MARCH 13, 2026 UPDATE: I have added the Addendum Submissions regarding the General Class at the end of this post. These were submitted February 17, 2026. They discuss eleven additional General Class Members. I have also updated my summary paragraph below. Note a previous version on this post said the addendum was posted March 9, but there was an upload error and the changes did not save at that time, and I only noticed it March 13.
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. [UPDATE: SEE BELOW] 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 have corrected 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, led by Mark Vessey, (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.
UPDATE: The addendum (see below after Part 5) of February 17, 2026 contains the stories of Jane Does 7, 13, 20, 21, 24, 25, 26, 29, 30, 31, and 32. These stories add to the picture; there is no other comprehensive view anywhere about what actual practices were at the University for any slice of time like this one. The Jane Does show how the University reacted through many of the above-listed administrative units, and: (16) St. John’s College, led at that time and now by History Department professor Henry Yu; (17) Human Resources, which sent the letter to Jane Doe 13’s counsel; (18) the AMS Players Club; (19) UBC Legal through its staff Kimberley Beck; (20) the Theatre Department; and (21) the poor conduct of the Chair of the UBCO NAM Committee, Shannon Dunn, who as of March 4, 2026 is Associate Vice-President of Student Housing and Community Services.
In my personal opinion, the General Class evidence showed egregious, discriminatory, and/or incompetent conduct by:
- Bob Shadwick, Colin Brauner, and Jeff Richards of the Zoology Department, who permitted Student X to sexually harass Tara McBryan. Their “solution” to her concern about performing lab work in the same facility as X was “was to ask Ms. McBryan to switch from Atlantic salmon to rainbow trout, and to grow her fish in static water in plastic garbage containers. [emphasis added] Ms. McBryan testified that instead of having access to a $7 million dollar facility as planned, she was reduced to using $200 worth of plastic containers and piping. She noted that there was no filtration in these containers so the nitrogenous waste was not removed and oxygen levels could not be maintained. She said that these types of fish inherently want to be in moving systems. She said that her fish were dying and that she did not consider attempting to grow them in garbage cans either ethical, or worthwhile scientifically given all the uncontrollable factors affecting her data.”
- The Theatre Department faculty who “had made it clear at the start of the program that conflicts between classmates were to be worked out by the students, and that going forward with such issues would be harmful to the group,” which caused Jane Doe 29, by a finding of the UBC NAM Committee, to endure two years of “being pursued by someone relentlessly sexually aggressive while being forced to closely interact with him on a daily basis as part of achieving her academic degree.” Jane Doe 30 also experienced harassment from the same individual. As with the Mordvinov Class, multiple students in the program witnessed the man’s misconduct and reported it to the University. No evidence of any action by Theatre Department faculty, or concern for their female students, was provided by the University.
- Shannon Dunn, who did not communicate with Jane Doe 31, to her great distress, causing Jane Doe 31 to personally call the then-President, Martha Piper, on a weekend to complain about being left in the dark about her complaint status. Ms. Dunn never bothered to communicate with Jane Doe 31 in any substantial way, causing Chad Hyson to take up communication duties after the Piper call, which he did not do for any other matters in the same phase. Notably, Ms. Dunn was partly responsible for the mishandling of Stephanie Hale’s case, but is not named in the Tribunal’s decision, probably because UBC did not call her as a witness. See
Hale v. University of British Columbia Okanagan (No. 5), 2023 BCHRT 121 (CanLII), <https://canlii.ca/t/k0gpj>
On the other hand, the General Class evidence shows meaningful supportive conduct by some members of the University:
- Gregory Dipple and Kurt Grimm of the Department of Earth, Ocean, and Atmospheric Sciences, who promptly supported Jane Doe 5, appeared to advocate for her interests with Monica Kay, specifically that she be supported in staying in a class without interacting with a man harassing her, and who appeared to follow up with her.
- Amy Stewart, a Residence Life Manager, who promptly reached out to multiple other University staff when Jane Doe 26 came to her (no other Residence Life staff acted like this), and Jane Doe 26’s goals of personal safety were met.
Part 5: Part 5 discusses the Complainants’ proposed systemic remedies.
General Class Addendum: Eleven additional Jane Doe Complainants’ stories were submitted February 17, 2026, over the University’s objection.
Glynnis Kirchmeier - and - Kirchmeier obo Others v. UBC 