The woman who accused a former University of Colorado football coach of domestic violence alleges the school was aware of the abuse and took significant measures to cover it up — including deleting a key email and ignoring her calls, according to a legal document filed with CU.

The Daily Camera on Wednesday obtained from the university a notice of claim filed by the accuser’s New York-based attorney, Peter R. Ginsberg. Any person who wishes to sue a state entity must first file a notice of claim.

Ginsberg said that, at a minimum, the woman should be compensated at a rate of $5,000 per day for the period of wrongdoing, which spanned a relationship of about two years. That would equal about $3.7 million.

“We are prepared to have a jury determine an appropriate amount for the injuries — physical and emotional — sustained,” Ginsberg said in an email Wednesday.

CU spokesman Ken McConnellogue said there were statements and inferences made in the notice of claim that are not accurate, but he declined to specify them.

In the notice dated May 17, the claimant — whose name was redacted by the university — said she made multiple attempts to report former assistant football coach Joe Tumpkin’s alleged abuse and violence to head football coach Mike MacIntyre. Related Articles September 24, 2020 Boulder County targets CU’s COVID surge with ban on gatherings, stay-at-home order for 36 properties

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Around the beginning of December, the woman said she emailed MacIntyre asking him to call her about a “a very confidential matter” concerning Tumpkin. In the document, Ginsberg alleges MacIntyre’s assistant deleted this email, and claims the assistant had a “personal relationship” with Tumpkin and access to MacIntrye’s email account.

Ginsberg also writes that the abuse, alleged to have taken place between February 2015 and January 2017, happened in university-provided lodging at the Broadmoor Hotel and Resort during a CU-sponsored trip for a team dinner with boosters and regents, and other hotels in Boulder and across the country.

Verbal abuse also occurred on university property and on a cellphone that CU provided, according to the notice of claim.

“Both university employees and supervisors were aware of the abuse of (redacted) at certain times. University personnel did not properly report or address these issues,” Ginsberg wrote.

In the claim, the woman’s lawyer said Tumpkin’s abuse was aggravated by a drinking problem, which he alleges CU officials knew about — including drinking while driving — and that they did not properly report or address these issues.

Tumpkin, who was ordered to resign his position, also is the subject of an ongoing criminal prosecution in Broomfield over the domestic violence allegations.

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