A Virginia Wesleyan College (VWC) student filed a lawsuit under the pseudonym,
Jane Doe. Jane Doe was invited from an alcohol free school party to a
party thrown by a peer advisor, where she was served a single shot of
alcohol laced with drugs. Ms. Doe left the party and was then brutally
raped by an upper-class lacrosse player.
The college employed a defense team to represent them in the case. In a
motion filed in July in the Norfolk Circuit Court, the defense asked Jane
Doe to provide a detailed account of her entire sexual history. Doe was
asked who she had had sex with “at any time,” as well as a
full list of all of the names.
Attorney Halperin Steps in as Counsel
Jonathan Halperin of the Halperin Law Center was featured in news articles
from Jezebel, Raw Story, and Huffington Post. In his Huffington Post interview,
he declined to provide the opposing counsel this information and need
the Court for a protective order.
Attorney Halperin stated the following:
"This is a drug-facilitated rape of a freshman woman on her third day of
orientation by a stranger. To ask the victim in discovery to name every
sexual partner and romantic interest she has ever had is irrelevant and
outrageous and totally inappropriate. It is intended to harass and intimidate
The defense lawyers for VWC insists that collecting this information is
not intended to harass Jane Doe or her claims of the lawsuit. They claim
they need the information to determine whether she was a virgin at the
time to justify whether or not the case warrants $10 million in damages
that Doe has asked of VWC. Attorney Halperin states it doesn’t matter
how much money is sought..The questions are simply “not couth.”
Attorney Halperin believes that the defendant’s questions are an
“unnecessarily broad interrogation into her sexual history……and
Jane Doe’s attacker no longer attends VWC, having been expelled of
the program in 2013 for sexual misconduct, a finding which was upheld
on appeal. VWC later allowed the rapist to “voluntarily withdraw”
however, “to help him further his education”.
Doe provided the following statement through Mr. Halperin:
“Invasive questioning about my entire sexual history only strengthens my
resolve to move forward in this case so others may not have to endure this."
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