceeded to summon Shepherd for an investigation, but threatened her with repercussions if she disclosed Jackson's complaint to anyone.

The attacks on Shepherd have rendered her unemployable in academia, resulting in her abandoning her previous ambitions of obtaining her PhD or even teaching at a university. As a master's graduate, Shepherd has suffered nervous shock as a result of the conduct of the defendants, which was the foreseeable and intended result. In the alternative, it was the reasonably foreseeable outcome of their conduct, and the defendants were negligent in their treatment of her.

So that's Shepherd's claim. As I said, after I reviewed this and talked in detail to Shepherd's lawyer, I concluded that Wilfrid Laurier had not learned what needed to be learned and launched a claim of my own this week. It reads in part:

"The plaintiff—that's me—claims against the defendants Nathan Rambuchana, Herbert Pimlott, Adria Joel, and Wilfrid Laurier University the following:

• Five hundred thousand for defamation.
• Five hundred thousand for injurious falsehood.
• Five hundred thousand in punitive damages.
• Pre-judgment and post-judgment interest in accordance with the Courts of Justice Act.
• Costs on a substantial indemnity basis and such further and other relief as counsel may advise and this honorable court may deem just."

The plaintiff's claim against Rambuchana, Pimlott, Joel, and the university: defamatory statements on YouTube on or about November 2, 2017, Rambuchana ordered his then-teaching assistant Lindsay Shepherd to attend what turned out to be a disciplinary meeting with himself, Pimlott, and Joel to discuss her having shown an extract from a TV Ontario program to her students.

The TV Ontario program moderated by Steve Pakin consisted of a debate between Peterson and Nicholas Matt. At the meeting on or about November 2, 2017, Rambuchana, Pimlott, and Joel each made numerous defamatory statements about Peterson, all of which the others endorsed both expressly and implied. The meeting's content has since been posted online on the video-sharing website YouTube and is available on the internet, where it is open to the public and easily accessible by anyone who wishes to view its content.

I'm skipping a bit here. At the meeting on or about November 2, 2017, Rambuchana, Pimlott, and Joel falsely and maliciously made numerous defamatory statements about Peterson, including but not limited to the following:

Defamatory statements made by Rambuchana:
a) Peterson identified student protesters by posting their social media accounts for the purpose of other people bullying and threatening them online.
b) Peterson is basically debating whether or not a trans student should have rights.
c) Peterson's position would be the equivalent of debating whether or not a student of color should have rights or should be allowed to be married, contrary to the Charter of Rights and Freedoms.
d) Peterson has engaged in the targeting of trans students, giving out their personal information for the purpose of having them attacked and harassed so that death threats will find them. This is something that Peterson has done to his own students and to other students.
e) Playing a speech by Peterson is basically like playing a speech by Hitler.
f) Peterson's opinion is like alt-right opinion, white supremacist opinion, anti-trans opinion, anti-gay opinion, anti-woman, misogynist opinion.
g) Peterson's view is whether trans people are people or not.

Defamatory statements made by Pimlott:
a) Peterson is academically suspect to say the least; he does not have the substantial academic evidence to be a credible person.
b) Peterson's positions don't have credible evidence, just like Charles Murray with his race claims of white superiority.
c) Peterson brings hatred and targets groups.
d) Peterson exhibits charlatanism.
e) Peterson has nothing really that is credible in terms of research.

Defamatory statements made by Joel:
a) Peterson's position is causing harm to trans students by framing their identity as invalid or their pronouns as invalid, contrary to the Ontario Human Rights Code.
b) Peterson is spreading transphobia.

Now I'm skipping ahead a bit again. The said words in their natural and ordinary meaning and the connotation of the comments, obvious to any reader, were meant and were understood to mean that Peterson is comparable to Adolf Hitler, the greatest despot in world history, deliberately spreads hatred both generally and in particular to students, is a member of the alt-right, is unfit to be a professor, breaches the code of ethics of his profession and university, is a white supremacist, has and expresses opinions which are uninformed and uneducated, is sexist, is misogynist, is racist, is homophobic, is transphobic, is a deplorable person, is incompetent, is a reprobate, lacks integrity, lacks the appropriate ethics to be a psychologist and professor, is a bully, and abusive towards students, wants to deprive minorities of any rights, organizes attacks, even death threats on students, breaches Canadian law, dehumanizes certain of his students, and lacks credibility and credentials.

The statements made by Rambuchana, Pimlott, and Joel infer all of the above, including but not limited to that Peterson is unsavory, sexist, misogynist, dangerous, racist, homophobic, transphobic, analogous to Adolf Hitler, and incompetent in his profession as an author, teacher, and professor and were false and specifically designed to impugn his reputation. These defamatory statements were malicious and designed specifically to damage his personal and professional character as a professor, author, lecturer, and public intellectual.

Well, you get the picture. That's the end of that. I'm hoping that the combination of the two lawsuits will be enough to convince careless university professors and administrators blinded by their own ideology to be much more circumspect in their actions and their words. We'll see how that plays out.