W XV S Princeton

MER-L-002281-21 11/03/2021 3:58:15 PM Pg 1 of 43 Trans ID: LCV20212565806
Anthony N. Gaeta, Esq. Atty. ID: 02214-2001

William A. Friedman, Esq., Atty. ID: 03472-3008
GAETA LAW FIRM, LLC
The Meadows Office Complex
301 Route 17 North, Suite 505
Rutherford, New Jersey 07070
Phone: (201) 939-3304
Fax: (201) 939-3349
Co-Counsel for Plaintiffs, Xiyue Wang and Hua Qu
Richard D. Heideman, Esq. (pro hac vice admission pending)

Noel J. Nudelman, Esq. (pro hac vice admission pending)
Tracy Reichman Kalik, Esq. (pro hac vice admission pending)
Joseph H. Tipograph, Esq. (pro hac vice admission pending)
HEIDEMAN NUDELMAN & KALIK, PC
5335 Wisconsin Avenue, NW
Suite 440
Washington, DC 20015
Phone: (202) 463-1818
Fax: (202) 463.2999
Co-Counsel for Plaintiffs, Xiyue Wang and Hua Qu
SUPERIOR COURT OF NEW JERSEY

XIYUE WANG and HUA QU, LAW DIVISION: MERCER COUNTY
Plaintiffs, Docket No.: MER-L-
v. Civil Action
PRINCETON UNIVERSITY and the COMPLAINT WITH JURY DEMAND

TRUSTEES OF PRINCETON UNIVERSITY,
Defendants.
The Plaintiffs, Xiyue Wang and Hua Qu, by and through their attorneys, as and for their
Complaint, allege and say:
1. This action is brought by the Plaintiffs against the Defendants, Princeton University
and the Trustees of Princeton University (collectively, “Princeton”), for severe personal injuries
and other irreparable harm, which the Plaintiffs have suffered as a result of the Defendants’
reckless, willful, wanton, and grossly negligent acts.

2. Specifically, Princeton, by and through its employees, representatives, agents, or
other persons acting on its behalf, directed the Plaintiff, Xiyue Wang, a U.S. citizen, graduate
student and Ph.D. candidate, to travel to the Islamic Republic of Iran (hereinafter, “Iran”) to
conduct research abroad on a foreign language visa, notwithstanding (a) Iran’s designation by the
United States as a State Sponsor of Terrorism, (b) Iran’s longstanding open and notorious hostility
toward the United States, (c) Iran’s known reputation for taking foreign westerners, particularly
Americans, hostage on specious grounds, (d) Mr. Wang was not studying or specializing in the
study of Iranian history or politics, and (e) Mr. Wang’s adviser lacked demonstrable expertise on
the subjects of Iranian history and politics.
3. Though Mr. Wang raised numerous questions and concerns both before and during
his visit to Iran, Princeton compounded its foolish and reckless decision to direct Mr. Wang to
travel to and conduct research in Iran, through a series of subsequent actions, inactions and reckless
decision-making, which subsequently resulted in Mr. Wang spending years of his life as a hostage
in Iranian prisons to be interrogated, abused, tortured, and emotionally destroyed.
4. For example, Princeton directed Mr. Wang to be persistent in his efforts to conduct
research in Iran’s Foreign Ministry Archives and Iranian National Archives (the “Archives”),
notwithstanding Princeton’s knowledge that the visa Mr. Wang was able to obtain restricted him
solely to foreign language studies.
5. As Mr. Wang’s activities attracted the malign interest of the Iranian authorities,
Princeton was shockingly ambivalent towards the very real threat this posed to Mr. Wang and
revealed that it had no plan whatsoever for protecting Mr. Wang, as it saw no need to do so.
6. The walls of Iran’s security apparatus closed in around Mr. Wang, and his laptop
and passport were seized, but Princeton advised him not to seek sanctuary at the Swiss Embassy,
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the only entity in Iran that could have possibly kept Mr. Wang safe, and assured Mr. Wang that he
was unlikely to be detained. Princeton assured Mr. Wang and Ms. Qu that they should rely on
Princeton’s judgment and expertise that Mr. Wang would not be detained and responded to the
alarms raised by Mr. Wang and Ms. Qu with indifference.
7. Only after Mr. Wang was inevitably arrested and imprisoned, Princeton finally
sprang into action. However, it did so only to protect itself, its institutional reputation and its
desperate and misplaced relationship with the terror-funding, hostage-taking, Western-hostile
dictatorship of Iran – leaving Mr. Wang to rot in Iranian jail cells. Specifically, Princeton sought
to fully control all efforts to secure Mr. Wang’s release by keeping his story out of the press,
dissuading his advocates, including his wife, Ms. Qu, from seeking help from experts, turning
down help offered to Mr. Wang without his family’s knowledge, keeping Ms. Qu away from the
contacts Princeton consulted, and stifling any outside efforts to rescue Mr. Wang from what would
turn out to be years of imprisonment and physical and emotional torture.
8. Upon Mr. Wang’s release, Princeton exacerbated the trauma that Mr. Wang
suffered by disclaiming any accountability for its actions, deflecting all blame for what Mr. Wang
experienced to others including the U.S. government and even Mr. Wang himself. Princeton’s
victim-blaming, as well as its refusal to provide appropriate support and accommodations to Mr.
Wang compounded Mr. Wang’s suffering.
9. In short, at every step, Princeton recklessly, willfully, wantonly, and in a grossly
negligent manner turned Mr. Wang into a target for and victim of the security apparatus of Iran –
a known State Sponsor of Terrorism – taking direction primarily from the pro-regime activists and
academics Princeton had hired and whose advise was diametrically opposed to the advice being
provided by experts in hostage situations, which Princeton ignored. In prioritizing the school’s
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coveted reputation and relationship with the terrorist state of Iran over the safety of its student,
Princeton’s conduct gave rise to and perpetuated Mr. Wang’s inevitable tragic fate.
JURISDICTION, VENUE, AND CHOICE OF LAW
10. This Court has jurisdiction over the Defendants because it has transacted business
within the State of New Jersey at all times relevant to this Complaint.
11. Pursuant to R. 4:3-2(b), venue is proper in Mercer County based upon the Plaintiffs’
residency and the Defendants’ principal place of business.
THE PARTIES
A. The Plaintiffs
12. Plaintiff Xiyue Wang (“Mr. Wang”) was and, at all times relevant hereto, is a
citizen of the United States and resident of New Jersey. Mr. Wang was a Ph.D. student at
Princeton, studying Eurasian history of the late nineteenth and early twentieth centuries. Mr. Wang
had no academic background in Iranian history and politics. As described more particularly below,
Mr. Wang was strenuously encouraged by his doctoral advisor as well as other administrative,
academic, other employees and affiliates of Princeton to travel to the Islamic Republic of Iran to
conduct research for his dissertation and improve his Persian language skills, despite Princeton’s
knowledge of the serious risks facing U.S. citizens in Iran and the lack of any safeguards in place
or experience placing students there. Throughout Mr. Wang’s time in Iran, he notified Princeton
of many instances in which his personal safety and freedom were in danger, but each time he was
encouraged to remain in Iran, stay quiet, and be patient with the instrumentalities of the regime.
13. On August 7, 2016, Mr. Wang was detained, his passport was taken. He was later
arrested, taken hostage, and caused to be imprisoned on false charges by Iranian authorities. In a
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bogus trial, he was convicted of Collaboration with a Hostile State as an infiltrator and a spy and
sentenced to ten years of imprisonment. He spent forty months (1,216 days) in Iran’s notoriously
brutal Evin Prison and was in Iranian custody as a hostage, used by Iran to extort the United States
for political gains just as it had done in the past. During his wrongful imprisonment, Mr. Wang
was tortured and mistreated in numerous respects.
14. Plaintiff Hua Qu (“Ms. Qu”) is and was, at all times relevant hereto, the wife of
Xiyue Wang and a permanent resident of the United States living in the State of New Jersey. Ms.
Qu has suffered severe mental anguish and extreme emotional pain and suffering, including the
loss of society and services of her husband.
B. The Defendants
15. Defendant Princeton University is a private not-for-profit, nonsectarian institution
of higher learning and research in Princeton, New Jersey. The Graduate School at Princeton
administers the Ph.D. program in which Mr. Wang was a student. Princeton also hosts the Sharmin
and Bijan Mossavar-Rahmani Center for Iran and Persian Gulf Studies (the “Princeton Iran
Center”) that sponsored Mr. Wang’s travels to Iran jointly with Princeton’s History Department.
Princeton University can sue and be sued in this Court.
16. Defendant Trustees of Princeton University is a New Jersey non-profit corporation
and is responsible for the overall direction of the university. The Trustees of Princeton University
consist of no fewer than 23 and no more than 40 members at any one time. The Trustees of
Princeton University approve the operating and capital budgets, supervise the investment of the
university’s endowment, and claim copyright ownership over all content posted on the websites of
Princeton University including those of The Graduate School at Princeton and the Iran Studies
Center. The Trustees of Princeton University exercise prior review and approval concerning
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changes in major policies and the hiring of faculty members. According to Princeton University
administrators, the Trustees of Princeton University were briefed on Mr. Wang’s case on regular
basis. The Trustees of Princeton University can sue and be sued in this Court.
FACTS
The Islamic Republic of Iran
17. Islamic Republic of Iran is a foreign state that is one of only three countries
currently designated by the United States of America federal government as a State Sponsor of
Terrorism pursuant to § 60 of the Export Administration Act of 1979 (50 U.S.C. App. § 2405) and
§ 620(A) of the Foreign Assistance Act of 1961 (22 U.S.C. § 2371). Iran has been designated a
State Sponsor of Terrorism at all times since January 19, 1984, the longest in duration among
designated countries that also had no diplomatic relations with the United States.
18. The current regime in Iran took control of the country in 1979, following the Islamic
Revolution—a series of events that culminated in the overthrow of the Pahlavi dynasty under Shah
Mohammad Reza Pahlavi and the replacement of this government with an Islamic republic under
the rule of Ayatollah Ruhollah Khomeini, a leader of one of the factions in the revolt. Under the
new regime, newspapers and several other democratic institutions were dissolved. In the years
following the revolution, human rights groups estimated the number of casualties suffered by
protesters and prisoners of the new system to be several thousands.
19. The United States severed diplomatic relations with Iran on April 7, 1980. This
action was taken following the seizure by student militants of the American Embassy in Tehran
and its staff on November 4, 1979, and the subsequent failure of the Iranian government to secure
the release of the 52 American citizens and diplomats for 444 days. The hostages eventually were
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released on January 20, 1981; however, diplomatic relations remain severed, and Switzerland
currently serves as the protecting power for U.S. interests in Iran.
20. Iran has continued to utilize hostage-taking as a tool of international diplomacy. In
the nine years prior to Mr. Wang’s detention, from 2007-2015, Iran arbitrarily arrested 27 reported
foreigners, dual nationals, or Iranian citizens with permanent residence abroad. From 2016-2019,
Iran arbitrarily arrested another 30 such individuals, including Mr. Wang.
21. The United States Department of State Travel Advisory for Iran advises that U.S.
citizens “do not travel to Iran due to the risk of kidnapping and the arbitrary arrest and detention
of U.S. citizens.” The advisory continues, “U.S. citizens visiting or residing in Iran have been
kidnapped, arrested, and detained on spurious charges. Iranian authorities continue to unjustly
detain and imprison U.S. citizens, particularly dual national Iranian Americans—including
students, journalists, business travelers, and academics—on charges including espionage and
posing a threat to national security. Iranian authorities routinely delay consular access to detained
U.S. citizens and consistently deny consular access to dual U.S.-Iranian citizens. The U.S.
government does not have diplomatic or consular relations with the Islamic Republic of Iran. The
U.S. government is unable to provide emergency services to U.S. citizens in Iran.”1
Attitudes at Princeton Regarding Iran and its Relations with the US
22. Despite Iran’s well-documented record of kidnapping, sponsorship of terrorism,
and explicit hostility towards the United States and its closest allies around the world, among the
academics at Princeton groupthink had coalesced around a belief that the U.S. had so badly
mistreated Iran in the past that it must engage and appease the Islamic Republic now. Pro-
engagement and pro-Iran scholars prevail at Princeton and Princeton as an institution sits proudly
1
https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/iran-travel-advisory.html.
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at the forefront of the pro-engagement crowd in the United States. In the classroom, published
materials and media appearances, Princeton academics overly emphasize US imperialism,
condescension, and other behavior toward the Middle East, especially Iran, as being responsible
for Iranian’s destructive behavior. Princeton has gone so far as to host and employ ex-Iranian
ambassador to Germany Seyed Hossein Mousavian who has been identified as contributing figure
towards the political murder of dissidents.
23. Seyed Hossein Mousavian is a Middle East Security and Nuclear Policy Specialist
at the Program on Science and Global Security at Princeton University. He is a former diplomat
who served as Iran’s Ambassador to Germany (1990-1997), which coincided with the regime’s
assassination of four dissidents on German soil. The German government eventually requested
the removal of Mousavian along with others attached to the intelligence section of the Iranian
embassy. Mousavian has also served as Head of the Foreign Relations Committee of Iran’s
National Security Council (1997-2005), Spokesman for Iran in its nuclear negotiations with the
international community (2003-2005), Foreign Policy Advisor to the Secretary of the Supreme
National Security Council (2005-2007), Vice President of the Center for Strategic Research for
International Affairs (2005-2009), General Director of Foreign Ministry for West Europe (1987-
1990), Chief of Parliament Administration (1984-1986), and the editor-in-chief of the English-
language international newspaper Tehran Times (1980-1990). Since joining Princeton in 2009,
Mr. Mousavian has written many articles and made many media appearances where he has
advocated in favor of the United States allowing Iran to obtain nuclear capabilities. Mr. Mousavian
is understood to be a strong and avid supporter of the current Iranian terrorist regime. Mr.
Mousavian frequently published pro-regime articles throughout Mr. Wang’s imprisonment in Evin
Prison.
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24. The history between Princeton and Iran is over a century old. Howard C.
Baskerville, Class of 1907, went to Iran as an English teacher and died fighting alongside his
students in a short-lived quest for constitutional democracy.
25. In 1969, Princeton accepted a foundational grant from the Pahlavi Fund, which was
established by the Shah to promote understanding of Iranian society and culture.
26. After the 1979 Revolution, the Islamic regime gained control over the Pahlavi fund,
and subsequently rebranded the charity as the Alavi Foundation. Through the fund, the new regime
continued to donate millions of dollars to schools across the United States to promote the hiring
on pro-regime professors at the most prestigious American colleges and universities, including
Princeton, which accepted the donations from the foundation despite the regime’s hostile relation
with the U.S. government.
27. In 2012, Princeton University established the Sharmin and Bijan Mossavar-
Rahmani Center for Iran and Persian Gulf Studies. According to the Princeton Iran Center’s
website, the center was “launched to promote groundbreaking independent scholarship and
teaching” and “to promote a new understanding of Iranian society and culture.”
28. Over the years, the Princeton Iran Center has received funding from and employed
as staff individuals who maintain allegiances with the current regime in control of Iran and who
openly oppose the activities of the United States and its allies in the Middle East.
29. The funder of the Princeton Iran Center Bijan Mossavar-Rahmani moved to the
United States from Iran in 1978 to attend Princeton. Today he is the Executive Chairman and CEO
of RAK Petroleum PCL, a United Arab Emirates energy company that sells petroleum to the
regime in Iran. Mr. Mossavar-Rahmani has a deep financial interest with the regime and avidly
promotes engagement.
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30. Mona Rahmani (“Ms. Rahmani”) was senior research specialist at the Princeton
Iran Center during its inaugural years of operation, from 2014-2017. In that capacity, she managed
programs, projects and events and supported research to promote engagement with the Iranian
regime. Her father Mostafa Rahmani was the director of the Iranian Interest Section (2010-2015)
at the Embassy of Pakistan in Washington DC. Ms. Rahmani is understood to be a strong and avid
supporter of the Iranian regime and was hired at Princeton because of her father’s close affiliation
with the Iranian regime. Mona Rahmani advised and facilitated Mr. Wang’s visa application.
31. Today, the Princeton Iran Center is led by its Director Behrooz Ghamari-Tabrizi,
who has spoken out in support of the Iranian regime and its proxy terrorist groups, and against the
United States and its allies in the Middle East.
32. Soon after Mr. Wang was interrogated by Iranian authorities the first time on July
20, 2016, several of the above Iranian regime sympathizers told Princeton that they did not want
to be involved or in any way being mentioned in Mr. Wang’s case, other than encouraging
Princeton to stay quiet about the matter and to direct the Wangs to stay quiet as well.
Princeton Directed Mr. Wang to Study in Iran
33. Mr. Wang was directed by Princeton to study in Iran primarily by his faculty adviser
Professor Stephen Kotkin.
34. Princeton vests in its faculty advisers complete authority over the research activities
of doctoral students they advise, as explicitly stated on Princeton’s Graduate School website:
“While the range of topics that Ph.D. students may pursue for dissertation work is wide, it
nonetheless may be limited by the interests and expertise of the faculty. Students may need to
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adjust their research topics in order to align them with faculty expertise if they wish to complete
the degree.”2
35. Generally speaking, advisee-students rely upon their faculty advisers for their
academic and professional success and enhancement. Advisee-students’ progress year by year
within the program requires their faculty advisers’ approval at their annual reviews. Advisee-
students’ applications for internal and external fellowships require their advisors’ endorsements.
Advisee-students’ depend on their advisors’ connections and recommendation letters to land
academic jobs. Advisee-students’ need their faculty advisers’ endorsements when the advisee-
students are up for tenure review and want to be promoted from assistant to associate professors.
As a result of these policies, faculty advisers wield nearly absolute control over their advisees’
decision-making, which in turn makes it extremely difficult, if not impossible, for student-advisees
to defy or even second-guess their faculty advisers’ advice and guidance.
36. Mr. Wang’s faculty adviser Kotkin is a particularly demanding faculty adviser who,
upon information and belief, has effectively forced out at least two of his student-advisees in the
last six years.
37. The manner Kotkin provided guidance, frequently compelled the Wangs into
making decisions that were harmful to Mr. Wang. When advising Mr. Wang and Ms. Qu about
engaging with Iranian authorities before, during and after their interest in Mr. Wang’s research,
Kotkin presented drastically irreconcilable views about the regime. As such, the guidance he
provided was wholly inconsistent at these various stages other than always being authoritative,
self-serving, and lacking in accountability. Initially, after Mr. Wang arrived in Iran, Kotkin
downplayed Mr. Wang’s concerns about being denied access to certain Archives, instructed Mr.
2
See https://gradschool.princeton.edu/academics/degree-requirements/phd-advising-and-requirements.
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Wang to firmly challenge any resistance he encountered from Iranian authorities, and discounted
such obstacles as merely the by-product of bureaucracy. However, once it became clear that this
approach had aroused suspicion, Kotkin refused to further communicate with Mr. Wang over
email. Then, approximately one year into Mr. Wang’s imprisonment, Ms. Qu was approached
with an offer to be put in touch with the BBC Persian media outlet, which would allow her to go
on air and make a plea directly to the Iranian people to advocate for Mr. Wang’s release. She
relayed this opportunity and her interest in pursuing it to the Princeton team, noting historical
precedent that such engagement has contributed to positive results. In joining Princeton’s efforts
to keep Ms. Qu silent, Kotkin informed the team that he had been offered a similar opportunity
and declined, based on his “strongly held” view that any public statement seeking Mr. Wang’s
release, even politely worded and appealing to the mercy of the Supreme Leader, could be
dangerous and provoke the anger of the regime. Based on Kotkin’s guidance, Ms. Hua declined
this interview and the opportunity it presented to engage the Iranian public, while expressing
concern that even a few more months in detention could seriously negatively impact Mr. Wang’s
condition. Mr. Wang would go on to spend over two additional years in prison following this
exchange.
38. When Mr. Wang enrolled in Princeton, he never intended to travel to or study in
Iran, nor did he study Iranian history or politics before or at Princeton. He came to Princeton
specifically to work with Kotkin, who is an expert on Russia and Soviet Union and who similarly
did not have any meaningful background or expertise with Iran. Initially, Mr. Wang was inclined
to do a comparative governance project about Russia’s Muslim territory and Russia’s neighboring
Muslim countries, that included (Ottoman) Turkey, Afghanistan, and China’s Xinjiang. In fact,
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Mr. Wang went to Turkey to sharpen his Ottoman Turkish in summer 2014 after his first-year
coursework, as he contemplated a project that would focus on Ottoman Turkey.
39. Initially, Kotkin directed Mr. Wang to perform his research in Afghanistan.
Although Mr. Wang did not intend on studying in Afghanistan or Iran per se, Kotkin suggested,
multiple times over, that Mr. Wang study in Afghanistan due to his knowledge of the Persian
language and his experience working and living in Afghanistan in the past.
40. On December 3, 2014, Michael Cook, a Princeton professor well-renowned for his
knowledge of Middle Eastern history, along with the Princeton Iran Center inexplicably began
recruiting students to study in Iran and prompted interested students to reach out to Dr. Kevan
Harris, (“Dr. Harris”) who was the acting director of the Princeton Iran Center at the time.
41. About three weeks later, on December 30, 2014, Mr. Wang directly responded to
Mr. Cook’s solicitation and reached out to Dr. Harris expressing his curiosity and interest in
studying Persian language, noting that Kotkin had been encouraging Mr. Wang to study
Afghanistan and Iran.
42. Dr. Harris encouraged Mr. Wang to apply to the Dehkhoda Lexicon Institute and
International Center for Persian Studies (“Dehkhoda Institute”). Dr. Harris himself had previously
studied in Iran and Mr. Wang therefore trusted Dr. Harris’ advice and direction. Upon information
and belief, during his study in Iran, Dr. Harris was arrested and detained. Dr. Harris however never
disclosed the fact that he was arrested in Iran to Mr. Wang, but instead inexplicably encouraged
Mr. Wang to study in Iran.
43. Mr. Wang had initially applied in February 2015 for an Iranian student language
visa for a summer Persian language program in 2015. Mr. Wang’s expectation in the beginning
was that he would merely study the Persian language at the Dehkhoda Institute in Iran during the
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summer of 2015 before moving on to Afghanistan to perform his substantive research in early
2016, since language study alone on a visa for that very purpose is a much lower risk activity. As
such, Mr. Wang applied for a student language visa through the Dehkhoda Institute from the
Iranian authorities.
44. After not hearing back on his application for many months, Mr. Wang made
alternate plans to improve his Persian language skills. By the fall semester of 2015, Mr. Wang
was in touch with the American Institute of Afghanistan Studies and the Afghan National Archive
in Kabul, in preparation for a research trip to Afghanistan beginning in January 2016. According
to his schedule, Mr. Wang submitted his dissertation prospectus on a project about Afghanistan
which was approved by Kotkin in mid-November 2015.
45. However, on November 18, 2015, Mr. Wang received an email from the Dehkhoda
Institute, notifying him that his student language visa to study at the Dehkhoda Institute in Iran
was approved. He shared this information that day in a routine advisor-advisee meeting with
Kotkin who immediately directed Mr. Wang to go to Iran in lieu of his original planned trip to
Afghanistan, despite his lack of experience or expertise on the country. While the United States
government had long severed relations with Iran and warns U.S. citizens not to travel to Iran, as
the U.S. is not able to protect them, the academic consensus at Princeton was that the concerns of
the U.S. government were significantly overstated.
46. Kotkin advised Mr. Wang that an opportunity to study in Iran was rare and that he
should take advantage of the opportunity to explore research possibilities in Iran, even though this
was beyond the scope of what Mr. Wang’s student language visa would permit. Kotkin further
advised that if it proved impossible to conduct research in Iran, Mr. Wang could always go to
Afghanistan later. Kokin directed Mr. Wang to consult Princeton Iran Center for further advice.
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47. On November 20, 2015, Mr. Wang emailed Ms. Rahmani, a Senior Research
Specialist at the Princeton Iran Center, who was referred to Mr. Wang by Dr. Harris. Mr. Wang
sought Ms. Rahmani’s advice on whether the Iranian authorities would allow him – as a U.S.
passport holder on a student language visa – to access the Iranian National Archives. Mr. Wang
explained to Ms. Rahmani that making the trip to Iran only for gaining spoken proficiency in Farsi
made little sense at that stage of his doctoral studies and that he would only seriously consider
going if it would be possible for him to see the Archives.
48. Ms. Rahmani responded hours later via e-mail assuring Mr. Wang that he would be
able to see the Archives and stating that she “would highly recommend going,” to Iran. Ms.
Rahmani further explained that the Princeton Iran Center had contacts at the Archives, and that it
would be easy for Mr. Wang to obtain a temporary pass as a visiting researcher once he was already
inside Iran on his foreign language study visa.
49. Princeton’s stature as one of the most elite institutions of higher learning in the
United States, its long tradition of Iranian studies, coupled with the fact that some of the best-
known Iran experts in the United States teach at Princeton convinced Mr. Wang that when
Princeton urged, advised and directed him to go to Iran to do research, it had conducted the
necessary due diligence and had the necessary safeguards in place to ensure his safety. Mr. Wang
expected that in sending him to Iran, Princeton considered his well-being to be a priority.
50. Mr. Wang was well-aware that a failure to align his research topic with Kotkin’s
direction could result in his removal from the doctoral program at Princeton (as has been the case
for a student in his cohort who was advised and subsequently forced out by Kotkin). Moreover,
when Kotkin told Mr. Wang to put his trip to Afghanistan on hold and instead to take the trip to
Iran, Mr. Wang relied on the advice and guidance given to him by his dissertation advisor. To the
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detriment of Mr. Wang and Mr. Wang’s family alone, Kotkin and Ms. Rahmani, on behalf of the
University, painted a rosy picture of studying abroad in Iran and did not provide any cautionary
advice.
51. By late November 2015, as a result of Kotkin’s insistence and the assurances
provided by the Princeton Iran Center, the Afghanistan focused dissertation project outlined in Mr.
Wang’s dissertation prospectus was set aside for a distinctly different, Iran-focused project.
52. Even after making this change to his dissertation prospectus, Mr. Wang continued
to raise concerns about the limitations of his language visa.
53. On December 1, 2015, Mr. Wang wrote an email to Ms. Rahmani, and Dr. Harris,
copying Kotkin, in which he stated, “[a]s a US citizen of non-Iranian descen[t], I think it would be
preferable for me to be as transparent as possible so that I would not be deported from the country
for doing things my visa does not prescribe me to do and therefore barred from entering Iran
again.” The next day, Mr. Wang met Ms. Rahmani in person and reiterated his concerns about the
limitations of his language visa. Ms. Rahmani agreed to contact the Iranian Interest Section at the
Pakistani Embassy in Washington D.C. on Mr. Wang’s behalf to gain clarity on the issue.
54. On December 5, 2015, Mr. Wang emailed Ms. Rahmani indicating his plans to
apply for a research visa. She replied two days later explaining that she had not yet heard back
from the Interest Section, but assured Mr. Wang that his concerns about the parameters of the
language visa “can be handled after the application is submitted.”
55. On January 17, 2016, Dr. Harris wrote to Mr. Wang that “it’s a good time to go [to
Iran] – looks like they are in a good mood over there. Take advantage of it!”
56. Ms. Anastasia Vrachnos, Princeton’s Vice Provost for International Affairs in
2015—2016, who would later on become the main Princeton administrator handing Mr. Wang’s
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case, replied to Mr. Wang’s email on January 28, 2016 about his trip to Iran with an encouraging
and optimistic tone that “it’s an exciting and dynamic time to be there,” again without any
cautionary advice.
57. On January 18, 2016, Mr. Wang submitted a funding proposal to the Princeton Iran
Center. The next day, he received an email indicating that the Princeton Iran Center would fully
cover the costs of his initial stay and a potential extended stay for a total amount of $12,413.18.
58. Mr. Wang was the first Princeton student who entered Iran on a U.S. passport to
conduct dissertation research in Iran under the current regime. Then director of the Princeton Iran
Center Prof. John F. Haldon proudly touted in an email to Mr. Wang, that his trip was “a pioneering
visit for Princeton” that the school hoped would enable it “to send other graduate students to carry
out research there” and “support Iranian graduates should they wish to work at Princeton.”
Mr. Wang’s Travel to Iran
59. On January 26, 2016, Mr. Wang set out on his first of two trips to Iran. During this
trip Mr. Wang studied at the Dehkhoda Institute as well as at the Iranian National Library.
60. During this first visit, Mr. Wang alerted Kotkin and other Princeton staff about the
challenges he was encountering in accessing materials at the Iranian National Archives due to the
limitations of his language visa’s parameters. Specifically, he was unable to access the National
Archives and was told that he needed to get additional permission. In response he was directed by
Kotkin to remain in Iran and continue his language studies at the Dehkhoda Institute, while he
continued to try to obtain the access he required. Kotkin told Mr. Wang that he must very politely,
very firmly overcome all of these obstacles.
61. On February 3, 2016, Mr. Wang wrote an email to Kotkin raising concerns about
the inability to do research on his student language visa and explaining that “the major problem is
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that foreigners cannot change [their] visa inside Iran, [so he] must leave the country and apply for
a visa elsewhere.”
62. The next day, Kotkin responded stating that while Mr. Wang had “the choice of 1)
using libraries (newspapers, printed materials) after daily language study; or 2) leaving to get a
new visa,” Kotkin, advised that he believed Mr. Wang should stay in Iran and conduct whatever
research he could. Kotkin, who possessed no specialized knowledge or information regarding Iran,
continued, “be realistic, be patient. It is a cumulative process – every day, a little more.”
63. On February 8, 2016, Ms. Rahmani sent Mr. Wang an email suggesting he reach
out to her father in Iran, whom she said, “can help you with anything you need through his
extensive network,” including “any of your visa questions and issues.”
64. Mr. Wang followed through and paid Dr. Mostafa Rahmani (“Dr. Rahmani”) a visit
in his home three days later. A staunch regime supporter, Dr. Rahmani started his conversation
with Mr. Wang with a discussion of the evils of the United States government. When Mr. Wang
expressed his concern about the frustration of doing research on a language visa, Dr. Rahmani
advised him to stay on the language visa for the time being, and there would not be any problem.
65. Mr. Wang returned to the United States on March 9, 2016, as it was the Iranian
New Year and the Dehkhoda Institute, National Library and National Archives were closed; and
it was a good time to join his wife and son back home in the United States. During this brief return
to the United States, Kotkin encouraged Mr. Wang to travel back to Iran again to complete
additional Persian language training at the Dehkhoda Institute and conduct research for his
dissertation at the Iranian National Library and Iranian National Archive.
66. On March 23, 2016, Mr. Wang reached out to Ms. Rahmani to inquire about the
status of his return visa for Iran, as he had submitted a return visa application before leaving Iran.
18
Over a week later, on March 31, 2016, Ms. Rahmani replied to Mr. Wang stating there was nothing
she could personally do at that point in time to expedite procurement of the visa.
67. Ms. Rahmani continued to say, “[w]ith Iran work, as you know, it’s always an
unstable situation, and I always recommend having as many backup and alternative plans as
possible.” Yet neither Ms. Rahmani nor Princeton had a backup or any alternative plans for Mr.
Wang throughout either of his trips to Iran. There were no alternative plans for an apartment,
obtaining proper visas, or ensuring Mr. Wang’s health and safety. Outrageously, there was no plan
in place to assist Mr. Wang if in following the direction of Princeton he continued conducting
research outside the language visa’s parameters the situation went awry.
68. Throughout his first and his second trips to Iran, Mr. Wang was extremely
transparent with all U.S. and Iranian authorities regarding his research intentions – but Princeton
was oblivious how this information would be perceived by Iranian authorities.
69. On April 30, 2016, Mr. Wang returned to Iran on a language visa. On May 1, 2016,
Mr. Wang visited the Iranian Foreign Ministry’s Student Affairs Office to get approval to conduct
research outside the parameters of the language visa. An official at the office informed Mr. Wang
that he would be allowed to conduct research in Iran under his current passport and visa, but Mr.
Wang soon came to learn, and immediately communicated to Kotkin, that the research facilities
he was able to access did not include the Iranian National Archive, which might contain the
materials Mr. Wang needed, resulting in the need for him to do further research outside his
language visa.
70. Around the same time, Mr. Wang encountered problems accessing his Princeton
emails. Princeton’s security monitoring system blocked Mr. Wang’s access after it detected
“abnormal” activities on his accounts. When he contacted Princeton’s Office of Informational
19
Technology, he was advised it was probable that Iranian cyber police had hacked into Mr. Wang’s
Princeton email account and downloaded all his messages and personal information. Mr. Wang’s
cellphone was likely being monitored as well. His phone number changed without notice, Mr.
Wang experienced delayed connections, and other strange third-party noises occurred while on the
phone indicating the phone was indeed hacked and his conversations were being listened to or
even recorded.
71. Mr. Wang relayed the access and hacking issues to Kotkin and others at Princeton
but was again directed to remain in Iran and continue conducting research beyond the scope of
what he had been authorized, in spite of being monitored. Princeton again had no alternative plans
and saw no need to take protective measures on Mr. Wang’s behalf. On May 6, 2016, Mr. Wang
emailed Kotkin to update him on the hacking of his phone and laptop and to update him on his
language and dissertation studies. In this email, Mr. Wang explained he was experiencing
problems from Iranian authorities, and that he believed that having a United States passport was a
“double edged sword,” because being an American was even more of a reason for the Iranian
authorities to falsely accuse him of espionage and to arrest and detain him. The next day, on May
7, 2016, Kotkin emailed Mr. Wang, “[c]ontinue to work along these lines, do not give up. Take
some time to see what happens. Be polite, persistent.” Mr. Wang remained in Iran and continued
his work in a polite manner, just like his advisor instructed.
72. Mr. Azari, an Iranian researcher introduced to Mr. Wang by Mr. Ramin Karimian,
– an academic contact that Dr. Harris put Mr. Wang in touch with – suggested that he would help
procure documents for Mr. Wang as they would be more likely to release the documents to an
Iranian researcher.
20
73. Mr. Wang advised Kotkin about the possibility of Mr. Azari procuring documents
from the Iranian National Archives. Knowing that this was beyond the scope of Mr. Wang’s
authorization and knowing that Mr. Wang’s phone and email were potentially monitoring Mr.
Wang’s communications, Kotkin did not raise any concerns.
74. On July 10, 2016, Mr. Azari received the first batch of documents for Mr. Wang.
A week later, on July 17, 2016, Mr. Azari went back to receive the second batch of documents,
but he was denied receipt as he was obtaining the documents for “an unauthorized foreigner.”
75. Mr. Wang immediately reported this incident to Kotkin, but his response was
shocking – Kotkin told Mr. Wang not to contact him via email. In his phone conversation with Mr.
Wang, Kotkin did not provide any cautionary advice, but merely suggested he and Mr. Wang
would speak face to face when Mr. Wang returned to the United States.
76. Princeton, which had assured Mr. Wang that it employed experts with good Iranian
relations, knew or should have known and understood the gravity of the situation, and should have
used their expertise and contacts to help Mr. Wang get out of the situation he found himself in as
a direct result of Princeton’s direction. Instead, the very experts that led Mr. Wang to believe he
could safely conduct research in Iran, refused to provide any further assistance towards securing
Mr. Wang’s release the moment their assurances about the regime proved false. The only guidance
offered was direct the Wangs to stay quiet. This guidance only served to benefit the Iranian regime
at Mr. Wang’s expense.
77. After approximately three months into the second trip to Iran, throughout which
Mr. Wang continued to experience difficulty in obtaining access to the documents at the Iranian
National Archives, Mr. Wang made plans to return home to the United States. However, on July
20, 2016, prior to his scheduled departure, the Iranian Ministry of Intelligence confiscated Mr.
21
Wang’s passport and laptop, preventing Mr. Wang from leaving the country. Mr. Wang
immediately reported it to Kotkin, Princeton’s History Department, the Princeton Iran Center and
Princeton’s Vice Provost.
Between Passport Confiscation and Arrest
78. On July 23, 2016, in speaking with Mr. Wang, Ms. Qu suggested that he to go to
the Swiss Embassy to seek sanctuary. Mr. Wang went to the U.S. Interest Section of the Swiss
Embassy, which provided him with no assistance.
79. On July 24, 2016, after Mr. Wang expressed his concern about possibly being
detained, Prof. John Haldon, the director of Princeton’s Iran Center at the time, told Mr. Wang to
“sit tight and say nothing to anyone outside the small group of people who already know about the
situation.” Prof. Haldon and Princeton were clearly trying to prevent Mr. Wang’s situation from
being known beyond the University.
80. On July 25, 2016, Ms. Qu, learned that all the Iranian experts at Princeton had
declined to help her or Mr. Wang, due to their own personal safety concerns. After directing Mr.
Wang to study in Iran, Princeton’s Iranian experts chose not to exercise their political capital to
assist Mr. Wang, while telling Mr. Wang and Ms. Qu not to involve anyone but Princeton – not
even the United States government – in facilitating his exit.
81. That same day, Ms. Qu was informed that Dr. Rahmani had withdrawn from the
Wang matter altogether as he also did not want to be involved. Dr. Rahmani’s withdrawal should
have alerted Princeton as to the gravity of the situation, but they again sat idly by, without even
relaying any sort of caution or concern to Mr. Wang or Ms. Qu.
82. On July 26, 2016, Iran interrogated Mr. Wang and threatened to detain him. On the
next day, Mr. Karimian, Dr. Harris’ academic contact, told Mr. Wang that he might be interrogated
22
by Iran’s paramilitary Islamic Revolutionary Guard Corp (“IRGC”) disguised as diplomatic
police.3 Mr. Wang immediately went to the Swiss Embassy again but was not allowed to stay there
for long.
83. Princeton several times articulated to Ms. Qu that Princeton had retained the best
lawyers in the U.S., some of whom were former senior State Department officials, and that she did
not need to obtain her own counsel.
84. Ms. Qu asked Princeton and specifically to Ms. Vrachnos to assist Mr. Wang with
seeking protection from the Swiss, but Ms. Vrachnos, leading the Princeton team working on Mr.
Wang’s case at the time, declined to assist with seeking protection for Mr. Wang and in fact was
adamant with Ms. Qu and Mr. Wang that Mr. Wang not visit or seek sanctuary from the Swiss
Embassy.
85. Furthermore, the then-Director of the Princeton Iran Center, Professor Haldon,
astonishingly told Ms. Qu she could safely rule out the possibility that Mr. Wang was being setup,
although of course that is precisely what happened.
86. On the same day that Princeton was insisting that Mr. Wang avoid the Swiss
Embassy, his landlords returned from their vacation, and concerned for their personal well-being
due to the Iranian security apparatus’ apparent interest in their tenant, asked Mr. Wang to leave.
Mr. Wang reported the situation to Princeton who advised that they had no means whatsoever to
make another arrangement for Mr. Wang to find a place to sleep.
3
The IRGC is a paramilitary arm of the Iranian Regime charged with protecting the Islamic Revolution both
domestically and internationally. The United States Department of the Treasury’s Office of Foreign Assets Control
has designated the IRGC as a Specially Designated National and a Specially Designated Global Terrorist pursuant to
Executive Order 13224. The United States Department of State has designated the IRGC as a Foreign Terrorist
Organization.
23
87. Despite these obvious red flags, Princeton continued to take no steps to utilize its
extensive domestic and foreign contacts and expertise to extract Mr. Wang from Iran or protect
him while he was there.
88. On July 27, 2016, Mr. Wang shared with Ms. Vrachnos the suspicions of Mr.
Karimian that it was the IRGC that had confiscated his laptop and passport, not diplomatic police.
89. After supposedly speaking to an expert, Ms. Vrachnos called Mr. Wang to again
reiterate the fact that Princeton did not think he would be arrested, and assured Mr. Wang that if
he were, Princeton would do everything within their considerable power to get him out of Iran.
90. That same day, Prof. Haldon emailed Ms. Qu and, in another attempt to suppress
the case, reiterated that Mr. Wang should stay low-key out of the public eye, again advised that
Ms. Qu should not involve the U.S. government, and expressed Princeton’s belief that Mr. Wang
would not be arrested.
91. In addition, Princeton’s Washington D.C. lobbyist, Joyce Rechtschaffen (“Ms.
Rechtschaffen”), and Princeton’s lawyer, John Bellinger (“Mr. Bellinger”), a seasoned former
State Department official, also told Ms. Qu that Mr. Wang should not go to the Swiss Embassy to
seek sanctuary.
92. On August 3, 2016, Ms. Qu told Princeton about the breaking news that Obama
Administration released $1.7 billion frozen Iranian assets, which included $400 million cash that
was paid as a part of the early 2016 prisoner exchange with Iran. Ms. Qu was deeply worried that
Mr. Wang was being held hostage for ransom to obtain more concessions and/or money from the
United States and begged Princeton to protect Mr. Wang. Ms. Qu’s request was completely ignored
by Princeton.
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93. On August 3, 2016, Princeton instructed Mr. Wang to retain an Iranian attorney,
Mr. Adib, to serve as legal counsel to Mr. Wang. Mr. Adib was a 71-year-old Francophone lawyer
living in Iran, who spoke very broken English and had little to no experience regarding legal issues
such as those facing Mr. Wang.
94. Mr. Adib told Mr. Wang he should retain him immediately because if he did not,
and he was arrested, it would be very hard if not impossible to find and retain another lawyer.
Considering all the circumstances, and as he had received the recommendation to retain Mr. Adib
from Princeton, Mr. Wang signed the retainer and hired Mr. Adib as his lawyer.
95. It is inconceivable that Princeton, who claimed to have long-developed contacts
and an excellent reputation in and relationship with Iran, was unable to find a more experienced
lawyer for Mr. Wang, especially considering the gravity of his situation and the fact that Mr.
Bellinger was the former legal advisor at the U.S. Department of State.
96. In fact, on May 24, 2017, Dr. Harris emailed Ms. Qu, “Adib is best situated to make
strategic decisions. I don’t have any suggestions regarding alternative lawyers in Iran.”
97. Princeton’s team and Ms. Qu could barely communicate with Mr. Adib in English.
Despite multiple requests from Ms. Qu, Princeton would not engage a translator other than Ms.
Rahmani who translated a few telephone meetings with the lawyer and failed to even show up in
some of the telephone meetings. Princeton ignored Ms. Qu’s request to engage a translator.
98. Princeton’s inactions coupled with their experts’ nonchalant and unreasonably
optimistic attitude prior to Mr. Wang’s arrest, allowed the situation to further deteriorate.
99. Dr. Rahmani, Mr. Mousavian, and other Princeton employees made the intentional
decision not to utilize their political capital in Iran to assist Mr. Wang. Specifically, Mr. Mousavian
was the former spokesperson for Iran’s nuclear negotiation team and a close friend of the then-
25
Iranian President Hasan Rouhani and Foreign Minister Mohammad Javad Zarif. Despite their
strong ties to the regime, the internal regime contacts Princeton touted in assuring Mr. Wang he
would be safe chose not to utilize their political capital to obtain the return of Mr. Wang’s passport
and laptop, to prevent his arrest or to assist Mr. Wang when he was imprisoned inside the Evin
Prison, notorious for holding and torturing political prisoners.
100. On August 7, 2016, Mr. Wang was picked up by Iranian officials who told Mr.
Wang they were there to take him to the airport so he could go home. But instead, Mr. Wang was
arrested for espionage charges and was taken to the notorious Evin Prison.
Post-Arrest
101. After his passport had been confiscated and during Mr. Wang’s imprisonment,
Princeton insisted to Mr. Wang, Ms. Qu, and later their representatives that the school would
control the efforts to secure Mr. Wang’s release using its contacts, including those close to the
regime. Instead, hoping to preserve those relationships and protect its reputation, Princeton
repeatedly and inappropriately put its interests and Iran’s interests ahead of Mr. Wang and Ms. Qu.
102. On August 8, 2016, after Mr. Wang’s sudden disappearance, Ms. Qu reached out
to her contacts as Princeton as well as Steve Fagin, head of the Iran Desk at the U.S. State
Department for assistance in locating Mr. Wang.
103. A week later, on August 14, 2016, Princeton officials told Ms. Qu that Dr. Adib
had confirmed that Mr. Wang was being held at Evin Prison. Princeton officials provided no other
information.
104. On September 13, 2016, Ms. Qu visited Prof. Haldon in his office seeking his help.
Haldon told Ms. Qu that he would co-sign a letter drafted by Ms. Qu to the Chinese Embassy in
26
Tehran. Haldon asked her not to mention it to Princeton University because that would be against
the University administrators’ express instruction to maintain a low profile.
105. By contrast, Ms. Vrachnos made it clear to Ms. Qu that, in her view as Vice Provost,
Princeton was only responsible to their undergraduate students, and not their graduate students
simply because graduate students “are adults.”
106. Mr. Wang was placed in solitary confinement in Evin Prison. It was not until 19
days later that Mr. Wang was allowed to call his wife. However, during those 19 days, Mr. Wang
was interrogated daily for at least four hours at a time, during which he was repeatedly threatened,
slapped and abused.
107. The emotional abuse and suffering to which Mr. Wang was subjected in Evin Prison
was just as inhumane as the physical abuse he endured. Mr. Wang became dehumanized inside
Evin Prison, which inflicted great physical and mental suffering not only on Mr. Wang, but also
his entire family, especially his wife, Hua Qu, their young son, S.Q., and his mother, Kexu Lan.
108. In addition, Mr. Wang was not able to see any of his family members during his 40
months’ long imprisonment, and he found it particularly painful, psychologically devastating, and
heart wrenching to have missed almost four years of his son’s seven years of life.
109. Having been unlawfully detained in the prime years of his mid-thirties, Mr. Wang
also suffered irreversibly in his academic and professional life.
110. During his confinement, Mr. Wang was severely mentally abused. His Iranian
captors falsely told him that if he made a video where he answered questions he would be let go.
Having made a video of Mr. Wang that was later used for propaganda purpose, instead releasing
him, the Iranian authorities forced Mr. Wang into a false confession, in which Mr. Wang had to
state that he was a spy for the United States. The confession simply read, “I am an American spy.”
27
111. On December 10, 2016, there was a two-day hearing in which a case was created
against Mr. Wang and a formal trial was set for March 2017.
112. On April 26, 2017, Mr. Wang was found guilty and sentenced to ten years in prison
for “infiltration” based upon spurious allegations that Mr. Wang had “gathered secret and top
secret [intelligence]” for the U.S. State Department, among other foreign government entities.
However, the prosecution did not and could not present any evidence of any wrongdoing by Mr.
Wang himself, except for his connection to Princeton University.
113. Mr. Wang wanted to accept the sentence as that would allow him to go to a lower-
security prison, but, at Princeton’s insistence, his lawyer appealed the conviction. This action
forced Mr. Wang to stay in the high security section of Evin Prison for another three grueling
months.
114. Princeton University was grossly unprepared to send Mr. Wang to Iran and unable
to provide the most basic logistical support for Mr. Wang after his arrival in Iran, which directedly
contributed to, and resulted in, Mr. Wang’s arrest, detention, torture, and physical and mental
abuse.
115. Instead of taking action to assist and accelerate Mr. Wang’s release, Princeton
chose instead to protect their own reputation over Mr. Wang’s health and well-being. Princeton
did nothing but try to suppress news about the case while feeding Mr. Wang and Ms. Qu false
assurances.
116. In an April 24, 2018 email to Ms. Qu, Princeton’s lawyer, Kevin Licciardi, reported
that Mr. Mousavian asked to advise Ms. Qu “that his connection with this matter is the worst thing
for Wang” and to stress to Ms. Qu, “and others who communicate with Wang, that there should
be no mention of Mousavian’s name.” Mousavian “instructed that if his name comes up on a call
28
with Wang, [Ms. Qu] and others should . . . say that Mousavian has nothing to do with this case
and that [they] have had no communications with him.” Licciardi told Ms. Qu, “you should also
state that Mousavian’s contacts with Iran (the President and Foreign Minister, etc.) have all been
cut off . . . [and] say that there is nothing Mousavian can do to help in this situation,” even though
that very same email revealed that Mousavian had recently met with the Foreign Minister
117. Princeton directed Mr. Wang to stay in Iran and wait to be arrested, without taking
any preemptive or protective measures. Rather than engaging in a determined, “all hands on deck”
effort to extract Mr. Wang from an ever-worsening situation, Princeton instead was doing
everything in its power to keep the case out of the public eye for their own reputation, both in Iran
and in America.
118. The lack of action and urgency from Princeton is indicative of how they were more
concerned with their institutional reputation and political interest than they were their student’s
health and well-being. Simply put, after encouraging and convincing Mr. Wang to go to Iran,
Princeton chose to put their reputation and political interest ahead of Mr. Wang’s personal safety,
all to the damage of Mr. Wang, Ms. Qu, their son and Mr. Wang’s mother.
119. Princeton could have escalated the case to the highest level of the Obama and
Trump Administrations and pushed for high-level action, especially considering Princeton has a
strong lobbying presence in Washington D.C. Princeton could have used its high-level
international contacts and their own experts to dissuade the Iranian authorities from detaining and
releasing Mr. Wang. Princeton also could have resorted to the national media to create immediate
international public pressure that could have prevented Mr. Wang’s arrest and detention or
accelerated his release.
29
120. Ms. Qu reached out to the office of her Congresswoman, Bonnie Watson Coleman
in spring 2017 to seek her help. The Congresswoman’s office initially showed interest to advocate
for Mr. Wang’s release, but after a phone call with Princeton’s representatives (outside of Ms.
Qu’s presence), the Representative Coleman’s office advised Ms. Qu that there was nothing the
Congresswoman could do to help Mr. Wang.
121. In fact, Princeton even refused to contact former First Lady and Princeton alumna
Michelle Obama in August or September 2016 shortly after Mr. Wang was arrested.
122. Sometime after Wang’s passport was confiscated and before he was arrested, the
Carnegie Endowment for International Peace, advised Princeton to take the case public in the
hopes that national media coverage would put the U.S. and Iranian governments under public
opinion pressure. Shockingly, Princeton did not take this sound advice – rather, they did everything
in their power to suppress the story from national media outlets to protect their own reputation and
political interest.
123. In September 2016, Jason Rezaian, who was also formerly falsely imprisoned in
Iran, heard about Mr. Wang’s case and reached out to Princeton University to offer help. Princeton
turned down his help.
124. Princeton consistently discouraged Ms. Qu from going public until the case was
publicly announced by Iran on July 17, 2017.
125. However, even after Mr. Wang’s arrest was made public, Princeton was
outrageously still discouraging Ms. Qu from speaking out. On July 20, 2017, Princeton emailed
Ms. Qu stating, “The University recommends against submitting a statement for the record. There
is no benefit to be derived.” Princeton’s continued effort to suppress publicity about Mr. Wang’s
case after it was made public continued to put Mr. Wang at risk.. Many experts also believe staying
30
out of the press serves Iran as well because it helps increase political leverage for Iran and increases
psychological pressure on the falsely imprisoned inmates.
126. On July 29, 2017, Kotkin wrote an email to Ms. Qu and others stating that he had
turned down an interview. Despite telling Mr. Wang in 2016 that he “must very politely, very
firmly overcome all of these obstacles” that he encountered from Iranian authorities, Kotkin here
expressed his “strongly held” personal view that “[e]ven a very carefully crafted statement,
translated into Farsi by our side, appealing to the mercifulness of the supreme ruler and the
tradition of mercy in Islam, could be dangerous, by provoking the anger of the regime.”
127. In May 2018, against the wishes of Princeton, Ms. Qu eventually hired a lawyer,
Jason Poblete (“Mr. Poblete”), to assist her and Mr. Wang.
128. In September 2018, Princeton’s representatives, Ms. Rechtschaffen and Mr.
Bellinger, finally met with Mr. Poblete, at which meeting Ms. Rechtschaffen told Mr. Poblete,
incredibly, that these situations just tend to work themselves out.
129. Ms. Rechtschaffen discouraged Ms. Qu from getting other professors, experts,
academic and human rights organizations from within and outside Princeton involved. Ms. Qu
later reached out to experts through her own contacts and was shockingly told, on at least two
occasions, these experts had reached out to Princeton University at the early stages of the case to
offer help, but were rebuffed by Princeton, who advised them that the family did not want any
additional help, although neither did Princeton communicate with Ms. Qu about such help offered,
nor did Ms. Qu inform Princeton that the family needed no such help.
130. Subsequently, the University of Washington Law School’s International Human
Rights Clinic published a proclamation to create publicity and awareness for Mr. Wang, which
31
irritated Princeton as this unwanted publicity put pressure on them to take affirmative action to get
Mr. Wang out of Iran.
131. All, and any, publicity regarding Mr. Wang’s arrest and detention was viewed as a
negative for Princeton and the Princeton Iran Center. Princeton was so concerned with controlling
the public narrative and perception they hired a public relations firm to control their messaging
public perception.
132. Everything Princeton did and abstained from doing was centered around absolving
its institutional responsibility, protecting its institutional reputation, and maintaining its political
relations with Iran. Princeton protected themselves first, hiring lawyers for themselves, refusing to
reach out to experts who may have been able to help Mr. Wang, and trying to suppress Ms. Qu, all
while allowing Mr. Wang rot in Evin Prison.
133. Princeton, one of the most prestigious universities in the United States, with one of
the most visible Iranian Studies Program in the United States, with the Princeton Iran Center so
well-endowed and well-connected, provided ruinous advice and direction to Mr. Wang and Ms.
Qu and failed or refused to properly advise Mr. Wang regarding his safety and well-being.
Princeton deterred steps proposed by Mr. Wang, Ms. Qu, and their representatives to involve other
parties that were willing, able, and had the capacity to help, including lawyers, U.S. government
officials, the Swiss Embassy, and U.S.-based experts on dealing with hostage crises. These actions
by Princeton needlessly and callously prolonged Mr. Wang’s imprisonment and exacerbated the
harm he and the other Plaintiffs experienced and continue to experience to this day.
134. During his imprisonment, Mr. Wang was abused, and his rights and physical well-
being were violated. He was held hostage by the Islamic Republic of Iran, in violation of U.S.
law, for 40 months. Eventually, on December 7, 2019, due to the concerted efforts of Ms. Qu, Mr.
32
Poblete, members of the U.S. Congress, and the Trump Administration, Mr. Wang was freed from
Iran via a prisoner exchange.
Aftermath of Mr. Wang’s Lengthy Imprisonment in Iran
135. Mr. Wang’s unlawful arrest and subsequent detention have caused him to suffer
numerous injuries including but not limited to physical and psychological injuries, emotional
injuries, and other pain and suffering, which injuries are ongoing, all to his damage.
136. Mr. Wang suffered from, inter alia, gastrointestinal disorder caused by enormous
stress that led to approximately 20 pounds of weight loss in his first 18 days of detention. Mr.
Wang continues to be impacted by physical injuries, which have required ongoing medical care
since his release.
137. Moreover, throughout his detention Mr. Wang was held, without cause, in solitary
confinement for extended periods of time causing psychological distress and mental psychosis.
While in solitary confinement, Mr. Wang was kept in a filthy cell with no human interaction, other
than being interrogated. Mr. Wang was subjected to torture, extreme isolation, the brutal conditions
and relentless interrogations and sexual harassment that caused him to attempt suicide.
138. During his imprisonment, Mr. Wang constantly worried for his wife’s, son’s and
mother’s health and safety causing him additional depression and emotional anguish.
139. Mr. Wang has sought and continues to seek medical care from professionals to help
treat him for his injuries.
140. These injuries continue to significantly impact Mr. Wang’s ability to lead a normal
life including making it difficult for him to reintegrate into family life.
33
141. Mr. Wang’s imprisonment has also disrupted his relationship with his wife. As a
result of his imprisonment and torture, the comfort that Mr. Wang and Ms. Qu once provided each
other has been disrupted and continues to suffer, all to their loss and detriment.
142. Mr. Wang’s imprisonment has had lasting negative repercussions on his son, during
a critical time in childhood development.
143. During his imprisonment and thereafter, Mr. Wang had great anxiety and fear over
the suffering his mother was going through. He has become detached from his family and friends
and fears the impact of his experiences, at the hands of the Iranians, will be permanent.
144. Mr. Wang also suffered direct financial loss as a result of his unlawful arrest and
detention. Although he attempted to return to his academic life at Princeton upon his return, he
faced tremendous difficulties: his old project is no longer possible, he needed to start a new project,
but his advisor and Princeton refused to accommodate him and kept pressing him to make
academic progress like any other ordinary third year Ph.D. student, especially under the current
pandemic, only to aggravate his trauma and impair his ability to make academic progress.
145. Incredibly, Princeton’s administration and Kotkin have refused to provide any
mechanism to accommodate Mr. Wang following his unimaginable ordeal of spending 40 months
in an Iranian jail.
146. Mr. Wang also lost personal property because of his imprisonment in Iran. He has
incurred significant expenses since returning from Iran to rebuild his family and professional life.
147. In addition to the injuries suffered by Mr. Wang detailed above, Ms. Qu suffered
her own injuries as a result of her husband’s unlawful imprisonment.
148. Among these were chronic stomach pain, migraines, worsened psoriasis,
sleeplessness, depression, anxiety, constant nightmares, and extreme fear. Ms. Qu sought mental
34
health counseling and was prescribed medication to treat her depression and anxiety. She
experienced extreme depression and anxiety when she thought about the torture and prison
conditions her husband was experiencing in Iran. She also worried about the toll the detention of
her husband was taking on her mother-in-law, Ms. Lan.
149. Ms. Qu’s entire life was disrupted as working for her husband’s release became a
second full time job. Not only was she trying to support her family and young son with full-time
employment, but she also worked tirelessly to advocate for her husband’s release, including
organizing a grassroots campaign, engaging in government advocacy and private diplomacy,
managing public relations, and mobilizing a group of graduate students to provide moral and
intellectual support to Mr. Wang.
150. Ms. Qu also worries about the lasting implications on her son, S.Q., and what the
absence of his father during his critical years of child development have caused, all to his damage.
151. Mr. Wang’s imprisonment also caused Ms. Qu’s career development to be delayed
and disrupted, as she had to spend considerable amount of time working on Mr. Wang’s case
throughout his imprisonment and therefore could not concentrate on building her own career. To
this day, Ms. Qu is still struggling with the consequences of a disrupted and difficult transition
while Mr. Wang’s professional prospects are bleak.
152. Ms. Qu was forced to spend significant sums of money arranging for childcare for
her son in order to allow her the time and space necessary to advocate for Mr. Wang’s release and
continue her own work and studies. Ms. Qu’s parents took turns flying from Beijing to Princeton
to help Ms. Qu. During a period of four years, Ms. Qu’s parents hardly spent time together. After
Mr. Wang’s release, Ms. Qu’s father went back to Beijing and was later diagnosed with
exacerbated cardiovascular conditions.
35
153. Iran’s imprisonment of Mr. Wang caused his son, S.Q., to be deprived of the
service, society, guidance, solatium and consortium of Mr. Wang and to suffer extreme mental
anguish and emotional pain and suffering.
154. Following his father’s imprisonment, S.Q. suffered nightmares, started to exhibit
behavioral problems and disconnected emotionally from his father refusing to speak with Mr.
Wang when he would call from prison. In addition to enduring a physically absent father, S.Q.’s
development was hindered by an emotionally distracted mother as Ms. Qu spent the duration of
Mr. Wang’s imprisonment consumed with securing his release and her continued stress to earn
enough income to support the family and to deal with the traumas.
155. Not only was S.Q. denied the parental guidance from his father at this time, because
Ms. Qu was working tirelessly for her husband’s release, she was required to leave S.Q. for
extended periods of time, sometimes multiple days which caused S.Q. additional fear anxiety
regarding the absence of his mother.
156. S.Q. spent many more hours with babysitters, caregivers and families from his
daycare, which would have otherwise not been necessary had his parents been able to be fully
present in his life at this time.
157. Today, S.Q. continues to suffer from ongoing anxiety and other symptoms of
childhood PTSD and other damaging conditions.
158. Mr. Wang’s mother, Kexu Lan, has also been injured by Iran’s imprisonment of
Mr. Wang.
159. Ms. Lan lost the services, society, guidance, and solatium of Mr. Wang, and she
continues to suffer extreme mental anguish and emotional pain and suffering.
36
160. Ms. Lan had to witness that her son was being held and languishing in Evin prison
for years on end. She suffered the fear and anguish that her son would not survive. She lived in
terror knowing that her son was being held in unimaginable conditions and that he was being
tortured. She feared that her son would not survive, and she would never see him again.
161. Today, Ms. Lan continues to suffer from ongoing anxiety, exacerbated health
conditions, and continues to fear for the health and safety of her son, and his family. She fears that
her son’s imprisonment has forever traumatized their family, and they each will never be able to
fully recover.
FIRST COUNT
(Gross Negligence/Recklessness)
162. Plaintiffs repeat, reallege and incorporate by reference those facts and allegations
set forth in all the foregoing paragraphs as if fully set forth herein.
163. Defendants Princeton University and the Trustees of Princeton, as an institution of
higher learning, maintains a duty to provide a safe environment to its students, whether on campus
or abroad performing research as a requirement of their coursework. Fulfillment of this duty with
respect to students studying abroad includes investigating and assessing the risks associated with
certain countries, advising students as to known risks present in locations considered for
coursework, and implementing safeguards to mitigate against risks. In this regard, it is also the
school’s duty to ensure that its doctoral students all have the option of conducting their research
in countries where risks to their safety, security, health and liberties are limited.
164. Defendants Princeton University and the Trustees of Princeton breached the duties
to Plaintiff Xiyue Wang, and acted in a wrongful, willful, wanton, careless, grossly negligent
and/or reckless manner under the circumstances:
37
a. By failing to exercise even slight due diligence or care in sending the Mr. Wang to
study abroad in the Islamic Republic of Iran, a foreign terror state and enemy country
with no diplomatic ties to the United States and with a history of kidnapping and
holding hostage American citizens;
b. By employing professors loyal to the Iranian regime and hostile to the United States to
educate Princeton students;
c. By encouraging Mr. Wang and other Princeton students to ignore United States
security policy and guidance as it relates to Iran;
d. By advertising opportunities for students to conduct research in Iran;
e. By directing Mr. Wang to perform research for his dissertation in Iran;
f. By directing Mr. Wang to remain in Iran and to continue to perform research after
being notified that he was not permitted to do so on his student language visa;
g. By failing to implement safeguards to protect Mr. Wang in Iran;
h. By failing to appropriately investigate and respond when notified by Mr. Wang that his
computer was likely hacked by Iranian authorities;
i. By counseling Mr. Wang against seeking the help of the Swiss Embassy in Iran after
his passport was confiscated by Iranian authorities;
j. By failing to provide any protection to Mr. Wang and bluntly suppressing Mr. Wang
and his family’s reasonable cautiousness during the three weeks after his passport and
laptop were confiscated and Mr. Wang had been threatened with arrest;
k. By failing to take adequate measures to assist with securing Mr. Wang’s release from
Evin Prison;
l. By interfering with the efforts of others, including, but not limited to, Ms. Qu and the
University of Washington, to secure Mr. Wang’s release;
38
m. By excluding Ms. Qu in Princeton’s communications with third party experts on Mr.
Wang’s case;
n. By deterring the help offered by others and lying to them that Mr. Wang and his family
did not want outside help;
o. By failing to provide accommodation to address Mr. Wang’s reasonable requests after
his release; and
p. By otherwise outrageously and recklessly failing and/or refusing to otherwise take any
and all reasonable and necessary steps to protect Mr. Wang’s liberty and well-being.
165. As a direct and proximate result of the Defendants’ willful, wanton, reckless, and
grossly negligent actions herein described, Plaintiff Xiyue Wang was detained and held hostage in
Iran’s Evin Prison for 40 months, suffering numerous injuries including but not limited to physical
and psychological injuries, emotional injuries, and other pain and suffering, which injuries are
ongoing, all to his damage.
166. But for Princeton’s willful, wanton, reckless, and grossly negligent conduct, Xiyue
Wang would not have traveled to Iran for his studies and research and would not have been
imprisoned and held hostage by Iran.
167. Xiyue Wang’s imprisonment by Iran has damaged all Plaintiffs physically and
emotionally, with injuries including but not limited to Post-Traumatic Stress Disorder, anxiety and
depression. Mr. Wang’s imprisonment has resulted and will continue to result in economic injury
to the Plaintiffs and has caused each of them to suffer significant financial losses, to date and in
the future, in amounts as will be proven at trial.
WHEREFORE, the Plaintiff, Xiyue Wang, seeks a judgment on this count against the
Defendants, Princeton University and the Trustees of Princeton University, jointly and severally,
for compensatory and punitive damages, pre-judgment and post-judgment interest, and costs of
39
suit, including an award of reasonable attorney fees, and such other relief as to this Court may
seem proper and just.
SECOND COUNT
(Per Quod on behalf of Plaintiff Hua Qu)
168. Plaintiffs repeat, reallege and incorporate by reference those facts and allegations
set forth in all the foregoing paragraphs as if fully set forth herein.
169. At all times relevant herein, the Plaintiff, Hua Qu, was and is the wife of the
Plaintiff, Xiyue Wang.
170. During and since returning from his imprisonment in Iran, and due to the trauma
and mental and physical injuries suffered there, Mr. Wang has been unable to contribute to
housework, home maintenance, childcare, cleaning, cooking, and other household tasks; and his
suffered a loss of consortium and the love and affection of and between husband and wife, Mr.
Wang and Ms. Qu, all to their damage. As such, Plaintiff Hua Qu has continued to bear full
responsibility for maintaining her family, as she did when Mr. Wang was imprisoned in Iran.
171. During and since returning from his imprisonment in Iran, and due to the trauma
and mental and physical injuries suffered there, the love, affection and marriage of Mr. Wang and
Ms. Qu has suffered substantially, all to their damage.
172. Prior to Mr. Wang’s imprisonment in Iran, he contributed substantially to
housework, home maintenance, childcare, cleaning, cooking, and other household tasks.
173. Prior to Mr. Wang’s imprisonment in Iran, he had a very loving, warm and intimate
relationship with his wife, Plaintiff Hua Qu.
40
174. As a direct and proximate result of the willful, wanton, reckless, and grossly
negligent conduct of the Defendant as previously set forth, the Plaintiff, Hua Qu, sustained the loss
of services, society, financial support, and consortium of her husband.
WHEREFORE, the Plaintiff, Hua Qu, demands that judgment be entered on this count
against the Defendants, Princeton University and the Trustees of Princeton University, jointly and
severally, for compensatory and punitive damages, pre-judgment and post-judgment interest, and
costs of suit, an award of attorney fees and such other relief as to this Court may seem proper and
just.
JURY DEMAND
The Plaintiffs demand a jury on all issues so triable.
DESIGNATION OF TRIAL COUNSEL
PLEASE TAKE NOTICE that, pursuant to R. 4:25-4, the Plaintiffs hereby designate Anthony
N. Gaeta, Esq. and William A. Friedman, Esq. as trial counsel; and, subject to their admission Pro Hac
Vice by this Court, the Plaintiffs further designate Richard D. Heideman, Noel J. Nudelman, Tracy
Reichman Kalik and Joseph Tipograph as trial counsel.
GAETA LAW FIRM, LLC

Attorneys for Plaintiffs,
Xiyue Wang and Hua Qu
/s/ Anthony N. Gaeta

_____________________________
ANTHONY N. GAETA
Dated: November 3, 2021
41
CERTIFICATION
Pursuant to R. 4:5-1, as made applicable to this Court, the Plaintiffs hereby certify that to
the best of the Plaintiffs’ knowledge, there is no other action presently pending or contemplated in
any Court on behalf of the Plaintiffs against the Defendants Princeton University and its Board of
Trustees, and this matter is likewise not the subject of any pending arbitration proceeding. The
Plaintiffs further certify that no interpreter will be required for trial, nor any accommodation for
disability.
I further certify that confidential personal identifiers have been redacted from documents
now submitted to the court and will be redacted from all documents submitted in the future in
accordance with R. 1:38-7(b).
DEMAND FOR INSURANCE INFORMATION
Pursuant to R. 4:10-2(b), the Plaintiffs hereby demand production of a copy of any and all
insurance agreements (primary and excess) under which the Defendants may be covered to satisfy
part or all of a judgment which may be entered in the action or to indemnify or reimburse for
payments made to satisfy the judgment.
DEMAND FOR ANSWERS TO FORM C AND C(2) UNIFORM INTERROGATORIES
Please take notice that pursuant to R. 4:17-1(b)(ii) the Plaintiffs demand certified answers
to Form C and C(2) of the Uniform Interrogatories set forth in the Appendix to the Rules
Governing Civil Practice.
42
GAETA LAW FIRM, LLC

Attorneys for Plaintiffs,
Xiyue Wang and Hua Qu
/s/ Anthony N. Gaeta

_____________________________
ANTHONY N. GAETA
Dated: November 3, 2021
Of Counsel and Subject to Order Granting

Admission Pro Hac Vice
Richard D. Heideman, Esq.
Noel J. Nudelman, Esq.
Tracy Reichman Kalik, Esq.
Joseph H. Tipograph, Esq.
Heideman Nudelman & Kalik, PC
5335 Wisconsin Avenue, Suite 440
Washington, D.C. 20015
Tel 202 463-181
Email: njnudelman@hnklaw.com
43
Civil Case Information Statement

Case Details: MERCER | Civil Part Docket# L-002281-21
Case Caption: WANG XIYUE VS PRINCETON Case Type: PERSONAL INJURY

UNIVERSITY Document Type: Complaint with Jury Demand
Case Initiation Date: 11/03/2021 Jury Demand: YES - 6 JURORS
Attorney Name: WILLIAM ADAM FRIEDMAN Is this a professional malpractice case? NO
Firm Name: GAETA LAW FIRM LLC Related cases pending: NO
Address: THE MEADOWS OFFICE COMPLEX 301 ROUTE If yes, list docket numbers:
17 NORTH, STE 505 Do you anticipate adding any parties (arising out of same
RUTHERFORD NJ 07070 transaction or occurrence)? NO
Phone: 2019393304
Name of Party: PLAINTIFF : Wang, Xiyue Are sexual abuse claims alleged by: Xiyue Wang? NO
Name of Defendant’s Primary Insurance Company

(if known): Unknown Are sexual abuse claims alleged by: Hua Qu? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? YES

If yes, is that relationship: Business
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO

If yes, please identify the requested accommodation:
Will an interpreter be needed? NO

If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
11/03/2021 /s/ WILLIAM ADAM FRIEDMAN

Dated Signed

W XV S Princeton

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MER-L-002281-21 11/03/2021 3:58:15 PM Pg 1 of 43 Trans ID: LCV20212565806

Anthony N. Gaeta, Esq. Atty. ID: 02214-2001

Richard D. Heideman, Esq. (pro hac vice admission pending)

SUPERIOR COURT OF NEW JERSEY

Plaintiffs, Docket No.: MER-L-

PRINCETON UNIVERSITY and the COMPLAINT WITH JURY DEMAND

Complaint, allege and say:

reckless, willful, wanton, and grossly negligent acts.

2. Specifically, Princeton, by and through its employees, representatives, agents, or

the subjects of Iranian history and politics.

in Iranian prisons to be interrogated, abused, tortured, and emotionally destroyed.

solely to foreign language studies.

alarms raised by Mr. Wang and Ms. Qu with indifference.

desperate and misplaced relationship with the terror-funding, hostage-taking, Western-hostile

turn out to be years of imprisonment and physical and emotional torture.

Wang compounded Mr. Wang’s suffering.

9. In short, at every step, Princeton recklessly, willfully, wantonly, and in a grossly

JURISDICTION, VENUE, AND CHOICE OF LAW

residency and the Defendants’ principal place of business.

was tortured and mistreated in numerous respects.

loss of society and services of her husband.

15. Defendant Princeton University is a private not-for-profit, nonsectarian institution

Princeton University can sue and be sued in this Court.

16. Defendant Trustees of Princeton University is a New Jersey non-profit corporation

The Islamic Republic of Iran

protesters and prisoners of the new system to be several thousands.

currently serves as the protecting power for U.S. interests in Iran.

20. Iran has continued to utilize hostage-taking as a tool of international diplomacy. In

Iran arbitrarily arrested another 30 such individuals, including Mr. Wang.

U.S. government is unable to provide emergency services to U.S. citizens in Iran.”1

Attitudes at Princeton Regarding Iran and its Relations with the US

22. Despite Iran’s well-documented record of kidnapping, sponsorship of terrorism,

materials and media appearances, Princeton academics overly emphasize US imperialism,

towards the political murder of dissidents.

students in a short-lived quest for constitutional democracy.

established by the Shah to promote understanding of Iranian society and culture.

with the U.S. government.

United States and its allies in the Middle East.

Princeton Directed Mr. Wang to Study in Iran

Professor Stephen Kotkin.

Advisee-students’ depend on their advisors’ connections and recommendation letters to land

to defy or even second-guess their faculty advisers’ advice and guidance.

last six years.

coursework, as he contemplated a project that would focus on Ottoman Turkey.

Afghanistan and Iran.

Mr. Wang to study in Iran.

which was approved by Kotkin in mid-November 2015.

the U.S. government were significantly overstated.

going if it would be possible for him to see the Archives.

inside Iran on his foreign language study visa.

to raise concerns about the limitations of his language visa.

language visa “can be handled after the application is submitted.”

Mr. Wang’s Travel to Iran

very firmly overcome all of these obstacles.

extensive network,” including “any of your visa questions and issues.”

dissertation at the Iranian National Library and Iranian National Archive.

was oblivious how this information would be perceived by Iranian authorities.

“abnormal” activities on his accounts. When he contacted Princeton’s Office of Informational

his work in a polite manner, just like his advisor instructed.