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.

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.

Contact via Facebook

Around Dec. 9, Ginsberg wrote, the accuser contacted MacIntrye’s wife via Facebook and said she needed to talk to her husband about Tumpkin. When MacIntrye called the woman later that day, she told him about the pattern of abuse and violence and also disclosed that she feared another woman was in danger, providing that woman’s location, according to the documents.

“Coach MacIntrye assured (redacted) that he believed her and would address the issues immediately,” Ginsberg wrote. “The following day, Coach MacIntrye told (redacted) that he had discussed the issue with Athletic Director Rick George.”

Afterward, Ginsberg wrote, MacIntrye blocked the accuser’s calls and did not properly report the alleged abuse.

George, MacIntrye and MacIntyre’s assistant were not adequately trained to report and address domestic abuse issues, Ginsberg argued in the notice of claim.

Throughout the alleged abuse, the woman says she suffered numerous physical injuries at the hands of Tumpkin, including multiple contusions, scratches, neck injuries from attempts at strangulation, stitches and the removal of a dental implant leaving her with a tooth missing for more than three months.

The woman also claims to suffer from psychological trauma from the abuse and “as a result of the lack of supervision and care by university personnel.”

“Mr. Tumpkin’s abuse, and the university’s failure to address and stop such activity, is a part of a history of ignoring and, indeed, covering up abusive behavior by people associated with the university football team,” Ginsberg wrote.

CU won’t release report

McConnellogue, the CU spokesman, said the university firmly believes no one should be subjected to domestic violence.

We’re not going to respond to particulars of the notice at this time.” he said.

Attempts to obtain comment from the athletic department regarding the allegations of email deletion and ignored phone calls were redirected to McConnellogue, who said the public report based off an external investigation into university officials’ failure to report the domestic violence allegations will cover those matters.

The university denied a Colorado Open Records Act request from the Camera for the full report, which was completed about two weeks ago. McConnellogue said the public would never see the full report, citing legal and personnel matters.

At a CU Board of Regents meeting last week, regents passed the decision on how to handle the university’s failure to report the domestic violence accusations to CU President Bruce Benson.

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

Elizabeth Hernandez: 303-473-1106, hernandeze@dailycamera.com, twitter.com/ehernandez