WHEREFORE, Plaintiffs pray for relief as follows: a. Defendant be served with process and answer herein; b. An award of damages in an amount to be established at trial, including, without limitation, reimbursement and prepayment for all of Plaintiffs’ tuition or related expenses; payment of Plaintiffs’ expenses incurred as a consequence of the sexual assault; damages for deprivation of equal access to the educational benefits and opportunities provided by UT; and damages for past, present, and future emotional pain and suffering, ongoing and severe mental anguish, and loss of past, present, and future enjoyment of life; c. An Order enjoining UT, along with all of its agents, employees, and those acting in concert therewith, from unlawful discrimination on the basis of sex, including the failure to address, prevent, and/or remedy sexual harassment; d. Injunctive relief requiring UT to redress its violations of Title IX including: 1) instituting, with the assistance of outside experts, and enforcing a comprehensive sexual harassment policy, including procedures for effective reporting of sexual harassment incidents, an effective and immediate crisis response, and an expanded victim assistance and protection program; 2) adopting a real “zero tolerance policy” under which there will be expedited proceedings and punishment proportional to the offense for violation of sexual harassment policies; 3) providing for an annual, independent review by the UT Board of Trustees, with the participation of outside reviewers, of Athletic Department compliance with the sexual harassment and recruiting policies and any other relief to be determined at trial requiring UT to comply with federal law under Title IX; and 4) enjoining UT from utilizing the TUAPA administrative process in sexual assault investigations. e. Attorneys’ fees pursuant to 42 U.S.C. § 1988(b); f. For the court costs of trying this action; g. For a jury to hear this cause of action; h. For costs to be taxed to the Defendant; i. For such other and further relief as the Court may deem proper; and, j. For pre- and post-judgment interest.
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k. Plaintiffs respectfully reserve the right to amend this Complaint to conform to