WATERLOO REGION — Wilfrid Laurier graduate student Lindsay Shepherd is suing the university, two professors and a former employee of its diversity and equity office.

A statement of claim filed in Kitchener Tuesday lists Laurier Prof. Nathan Rambukkana, Prof. Herbert Pimlott and former diversity and equity office employee Adria Joel, along with the university, as defendants. Pimlott and Rambukkana are both on temporary leave of absence from regular duties at the university.

The claim alleges harassment, intentional infliction of nervous shock, negligence and constructive dismissal.

The lawsuit, which seeks $3.6 million in compensation and damages, claims Shepherd was "subjected to continuing abuse and a toxic climate from the university and its representatives" and has "suffered nervous shock as a result of the conduct of the defendants."

The suit also claims "attacks" on her "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 Masters graduate."

Shepherd is represented by Toronto-based employment lawyer, Howard Levitt.

None of the allegations have been proven in court.

"Wilfrid Laurier University has received notice of Lindsay Shepherd's statement of claim, which is one perspective of a legal matter issued in pursuit of a financial claim," the university said in a statement Wednesday.

"Laurier will vigorously defend against the statement of claim."

The university has yet to file a statement of defence.

In November, Shepherd made headlines after releasing a recording of her being reprimanded by Rambukkana, Pimlott and Joel, for showing her first-year communication students part of a televised debate about the use of gender-neutral pronouns. Included in the TVO show debate was University of Toronto Prof. Jordan Peterson, who argued against being forced to use them.

Shepherd was told a complaint was made against her and that exposing the students to Peterson's argument was transphobic and created a toxic classroom environment.

The university launched an independent investigation which found Shepherd did nothing wrong and that there had been no complaint. Rambukkana and university president Deborah MacLatchy issued apologies.

MacLatchy also launched a Freedom of Expression task force with the aim of crafting a guiding statement for the university. The statement was passed by the university's senate in late May.

"Since Ms. Shepherd first raised her initial concerns, the university has taken numerous measures to address the matter," the university said Wednesday. The statement points to the apologies, the creation of the task force and the independent investigation.

Shepherd said Wednesday her lawyer had urged her to file the suit soon after the November incident but, at that time, she was resistant and "didn't think it was necessary."

She changed her mind in May when a fellow graduate student filed a harassment complaint against her, as detailed in the suit. The matter is currently under investigation but it was "the final straw," she told The Record.

"The process of that complaint was in bad faith," she said, adding to a toxic environment that she alleges in the suit was created by other members of faculty in their treatment of her.

Some of the incidents Shepherd points to in the suit include an allegation that a professor (not listed as a defendant) attended her tutorial, offered emotional support to Shepherd's students and then sat at the back of the room for the entire class.

In another case, Shepherd was assigned, in her second semester, to work as a teaching assistant to a professor who had publicly showed support for Pimlott and Rambukkana. The suit lists a number of conflicts between Shepherd and the professor.

Another professor is alleged to have told Shepherd, in front of her classmates, that she could not use a laptop in class as the professor did not want her recording the lecture.

"I don't really care if I win or lose (the suit)," said Shepherd. "It's about seeing what direction our university is going to go and I think this lawsuit is going to be a big part of showing us that answer."

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Shepherd is expected to complete her studies at Laurier by the end of the summer, after she defends her major research paper.

lbooth@therecord.com, Twitter: @BoothRecord

- Who is Lindsay Shepherd?