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his Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 and 28

U S C § 1332 The parties are diverse and the amount in controversy well exceeds the statutory

limit, exclusive of interest and costs.

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enue is proper pursuant to 28 U S C § 1391 because all Defendants reside in

this district and a substantial part of the events or omissions giving rise to the claims occurred in

this judicial district.

F CTU L LLEG TIONS COMMON TO LL C USES OF CTION

Paul s Initial Thriving Experience at Columbia

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When Paul was accepted at Columbia University as a J ohn Jay Scholar f our years

ago, he and his whole family were delighted. At that time, Paul was a curious and open 19-year-

old with a wide range of interests and was eager to contribute to the community of one of the

most prestigious universities in the country with his multitude of interests, which he wished to

expand and develop in return. His parents were convinced that Columbia would be the place

where Paul would receive important stimuli for his academic and personal advancement. Paul and his parents imagined Colum bia University to he a place where Paul s critical thinking, his

alert mind, and his intellectual curiosity would he fostered, and where he would make

experiences that would nurture and strengthen him for life.

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In the first two of his years at Columbia University, before the events at issue in

this case began, Paul was extensively involved in student life at Columbia. He participated in

CO OP, ADP, lightweight rowing, the WBAR radio show, stage design, and student film

production group (an initiative started by Paul). He also had an on-campus paid job as an audio-

visual technician.