Here's the Full Complaint in the 'Mattress' Lawsuit Against Columbia

Columbia University senior Paul Nungesser filed suit against the school yesterday, alleging that it refused to protect him from the harassment and hostile learning environment created by fellow student Emma Sulkowicz’s rape allegations against him, and her “Carry that Weight” performance art piece. Nungesser’s attorney, Andrew Miltenberg, has provided us with a full copy of the complaint in the suit.

The lawsuit, although it doesn’t name Sulkowicz as a defendant, tells the story of their interactions following the alleged assault from Nungesser’s perspective. It features lengthy excerpts from their Facebook messages and suggests that Sulkowicz accused him of rape because he wasn’t interested in dating her:

As is evident from Emma’s Facebook messages to Paul during the summer prior to their sophomore year, Emma’s yearning for Paul had become very intense. Emma repeatedly messaged Paul throughout that summerthat she loved and missed him. She was quick to inquire whether he was in love with the woman he was seeing abroad.

Thereafter, she continued purusing him, reiterating that she loved him. However, when Paul did not reciporcate these intense feelings, and instead showed interest in dating other women, Emma became viciously angry.

The suit accuses Sulkowicz of filing a “false complaint” with Columbia, and says she pursued a “scheme” to “brand Paul as a rapist.” It does not mention the other three sexual assaults Nungesser was accused of, including the two that went through the campus disciplinary system and found him not responsible.

We’ve asked Miltenberg why Sulkowicz isn’t personally named as a defendant in the suit, and will update if we hear back.

Update, 11:15 a.m:

Miltenberg sent the following statement to Jezebel:

This case is not about Emma Sulkowicz. It is about Columbia University as an institution, which was not only silent, but actively and knowingly supported attacks on Paul Nungesser, after having determined his innocence, legitimizing a fiction. Emma Sulkowicz is merely a footnote to this story. We already know that she cleverly crafted a story, and rode it to celebrity on the back of someone found not responsible.