A man whom the University of Kansas expelled after finding he sexually harassed and stalked female students is now suing KU, claiming the university overstepped its bounds, and is asking a judge to nullify KU’s discipline.

The same man also filed a second lawsuit alleging he was discriminated against when he wasn’t hired for a student position with the KU police department, and further alleging that a KU police deputy chief violated his privacy and “stalked” him after he applied.

In addition to being expelled from KU in the fall 2017 semester, the man was banned from campus for 10 years and given a transcript notation indicating his expulsion was for “nonacademic misconduct,” according to his suit.

The man, through an attorney, filed the first lawsuit in December under the pseudonym John Doe. He filed the second lawsuit in March, without an attorney, using his actual name, Ray Kamila.

Both suits are pending in Douglas County District Court.

At a recent hearing — which Kamila himself did not attend — Judge Paula Martin considered Kamila’s request to make KU foot the bill for preparing a written transcript from the lengthy administrative hearing that resulted in his expulsion.

His attorney, Matthew Donnelly, said KU had quoted an estimate of $750 to $1,000 to prepare that transcript, and that his client was currently living in Oregon, working a part-time job and hoping to get back into school to continue his education.

“He does not have the funds to pay for that transcript at this time,” Donnelly said.

The judge ordered Kamila to pay for the transcript, siding with KU attorney Megan Walawender who said Kamila had retained an attorney for KU’s administrative process as well as an additional law firm, Donnelly’s, for the pending court case and must be able to afford the transcript.

Also, Walawender said, KU shouldn’t have to pay to fund litigation against itself.

“It seems odd for us to have to front state taxpayer dollars when a student is suing us,” Walawender said.

Walawender asked for permission for KU to file responses under seal because filings would include information about mental health counseling that Kamila and at least one of the women had received, which would be a violation of federal student privacy laws.

The judge denied that request, saying only counseling records could be sealed and the rest of the filings must be open because the public interest outweighed other privacy concerns.

KU spokeswoman Erinn Barcomb-Peterson declined to offer additional response outside of court proceedings regarding either lawsuit.

“The university doesn’t comment on pending litigation,” she said.

Donnelly did not offer additional comment, including responding to a question seeking explanation for why Kamila filed the first lawsuit under a pseudonym.

Harassment and stalking expulsion

KU has not filed a formal response to allegations in Kamila’s first lawsuit, but his suit includes more than 40 pages of documentation — including dozens of messages to the women, and their friends — from the KU student affairs process that led to his expulsion.

Kamila met both women at gatherings of different college Christian organizations, according to the documentation.

According to KU’s Office of Institutional Opportunity and Access investigation findings outlined in letters attached to the lawsuit:

After meeting the first woman in spring 2016, he sent her Facebook and text messages. She didn’t respond, but they continued.

“I have a crush on you,” one said. “I am thinking of you and I am praying for you as well. I will be giving you a list of my desires. I will also make sure to point things out to you about why do I like you or why am I attracted to you as well.”

The woman blocked him, and leaders of the organization, Called to Greatness, asked him to stop contacting her. He then sent messages to her via Facebook accounts with other names.

“I felt hurt seeing you a little distant, as I have let you known my interest towards you and I never had a chance to talk to you,” one said. “… I never realized what we have almost the same facial structure and same eye color as well.”

He also had flowers sent to her off-campus address, and she feared he learned her address by following her home without her realizing. When a relative of the woman asked Kamila to stop, he sent that person curse-laden texts.

KU security cameras captured him putting up fliers at Jayhawker Towers disparaging various people associated with Called to Greatness, calling them “pedophiles” and members of a “fake ministry.”

The woman told KU investigators the stalking made her feel unsafe on campus and at home alone, negatively affected her academics and caused her nightmares.

Kamila met the second woman at a local church college life group. After he told her he was lonely and didn’t have friends in Lawrence, she invited him to a Bible study saying there was “a great group of guys” he might be able to plug in with.

He began texting her messages, selfies, Bible verses and audio files of songs the woman said came from a religious website focused on marriage and sexual purity. Wanting to be kind, she sent some friendly responses but eventually replied, “Stop talking to me.”

Group leaders told him to stop contacting her as well and eventually asked him to stop attending the group. At one point, Kamila approached the woman in the library and asked her to step aside with him out of view of her friends and give him her email, which she did because he had told her he previously was a U.S. Army Green Beret and she didn’t know what he was capable of.

That woman said due to fear, anxiety and distress, she asked for accommodations for her finals, lost weight and became afraid to open her windows or blinds.

KU found that his actions were based on “sex and gender stereotypes,” and despite opportunities to change persisted with the “severe, pervasive” behavior and also retaliated against their friends who tried to help.

“The evidence presented during the hearing shows a pattern of behavior by you, where you are unequivocally told that your behavior is unwelcome, but you persist in your unreasonable belief that everything is a misunderstanding and that if you are able to continue contacting the person you have been told not to contact then it will be cleared up,” Tammara Durham, vice provost for student affairs, wrote. “This is particularly concerning.”

This is not the only time Kamila has been disciplined for harassing and stalking behavior, according to KU.

A letter from the university hearing panel says that he admitted to being expelled or suspended from Kansas State University for “disciplinary actions,” has a protection from stalking order issued by Sedgwick County District Court and two other unrelated no-contact directives at KU.

The hearing panel didn’t consider those in determining his responsibility for the harassment and stalking accusations at hand, according to that letter, but “these facts show a pattern of behavior and lack of understanding or ability to comport himself appropriately that only further confirms our sanction recommendation.”

KU told Kamila it would not reconsider its decision to expel him.

Kamila wants the court to review KU’s decision, reverse it and order KU to remove all references to the investigation from his official student records, according to his lawsuit. He also asks for “compensatory damages” without a specified amount.

Kamila says in the lawsuit that KU failed to establish that he was in its jurisdiction — specifically, on campus — when any of his alleged misdeeds took place, aside from the Jayhawker Towers and the library incidents.

“This claim is dubious considering that she was in a public place, with several of her friends, and that she had a friendship with Petitioner where they exchanged texts that often included bible verses and other encouragements,” the lawsuit says. “Nevertheless, these are the only two instances where KU introduced any evidence that Petitioner was on campus, within KU’s jurisdiction.”

He also alleges that because of the way KU’s student code is worded, KU has to show evidence he committed both sexual harassment and sexual violence to prove he violated it, which KU did not. Additionally, he alleges KU breached its contract with him as a student by prohibiting him from campus.

Lawsuit against KU police

In his lawsuit against Deputy Chief James Anguiano of the KU Office of Public Safety, who is also being defended by KU attorney Walawender, Kamila said he applied for a student job with KU police in 2014 and “did extremely well” during the interview.

However, Kamila said, he was passed over for the job in favor of a younger, white female student. “Petitioner was harassed and discriminated against … based upon Race, Sex, Color, Religion, National Origin, Veteran Status, Ethnicity and Disability,” his lawsuit says.

Kamila said in the suit that his “background religion” was Hindu and that he is of Asian descent and claimed that Anguiano asked him “to confirm whether he is a Muslim or not.” Kamila said he had a “service connected” physical disability and was asked to provide additional documents beyond a military records form to prove he had served in the armed forces.

“Petitioner find (sic) this to be extremely rude, disgusting, horrified, insinuating, and damning to Petitioner’s privacy and ethical values,” Kamila wrote.

He accused Anguiano of continuing to treat him poorly from 2014 until summer of 2017, including “stalking” him through security cameras in the Jayhawker Towers common area and entering his then-apartment there, threatening his “peace and privacy.”

The court file also includes a complaint Kamila filed with the Kansas Equal Employment Opportunity Commission. In the document, he alleges discrimination by KU as an institution and names Anguiano and around 20 others, including employees of KU Student Housing and Student Affairs, plus people affiliated with other community organizations including Called to Greatness, Justice Matters and Velocity Church.

KU has filed a motion to dismiss the second lawsuit.

According to KU’s response, certain employment discrimination claims should be dismissed because they occurred too long ago to be legally viable. Others should be dismissed because Kamila failed to present evidence that he was discriminated against because of his age or his military status, including not establishing he was in fact a member of the military.

Finally, KU said the law doesn’t allow Kamila to seek damages from Anguiano in his private capacity because he was acting in his professional capacity.

“Plaintiff’s claims stemming from state and federal employment claims must be dismissed as none provide for individual liability,” Walawender wrote in KU’s motion to dismiss the suit.