Lying on Letterhead
Time to set the lies on FIRE.
I’m very happy to share that the Foundation for Individual Rights and Expression (FIRE) has taken on my case for public advocacy. FIRE defends free speech and due process in higher education and beyond. They jumped in as soon as I sent them the story.
FIRE's mission has nothing to do with gender. What’s striking is that even without the harassment and discrimination, Eastman’s violations of academic freedom and due process were severe enough to warrant FIRE's full involvement.
It shows how deep the culture of silence and abuse is. Eastman—and many places like it—will break every rule in the book to preserve it.
It's time for that to end.
You can take action by:
Going to thefire.org/rochester to contact the university and demand accountability.
Amplifying the story on this platform and others.
Becoming a free or paid subscriber.
The text below is taken directly from my complaint against the Eastman School of Music, submitted to the New York State Division of Human Rights under penalty of perjury. I filed the complaint after being illegally expelled from the school with no process, warning, or prior disciplinary action.
Paragraphs are numbered as they are in the original filing. Redactions are marked in brackets. Some pronouns have been changed for anonymity.
Evidence of Unlawful Expulsion
Summary
1. On February 25, 2025, Matthew Ardizzone, Associate Dean of Graduate Studies, sent me an expulsion letter from the Eastman School of Music. Kate Sheeran, Dean of the Eastman School of Music, and Reinhild Steingröver, Associate Dean of Faculty Affairs, were copied.
2. The expulsion immediately terminated my standing in the Doctor of Musical Arts degree in orchestral conducting, which I began in August 2023. It came with no warning or prior disciplinary actions.
3. The letter was undated. In it, the school cited a single policy—without identifying the policy’s source or contents—then bypassed all the requirements of the policy they invoked.
The letter contained numerous demonstrably false allegations and offered no process for appeal. (See Doc C1: Expulsion Letter)
4. My expulsion from Eastman comes after nearly two years of reporting discrimination, harassment, and retaliation. A university investigation had already verified violations of harassment policy and institutional misconduct.
That misconduct continued to such a degree, it triggered a second, ongoing investigation. The administrators who issued the expulsion were the primary subjects of the investigation—an egregious conflict of interest.
The individuals issuing the expulsion were—at the time of the decision—subjects of official university review of misconduct against me.
8. In the expulsion letter, Graduate Dean Matthew Ardizzone makes eighteen separate allegations.
He misleadingly presents them as if allegations alone are sufficient grounds for immediate expulsion. He cites no review process, substantiation, or avenue for appeal.
9. All of the allegations are false, misleading, unsubstantiated, and/or irrelevant. Many are vague and some are implicitly gendered—relying on thinly veiled critiques of my tone, credibility, and deference, in an institution where verbal aggression, gratuitous profanity, routine misrepresentation, and casual insubordination were routinely tolerated in a male-dominated department and administration. (See Full Chron. ¶21-56)
10. Ardizzone includes a long list of nonspecific and inflammatory misconduct charges—which were never brought forward, formally or informally, prior to the expulsion.
At the same time, he incoherently claims that the alleged misconduct played no role in the decision to expel me. The sole purpose of including it seems to be intimidation and/or inflicting reputational harm.
All of the allegations were false, misleading, unsubstantiated, and/or irrelevant.
Many were vague and some were implicitly gendered—relying on thinly veiled critiques of my tone, credibility, and deference.
11. At least three allegations are duplicative and reframed to appear distinct. One allegation lists a course by name; the next repeats the claim, listing the course by number.
All but the most careful reader—with deep knowledge of Eastman's course catalogue—would mistakenly conclude the allegations referred to two different courses.
12. Several allegations cite decisions the school had affirmatively approved. Ardizzone cites two instructional arrangements—mutually agreed upon between faculty, administration, and myself—as grounds for expulsion.
He fails to mention that he personally approved the decisions when they were made, and they were never revisited. He uses one of them to make a duplicate claim, as described above.
13. It is difficult to offer any explanation for these irregularities other than deliberate deception.
Ardizzone incoherently claimed that my alleged misconduct played no role in Eastman’s decision to expel me.
The purpose of including it in the letter seemed to be intimidation and/or inflicting reputational harm.
Far from offering clarity, the letter seems designed to overwhelm any reader through contorted facts and nebulous reasoning. The letter was even issued—curiously—with no date.
13.a Note: …In a previously contested case in which Ardizzone rescinded a student’s admission, the family specifically notes in their legal complaint that his letter was undated.
It is notable that Ardizzone has repeatedly declined to date documents carrying significant academic and legal consequence.
Sheeran recused herself from chairing the panel that validated my harassment complaint, citing an unspecified conflict of interest.
She did not recuse herself in issuing my expulsion, despite the open investigation.
Exploitation of Institutional Credibility
16. The expulsion letter was issued on formal letterhead, cited institutional policy, and carried the appearance of procedural legitimacy.
It relied on a single policy—Satisfactory Academic Progress (SAP)—to justify my removal and bypassed the multi-semester review process—including opportunity to appeal—that policy unambiguously requires. (See Doc P1: ESM Handbook 5.00 and Appendix A: Expulsion Rebuttal)
17. [Redacted]
18. Any reasonable person would assume that administrators citing a policy—in an expulsion letter on school letterhead—were, in fact, following that policy and making statements in good faith. Eastman’s leadership exploited that institutional trust.
19. Shielded from external scrutiny, the school violated the very policy it claimed as justification for my removal, while making multiple demonstrably false claims.
It is difficult to offer any explanation for these irregularities other than deliberate deception.
20. Even if Eastman leadership made the tenuous claim that they exercised discretionary authority in this case, that would only heighten concern.
Even the most generous allowance for discretion does not permit an administrator to contradict all published policy—certainly not under egregious conflicts of interest, and certainly not while issuing an extreme disciplinary sanction.
21. If claiming discretion as their defense, the school would also need to justify why they repeatedly cited policy as grounds for shielding chronic misconduct by a professor who engaged in verified harassment but chose to exercise discretion to expel me after I engaged in multiple acts of protected activity over nearly two years. (See Damages and Relief ¶102-105 )
Egregious Conflicts of Interest
22. In December 2024, the Office of Equity and Inclusion opened a second investigation into ongoing misconduct by Eastman’s leadership related to my case. Ardizzone—who signed the expulsion letter—and Sheeran—who was copied on it—were both subjects of that investigation.
I had named Steingröver—also copied on the expulsion letter—in my reports to the OEI of an escalating hostile environment created by Eastman’s leadership.
Eastman cited a single policy—without identifying its source or contents—to justify my removal, then bypassed all the requirements of the policy they invoked.
23. The individuals issuing the expulsion were—at the time of the decision—subjects of official university review of misconduct against me. That conflict of interest alone renders the expulsion invalid.
24. Sheeran's involvement is especially troubling. When university policy required her to chair the panel that ultimately validated my harassment complaint—and sanctioned Professor Neil Varon and Dean John Hain, whom I reported—she recused herself, citing an unspecified conflict of interest.
25. …Despite being clearly familiar with recusal procedures, she failed to invoke them in multiple decisions—including my expulsion—in which she had an unambiguous conflict of interest. (See Full Chron. ¶231-234)
26. At the beginning of the 24-25 academic year, I raised concerns, in writing, that Ardizzone—specifically tasked with overseeing my academic standing—was a direct report to John Hain, who had threatened me with a defamation suit, creating a direct conflict of interest for Ardizzone. There was no meaningful intervention, despite multiple requests. (See Full Chron. ¶244-246 )
My expulsion was not justified by any published policy or precedent of the Eastman School of Music or the University of Rochester.
29. Despite multiple direct notices, Ardizzone signed my expulsion letter, with Sheeran and Steingröver copied. Expelling a student without process would be indefensible even without the conflicts of interest. With those conflicts, their actions signal undeniable malicious intent.
No Policy Basis
30. All relevant institutional policies…are included in the supporting documents. (See Docs P2-5)
31. Grounds for expulsion are rare, extreme, and uniformly require a comprehensive process of review and appeal.
In a 2024 incident that made national headlines, students were arrested during campus protests. Despite the university’s allegations of racism and hate crimes, the students received disciplinary hearings before being expelled.
UR Spokesperson Sara Miller said that all disciplinary matters are “handled consistent with published processes meeting the institution’s obligation of fundamental fairness.”
32. In 2020, Eastman rescinded admission to Siyu Yang on allegations of racist social media posts.
In a summary ruling, Judge Anne Marie Tadeo described how Eastman formed a committee to review the posts, offered Yang an opportunity to submit a response, offered him an opportunity to revise his response when the first was deemed insufficient, and held a phone call with Yang and his family.
33. Tadeo concluded, “The Court finds that while neither the University or Eastman were required by the Policy to go through the above steps, they offered [Yang] numerous opportunities to explain and clarify.”
The key administrator overseeing that process was Matthew Ardizzone—the same official who later bypassed all policy requirements to issue my expulsion.
34. …My expulsion was not justified by any published policy or precedent of the Eastman School of Music or the University of Rochester.
39. In issuing my expulsion, Eastman bypassed every procedural step outlined in its own policy.
There is no provision for demanding a student turn in their keys and badge to security or barring them from all school activities.
There is no provision for revoking a student’s access to university email—an action which resulted in loss of critical documentation in an ongoing university investigation and legal filings for which the school’s leadership had been put on notice.
40. Eastman issued an immediate expulsion based on my alleged failure to make Satisfactory Academic Progress.
Not only did I meet no published criteria for failure to achieve Satisfactory Academic Progress, the very policy the school cites does not allow for immediate expulsion under any circumstances, nor for the actions that followed the invalid dismissal.
(End of DHR excerpt)
Eastman threatens students with expulsion for failing to cite their sources.
Why is no one calling for the resignations—or terminations—of senior administrators, including the Dean of the Eastman School of Music, who were willing to:
lie on university letterhead,
bypass all university policy
during an open investigation,
expel a student who reported documented misconduct?
Why didn’t anyone call for the resignation of Eastman’s Title IX Coordinator—and Senior Associate Dean—when he threatened to sue a reporting student?
Why has Eastman’s Director of Orchestras—found in violation of harassment and privacy policies—kept his job in spite of accounts of decades of abusive behavior?
Maybe “integrity” isn’t what Eastman is really protecting.
Please go to thefire.org/rochester to demand accountability and amplify the story on this platform and others.
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