Motion to Sanction

The complete motion to sanction (including Exhibits and defendant declarations) the CRD for their prosecutorial abuse, fabrication of facts and for filing a complaint with no legal or factual basis can be found here. An excerpt follows …


… Neither Iyer nor Kompella have ever held casteist views, and both have actively opposed the caste system in their personal and professional lives. Iyer has remained publicly irreligious for over twenty years. These uncontradicted facts were provided to Plaintiff during the investigation of Doe’s administrative complaint, and more recently in Iyer and Kompella’s

sworn declarations submitted in support of Defendants’ opposition to Plaintiff’s Motion to Proceed Using a Fictitious Name. (A copy of Iyer’s declaration is attached hereto as Exhibit B.) Those declarations, and the facts contained therein, conclusively disprove Plaintiff’s abstract “upon information and belief” assertions regarding Defendants’ adherence, or lack thereof, to the caste hierarchy. Moreover, and equally inconsistent of Plaintiff’s “information and belief,” the declarations provide, in part, that: