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.
D. Intimidation, Retaliation, Abuse of Power in Varon’s Studio
32. Varon insisted that his studio—a group of students under a private teacher—was “a family.” The result was cult-like behavior. Students deferred to Varon, protected him, and withheld even innocuous information if they thought he would disapprove. Even professional staff would not confront his behavior when it was unreasonable or unprofessional.



32.a Note: While Varon’s intimidating behavior may not have been unlawful on its own, it was part of a broader climate in which he could act with impunity. Retaliation for my later protected activity was so inevitable, multiple Eastman officials openly anticipated it but offered no intervention or protection. (See ¶61, 74, 99.a, 124–125)
33. Varon repeatedly held the orchestras past their scheduled end time. I observed an egregious incident, in which he looked at the clock, saw he was five minutes over, and said, “I know we’re over time, but I want to tell you a story”—then held them for twenty more minutes.
34. Early in my tenure, I had heard many complaints and witnessed the problem firsthand. I offered to politely speak up in rehearsals, as a teaching assistant, if Varon ran over time. [A TA] strongly advised against this, saying “He knows,” adding that he felt entitled to control the group’s schedule however he saw fit, as their director…
Varon insisted that his studio was “a family.”
The result was cult-like behavior.
34.a Note: Eastman leadership recognized this as an ongoing issue. In our first meeting, John Hain, Senior Associate Dean, said his inbox was “overflowing” with complaints from students. The school offered no meaningful action. Varon would later engage in similar tactics in retaliation for my taking accommodations after his harassment. (See ¶110–116)
35. [A staff member] once told [a TA] that students had complained… about Varon holding them late. They discussed it and agreed not to tell him, fearing immediate hostility toward themselves or the students who complained.
36. In another incident, when a faculty coach failed to show up to a rehearsal, I asked [a student] to notify Varon. They refused, responding, “he can’t handle it right now.” I had to insist that Varon was the only one who could resolve the situation before they would contact him.
Long after the formal harassment finding, his students had signs around their cubicles that said
“The Varon Zone”
“Students of Neil Varon,”
and “Which Neil Are You Today?”
37. In our earliest conversation, [a student] told me [redacted]. They begged me not to tell Varon, fearing his disapproval would affect the opportunities he offered them in the program and his willingness to recommend them. They warned me not to disclose anything he might find unacceptable, saying it could cost support and opportunities.
38. [Redacted]
39. In the strangest example of this behavior, [a student] told me that [students] had occasionally used what they referred to as “baby talk” with Varon to keep him in a good mood. I witnessed a brief exchange of this behavior between them later. I would not have fully understood the interaction without their previous explanation, but it was still unsettling.
40. Even after Varon was placed on leave—following my published account, a university investigation, and a confirmed violation of harassment policy—his students, all male by that point, displayed celebratory signs around their cubicles. They read “The Varon Zone,” “Students of Neil Varon,” and “Which Neil Are You Today?” with various photos of him.
[An administrator] worried that Varon’s students would become “a lynch mob.”
The school took no action to prevent the anticipated retaliation.
99. …I reached out to [Varon’s students], explained the situation, offered to meet to discuss it openly, and proposed logistical adjustments. I explicitly said that following the complaint, I hoped to simply get through the degree and continue to access program resources without further friction. I asked them not to share the information and to avoid prematurely raising the topic with Varon as a courtesy to him. No one responded.
99.a Note: The school made no effort to facilitate any conversations, aside from suggesting that I have a private, unstructured meeting with Varon immediately after reporting, which I declined. [An administrator] later said that intervention from the school was needed to pre-empt a retaliatory dynamic in the cohort—worrying that the other students would become “a lynch mob”—but no action was ever taken. (See ¶125)
100. Shortly after that, I saw a Google Doc called “Rebecca Points” visible in [a student’s] email when they had it open in the ensemble office, our shared workspace. They did not share the contents of the document, but seeing it was unsettling.