Update #64: Complainants’ Final Submissions Sent to Tribunal on Friday, January 30. Read Them Here.

At the end of the day on Friday, January 30, 2026, Clea submitted the Complainants’ Final Submissions.

Part 1: Describes the statutory requirements for complainants to prove a claim under the BC Human Rights Code, describes how Member Prince should utilize the expert evidence of Dr. Laura S. Brown and Dalya Israel, Executive Director of Salal Sexual Violence Support Center (formerly WAVAW), describes on a high level how we proved UBC failed to be conversant with or consider the Code in any of its conduct, and previewed the layout of the following submissions.

Part 2: Recounted the evidence about how the University responded to reports of sexual misconduct by Dmitry Mordvinov, including descriptions of his earliest harmful or unprofessional (but not sexually violent) conduct of which the University was aware, and the general culture of tolerance of sexual misconduct at Green College. This took place from 2011 (when he first arrived) through 2014. The evidence we had available showed that my report to the History Department January 8, 2014 was the earliest report of sexual misconduct by a student. Subsequently, Green College received a report from Student E May 1, 2014 about his sexual misconduct conduct towards her, very shortly before Mordvinov raped Student B at the end of May, and by June 2014 all the key operational personnel had knowledge of accounts by Students E and B. The evidence showed they took no effective action, and my report was buried.

Then the narrative discusses actions by the History Department female graduate students in the summer of 2014, as we grappled with news of Student B’s rape. Caitlin Cunningham came to the conclusion that the University would not act unless she complained about Mordvinov’s sexual misconduct towards her (from 2013). She decided to submit a complaint to Monica Kay of the Equity and Inclusion Office (EIO) shortly after graduating in December 2014, and I joined her complaint. The bulk of the evidence about 2014 discussed how the University talked itself out of acting, at Green College, at History, at EIO, at Campus Security, and at VP Students Office.

I will note the chronological narrative is frequently interrupted for long stretches of analysis as we critique the University’s failure to act effectively at various points; if you are not familiar with the basics of what happened, this might be more challenging. Unfortunately it was necessary, because no one took ownership of the process and we had to review the evidence from many administrators pointing the finger at each other.

The narrative continues in roughly chronological order through the events of 2015, when the University’s first meaningful action comes April 30, 2015 banning Mordvinov from campus (but not from continuing his PhD progress, which it continued to fund). It acted after male graduate student Stephen Hay complained about the risk Mordvinov posed. History graduate students petitioned the Department to speak honestly about the fact that they were concerned about sexual misconduct and risk, which was received by Chair Tina Loo as a threat to her authority. In contrast, a similar petition in Green College had a better result because Green College Principal Mark Vessey was more inclined to let students speak openly, even though he partly created the problem because he refused to consider banning Mordvinov from residence. The fall of 2015 covers the Non-Academic Misconduct hearing process and the students working with CBC’s fifth estate. When the “School of Secrets” documentary aired in November and after the press conference held by myself, Caitlin Cunningham, and Kaitlin Russell, Part 2 concludes with discussion of the aftermath.

Part 3: Part 3 describes the individual remedies complainants seek for the 10 members of the Mordvinov Class of complainants. It contains some evidence not included in Part 2, mainly about the impact for each individual who testified.

Part 4: This describes the narratives of some members of the General Class. Unfortunately, due to the number of “Jane Doe” files – the documents related to General Class members for which we do not know who they are – Clea could not complete all of them in time, so we will supplement for the remaining Jane Does. The General Class members contained here are complete, including proposed individual remedies.

I will post the follow-on submissions for the General Class once it is received.

Part 4 begins with three General Class Members about which we have the most evidence. The first, Melanie Tremblay of Green College, reported sexual misconduct to Green College in 2014 and 2015 by another member of the College. While she did not testify, eventually she decided she wanted her name used by Member Prince in the final decision. We refer to her as “MT” in submissions. Second, we discuss the harrowing story of Tara McBryan of the Zoology Department, where she endured persistent stalking and harassment by a fellow Zoology graduate student that the Department never corrected; Ms. McBryan testified. Third, we discuss Lauren Fisher’s reports of sexual misconduct to various units at UBC, including residence staff, counseling, and medical, none of whom effectively supported them or expressed curiosity about the male UBC students who were abusing her. Mx. Fisher testified and uses she/they pronouns, preferring “they,” but the narrative uses she/her pronouns. We apologize for the error and will correct it with the Tribunal.

We continue with the Jane Doe files, the Class Members about which we only have documents, covering the stories of Jane Does 1, 2, 3A, 3B, 3C, 4, 5, 6. The Jane Doe files in the submissions so far, then, cover how the University reacted to reports of sexual misconduct at the following administrative units: (1) Green College, (2) EIO, (3) Campus Security, (4) VP Students, (5) the Zoology Department, (6) Residence Life, (7) Counseling, (8) Student Health, (9) Access and Diversity, (10) Department of Theatre and Film, (11) the Engineering Department, (12) the English Department, (13) the Irving K. Barber Learning Center, (14) the Department of Earth, Ocean, & Atmospheric Sciences, and (15) the Non-Academic Misconduct process run by Robbie Morrison in whatever office that is. Also, the RCMP on-campus detachment makes a brief appearance, but they were useless.

Part 5: Part 5 discusses the Complainants’ proposed systemic remedies.