Wright v. Dorsey - Responses

VIRGIN I A:
{:'l f ED
IN THE CIRCUIT COURT OF FAIRFAX COUNT\{~/V/1 ,· / ':-,: -.,
··-' '' f,. -.~/\ff"\
• • I :J
JOSHUA WRIGHT, zcn..~r:o

,.__
, I9 /.:>2: 0 I
1115 Theresa Ann Street
McLean, Virginia 22101
. :r
Plaintiff and Counterclaim Defendant
vs. Civil Action No.2023-12232
ELYSE DORSEY,
and
ANGELA LANDRY,
Defendants and Counterclaim Plaintiffs :
ANGELA LANDRY'S ANSv\TER
Joshua Wright all but admits in his Complaint that he pursues inappropriate relationships
v,,ith his law students and subordinates alike. His own allegations indicate he v,as in
1
relationships (self-servingly described as "on again and off again") \vith both Angela Landry and
Elyse Dorsey in the same timeframe, while also their law professor or supervisor and also
married and also, during some of that time, in a relationship with then-GMU law student and/or
subordinate Lindsey Edwards (the woman described in the Complaint as his current girlfriend).
He proudly details the career mentorsbip, opportunities, and assistance be offered to Ms. Dorsey
and Ms. Landry, and the reader is expected to believe he did this out of the goodness of his heart,
and that he never withdrew this support, even when those relationships ended. Yet Wright's
assertion that be never withdrew his professional support for Ms. Dorsey and Ms. Landry after
those relationships ended is untrue, and this lawsuit merely further illustrates the retribution he
seeks when his relationships \Vith those over \\horn he exercises his power do not go as planned.
Wright also ignores a principle intrinsic to sexual harassment law-that the superior·s
position over his subordinates by definition creates an inherent power imbalance and divests
subordinates of the ability to trulv consent.

.., ••
So \\11en Ms. Dorsev and Ms. Landn· sav thev feel
.,J o-' ~ •'
their relationships \;vith \Vright were not truly consensuaL not only is such a statement protected
opinion speech under the First Amendment it is a fitting characterization of the power dynamic
of those relationships.
Apart from the fact that \Vright' s allegations are simply false, his legal theories also fail.
He does not deny he was in sexual relationships with Ms. Landry and Ms. Dorsey, but instead
takes issue with their chamcrerizotion of those relationships. That is the very definition of
1
pro1ected first Amendment opinion speech. Indeed, the title of the Law?,60 article,"' I Suffered
Silently': Ex Law Prof Allegedly Preyed on Students ... describes Ms. Landry· s experience and
ber feelings. The Complaint acknovl'ledges that Ms. Landry ''felt pressured and fearful of
retaliation," "fell that she 'couldn't say no to \Vright' and that she was constantly fearful of what
might l1appen to her professionally if she didn't maintain a sexual relationship with Mr. Wright."
Finally, Wright attempts to paint Ms. Dorsey and Ms. Landry. two of his [many]2
\ ictirns. as "heartbroken .. and "scorned" former lovers. but be can only weave this false narrative
1
Because Wright has pursued claims based on statements immunized from tort liability under
Virginia's Anti-SLAPP (strategic lawsuits against public participation) statute, Va. Code§ 8.01-
223.2, Ms. Landry is filing simultaneously here\vith a plea in bar and counterclaim for dismissal
of this action and recovery of ber fees and costs.
2
In this lav-1suit,Ms. Landry and Ms. Dorsey \Vill show that \Vright had a modus operandi of
manipulating and luring lav,1 students into relationships with him and then threatening to
withdraw professional opportunities and career assistance if they refused to capitulate, and that
his modus operandi with them was similar to how he has operated with others. See also Leah
Nylen, Ex FTC-Commissioner Faces Storm of'Sexual Harassment Claims, Bloomberg,
2
through selective editing of the key communications he relics on and entirely fabricating a story
that suits him. In one email \\/right refers lO in his Complaint but does not attach (an exchange
from 2020 in which be purports to apologize to Ms. Landry for his conduct), he appears to
understand she is anything but a heartbroken, scorned former lover, as he writes:
I\\ as emotionally manipulati\'e, clecepti\'c. and not capable of honest emotional

exchange. I'm sorry. I know you are long past all of that and happy and do not
need to hear any of that from me.
Ex. No. l lO this Answer. Later on in that same email chain, Ms. Landry asks:
Ha\'e you told ;\fason yet about your history of rahng ach antage of frmalc
stuclentsJ
Wright does not lake isstie with that characterization, and instead replies:
l\e clone e\crytliing J'n: told you I \Yould do.
Id.
As Ms. Landry sets forth in greater detail throughout tbis Answer, Wright's
characterizations of Ms. Dorsey and Ms. Landry are imagined. as are his attempts lo portray
negotiations to settle their legal claims- negotiations in which he actively participated with
cotmsel-- as an extortionate '·multi-million dollar demand.''
Simply put Joshua \A/right bas a pattern and practice of using his status, title .. and
amhority to lure in ]av,, students and his subordinates. use them at his sexual disposal. and keep
them quiet ,:,.,hiledoing so. I'his lawsuit is yet another attempt to silence them. They v-.1ill
not be
silenced.
1n furtl1er support of her Answer, Ms. Landry responds to tbe allegations of Wright's
complaint as follows:
https ://vvvvw.bl 00111 berg. com/news/ articles/2 023-0 8-2 8/ ex -ftc-comrnissi oner-faces-storm-of-
sexual-harassment-accusations? em bedded-checkout=true (last accessed September 19. 2023).
3
1. Denied that any tortious conduct occurred. The remainder stales a legal
conclusion.
2. Admitted.
3. Adn1i11ed.
4 Admitted.
5. Admitted.
6. Denied.
7. Admitted that Wright has had many research assistants and students. but Ms.
Landry does not know how many.
8. Ms. Landry lacks information sufficient to admit or deny.
9. Admitted.
10. Admitted that Wright has served as FTC Commissioner and left his position at
GMU to do so, but Ms. Landry does not knovv that he left his position at GIV[U \\ith respect to
am other public service.
11 . Admi1ted.
12. Admitted. except Ms. Landry does not knov-, \l\·hat \\'right and Ms. Dorsey's
awareness was of each other's marital status or of l\•1s.Dorsey's marital status at the time.
16. Admitted.
4
l 9. Admitted. e:-,,:ceptthZll Ms. Lmclry does not know hciv, nrnny academic papers
\\'right and Ms. Dorsey published together.
20. Ms. Landn lacks information sufficient to admit or elem.
11 Ms. Landry lacks information sufficient to admit or deny.
2J. Denied that \Vright broke up with J\1s. Dorsey al that time and further swted that
Ms. Dorsey had already broken up with \\'right al the time he sent this message.
24. Admitted that Lindsn Edwards is the ·'other woman·· referenced rn the first
sentence and admitted that Ms. Dorsey had previously worked with Ms. Eclv,'ards. Ms. Landn
lacks information sufficient to admit or deny the remainder. although does believe Wright was in
a relationship with Ms. Edwards in the late 202 l timefrarne.
25. Ms. Landry lacks information sufficient to admit or cleiw.
Ms. Landn lacks information sufficient to admit or deny.
27. Ms. Landn lacks informalion sufficient to admit or deny.
29. Ms. Landr, lacks information sufficient to admit or deny.
30. Ms. Landry lacks information sufficient to admit or
31. Ms. Landry lacks information sufiicient to admit or deny.
33. De11led.
34. Denied.
35. Denied.
36. Denied.
37. Denied.
5
Ms. Dorsev Learns that Ms. Landrv is Another Victim of \Vright, and the Women
Share thefr Stories
38. Ms. Lanclr\' denies that there is or was any ·'crusade'· and denies that there is or
\Vas any ·'recruiting.'· \Vhen Ms. Landry learned of Wright's abuse of Dorsey, she believed her.
She contacted Ms. Dorsey to share her own experience and mistreatment by \Vright. and 10
support Ms. Dorsey emotional Iv and in her Title lX claim. Ms. Landry's experience with Wright
was similar to Ms. Dorsey's. particularly in hov-.:\\'right le,eraged his power as a professor and
later, a mentor. career ach·isor. and boss. to engage in an intimate and sexual relationship with
Ms. Landry. just as he did \Vith Ms. Dorsey.
39. Denied.
40. Denied. Ms. Landry and Wright \Vere not in a ''consensual sexual relationship."'
Wright \Vas in a position of pmver cl\'er Ms. Landry not only as a professor at her law school generally
but a professor who had control over her grades and v11ho.through the sexual relationship. positioned
himself as a gatekeeper to her career, e\'en af'Lcrshe graduated from lmv school.
The sexual relationship began in approximately 2010. \\'hen Ms. Landry was m \Vright's
contracts class as a l L student. During the first semester, Wright emailed his then-student, Ivls.
Landry, to say what a coincidence it was they had gone to the same undergraduate school and to
offer mentorship and ad\'ice if sl1e needed it.3 Appreciative of his offer to be a resource, Ms. Landry
\Vould meet ,vith him in in his office to discuss or email seeking guidance about school and career
prospects.
3
In February 2020, long after their relationship v-;as oYer, when Ms. Landry confronted Wright
about hov,, he had treated her and others, Wright admitted to Ms. Landry that he vmuld send out
"friendly" emails and other messages almost indiscriminately to v,ornen just to see \Vho \Vould
respond. which would determine if he \vould attempt to pursue them, and that this behavior
began as early as 2004, shortly after he got married.
6
Yet. gradually. \Vright began to cross the line from professional to personal. initially testing
boundaries by. for example. telling Ms. Landry she was '·cute'· \\hen she shifted nervously in her seal
durirn2 their c01werscllions. and eventuallv sayirn.>thirnzs clurin12_

<....-, V •' L..,
their conversations such as. '·I miss
._; <._. ,
you.'· or··] really want to hug >'OU right now.·· Wright told Ms. Landry that he was separMed from his
vviie, but explained he \,.ras still living in the same house so they could figure out how to co-parent
their children.
Eventually. during Ms. Landry's second semester as a l Lone day in Wright"s oiTice. Wright
kissed her. The relationship became sexual soon thereafter. \Vright freguently found ways 10 remind
Ms. Landry 1hat he had influence over her success as a student and the promise of her career. He 1old
her how. despite the school's implemented system of blind grading. he could discern the identity of
the student based on their exam. He did this in part lo brag and in pan 10 convey that he would know
v,foch exam was I'v1s.Landry" s and that he had powcr--for better or for worse---{)VtT the grade she
received. \\'right would also tell Ms. Landry tha1 he was speaking about her to her other professors.
and told her he would tell them \Vhat a good student she was and that they should not '·mess tbis up.,.
/\]though \Vright framed this to suggest he was "putting in a good word" for her \\"ith her other
professors. i1 was equally clear to Ms. Landry that Wright could exert his influence in the opposite
direction.
At the end of her 1L year. Wright offered Ms. Landry a position as his research assistant for
the summer. At the encl of her 2L year, \Vright helped her ob1ain a summer internship at the Federal
Trade Commission. where he was later a presidentially appointed commissioner. Their romantic
relationship continued through Ms. Landry's graduation from law school in 2012. throughout which
Ms. Landry believed thal \Vright was separated from his wife and exclusively seeing Ms. Landry.
(She only later learned that not only was be not separated from his wife, he was also simultaneously in
7
sexual relationships with other people.) \rv'hen Ms. Landry graduated from lmv school and went to
work for her first lm:vfirm. the relationship fizzled out.
·when \Vright was nominated to be an FTC Comrnissioner in 2012. he told Ms. Landry that he
\Vould hire her for a prestigious attorney advisor position in his office in 20 I 5, which he ultimately
did. Once Ms. Landry was back in \Vright's sights as his supervisee once again at the FTC he re-
initiated the sexual relationship. \\hich lasted into late 2015 or early 2016. The relationship died out
not long after \Vright abruptly resigned from the FTC in :?O15 and Yvasno longer Ms. Landry's direct
supervisor and boss. AAer stepping down from the FTC Wright returned 1o teaching at GMll and
joined the firm \Vilson Sonsini Goodrich & Rosati. At the time \Vright started working at Wilson
Sonsini in approximately January 2016. he \\as: ( 1) in a sexual rela1ionship with Ms. Dorsey, who
believed they were exclusive and he was separated: (2) in a sexual relationship with Ms. Edv,;ards; and
(3) still married. Ms. Echvards, it should be noted. was a lm:v student at GJvlU at that time, and bad
also accepted an offer from \Vilson Sonsini to be a summer associate later that year. \\ 1hen Wright
accepted the offer from \\'ilson Sonsini, he kne\\ that he would soon no1 only be Ms. Edwards'
professor, but also her superior at her upcoming job.
Ms. Landry expressly requests a reply pursuant to Rule 3: 11.
41. Denied and further stated that \Vright conspicuously omits quoting a key portion
of Ms. Landry's statement that is right there in his own exhibit: "You can·1 blame me for
leaving a toxic relationship: I want lo move past it: it \\as fucking toxic.'' Compl. Ex. B.
Denied that J\1s. Landry, "like Defendant Dorsey," ·'did not take it welL" and further
denied as to \)-/right's patently false characterization, false context and incomplete quotation of
the email attached to the Complaint as Exhibit B. Wright and Ms. Landry's relationship died Ollt
long before these messages were exchanged, after Wright was no longer Ms. Landrf s boss and
8
supervisor. and once he had re-set his sights on his ne,v supen1see al \Vilson Sonsini. Ms.
Eclv,ards. \\as also pursuing a relationship ,vith J\.1s.Dorsey. and was also still married.
Bv the time of the December

V
2016 messages reflected
,__
in Exhibit B. Ms. Landry and
' V
\Vright' s relationship had ended months earlier, Ms. Landry had met and fallen in lovr with her
now-husband. and she ,.vas long over \Vrigl1t. Vo/right, hmvever, desperately sought to rehash his
relationship with Ms. Landry. ror reasons Ms. Landry did not understand. ln the messages. Ms.
Landry expresses anger that Wright Yvas reaching out to dredge up discussion of their 10xic
relationship. Wright's use of ellipses in his quotation of the messages misleadingly omits Ms.
Landry's slatement reflecting that she did not ,vant to be in a relationship ,vilh him. as stated
above. Ms. Landry expressly requests a reply pursuant to Rule 3: 11.
42. Admitted that Ms. Landry tried to remain on good terms with Wright at the time.
given thal she had already been excluded from \Vright' s "in crO\vd" following the conclusion of
their relationship and gi,en her belief that he maintained control over her career and professional
reputation and ,vould leverage it to her di sad, antage if she ran afoul of him. Denied as to the
characterization that Ms. Landry was being ·'pushed out'" of her law firm. Exhibit C speaks for
itself and all other characterizations and allegations are denied.
43. Fxhihit C speaks for itself and all other characteriz2,tions and allegations are
denied.
44. Admitted that they met for coffee. Exl1ibi1 C speaks for itself and 2,l] other
characterizations and allegations are denied.
45. Denied that Ms. Landry "struggle[d] \Vith finding a job" and denied as to Wright's
characterization of Exhibit C.
46. Admitted that Ms. Landry sent Wright a message that said. in part "Hiiii:·
\Vrighf s Exhibit C to the Complaint shmvs Ms. Landry writing him earlier for career guidance,
9
and \Vright consistently putting her off and rescheduling promised meeting times. After multiple
messages nying to schedule a time to talk .. Ms. Landry exasperatedly \\rites. ··] liiii. Am
thoughts ye() rm sure you·re super busy. Sorry for bugging ym.1.--
47. Denied. This paragraph refers to an email exchange that Wright initiated with
l\•ls. Landn on February 2 L 2020, v,focb Wright intentionally (and comenienth for his
narrative) omitted from his Con1plaint. h is attached to this Ans,nT as Exhibit No. ] . By the
time \\'right sent the February 21. 2020 ernaiL Landry had learned of his paltern of abusing his
power to take advantage ofl1is students and subordinates.LI \Vrigh1 wrote, in rele\·ant part:
Angela,
Please don't respond 110\\ to this be I don't \\ ant ycrn to think I'm sol' a
response or doing it for any reason other than to communicate my sincere
aJ)olo<ry
hv to you. 1 am doirwb a lot of rearrano·in°
L' b b and re-or<"clllizirw
b of lll\',, lifr·
~
right llO\Y. 1t's a project. Some of it is really long O\ tTchw. Senne of those
changes require me being brutally honest \Yith myself about\\ hath c done and
wbo I \Yant to be from here on out. That includes this apology.
l want you to know l arn genuinely frir hO\\ T tn°atecl you. J \\ as

emotionally manipulative, deceptive, and not capable of honest emotional
exchangT. I'm sorry. I lrnmv you are long past a11 of that and happy and do
not need to hear any of that from me. And I'm so pleased for you 1 But I need tu
tell you--even if you don't want or need it or hcl\ e any use for it-- that I am
sorry and that if you eYcr \\'ant to talk to me about anything I'm here for it.
Ms. Landry felt that his outreach was disingenuous. manipulati\'e. and self-serYing. She
in part:
But your email is frustrating ancl maddening. and 1 clesen·e so much better than
this. You started by saying not to respond. Then you explained your selfish
reasons for sending the email. Then you briefly, anc.l at a high le\ eL touched on
the horrible way you treated me.
1
' !n Januarv 2020, Ms. Landrv learned from Lindsev Edwards that. similar to Ms. Landrv's
.., , ,) ,,i , ~'
experience (and nmv, Yveknow, Ms. Dorsey·s experience). \Vrigbt l1ad initiated a sexual
relationship with Ms. Echvards v,hile she \Vas l1is student at GMU. She had further learned from
Ms. Ed\vards that the relationship extended to his role as her supervisor at Wilson Sonsini; that
\Vright had been investigated by and forced to resign from Wilson Sonsini over the relationship:
and that Wright had engaged in sexual relationships \Vith other students and subordinates.
10
Ex. No. 1. (Emphasis added)
In his Paragraph 4 7, \I/right quotes a single phrase from Landry· s response: "l was
willing to do anything to be with \ ou··. ln fact. ihe full sentence. which was part of a much
longer n,essage, reads:
And I was willing to clo anything to lw \\ ith you while you manipulated me
and lied to me and gaslighted me.
Jd. (Emphasis added.)
Wright then offers to ban: a conversation with Ms. Lmclry:
And 1'm committed to changing the \\ 1 treat others aJJd myself amC1ng other
things. 1 know yuu do not need rny a pol But. as a next step. I'd like ~J han'
the com ersation you descrilw below if you are\\ illing·
The two did meet up to talk. on Febnrnry 2020. The remainder of the email thread
reflects a follow up from their conversation. in which Ms. l ,andry states:
Han· you told \~ason about your histon· of taking achan of fomale
students? In that efli.)rt to EKe brutal trmhs \O you can maL.c the changes you
need to rnaJ,,eJ
To which \Vright replied, not with a denial or objection to her characterization .. but
instead with:
J'\'e done eYerything I\·e told you I \\ oulcl. do.
Jd.
In addition, Ms. Landry denies that \\ right' s message was prompted by his ·'then and
current girlfriend." Wright is referring to Ms. Lindsey Edwards. his current girlfriend. Ms.
Edwards ,vas not, contrary to \Vrigl1t' s pleading, his girlfriend at the time he sent this message.
on February 21, 2020. In point of fact, that clay, upon receiving his email, Ms. Landry texted
Ms. Edwards, \Vho was a good friend and who did indeed officiate at Ms. Landry's wedding.
11
Their text exchange 1s attached as Exhibit No. 2. 11 started with Ms. Lanclrv writing 10 Ms.
Edwards:
He srnt mt· a (bullshit) ,qxilogy email.
Ms. Eclwards responded:
\\'cm
So much hc1::-: hc1ppcnccl.
1"11haw 10 fill yot1 in.
I finally blocl,cd his nmnlwr.
The long and short of it is-he ::-:pent a month begging me to forgiYe him and
telling me all this shit ...he \\anted to build his lift. around me, was getting help.
etc .. and _just when I \\ as (stupidly) about to forgin: him. be changed bis mind
and decided lw's going to try to mal,e it \\Orh with [his then-wifr·J.
I told him if lw's going; to as]; her to let him stay then lie needs to tell her the
trntli about C\ erything .. all of it.
I pulled out the moot COUJ t thing after he did this.

He's disgusting /\ngela
Like he should be fired from George ason. He's a foe king predator.
] dun't think he',s actually capable of changing. And it makes me sich to think
about some other ambiguous =si . eager woman going through this.
Ms. Landry replied:
Yeah_ that too. 1 was actttally _just about to say that 1 don't think he shollld be
allowed to be in a position ofp(l\\er like that anymore. He's only shmvn that lie
wants to abuse it.
Ms. Edwards replied:
I\ E: beeu thinking a lot about reporting him. But it has to be after a new dean
comes in becallse Henry will jmt sweet it under the rug.
He's actually a fucl,ing predator.
There have been at least 5 women over 9 years that he's done this to.
That's already ,vay too many.
I also don't ,vant it to end up fucking my deg-ree over

Because he \Yas grading me
Ex. No. 2. (Emphasis added.) This text exchange, among many other things, exposes \Vrighf s
false allegation that Ms. Edwards \Vas his girlfriend at the time or that she was the one who
12
encouraged him 10 ·'make amends'· 10 Ms. Landry. :Ms. Landry expressly requests a reply
pursuan1 10 Rule 3: 11.
48. Denied that 1l1esc are 1he '·,vords of a scorned woman_·· \\'hen the messages are
read in their entirety. they are obviously the words of someone who was ''manipulated."" ·'lied
10:· "'gas[lit]."" and y\']10 is glad 10 be out of a ·'toxic relationship."" Ex. No. l. Denied that JVls
Landry's words were ·'not those of someone who was pressured to be in a relationship.'" as
Wright alleges~to the contrary~hcr words state precisely that fact: ··1 know now that wha1 you
showed me was not love." Wright himself ackno,\lcdges this in the email. conceding that Ms.
Landry is "'long past all of that and happy." ln other words. \Vright" s strenuous effort to depict
Ms. Landry as an angry. scorned lover arc refuted by his o,\·n words.
49. Denied. In April 2022 (not January l, as Wright alleges). Ms. Landry and Ms.
Dorsey connec1ed about their similar experiences with Wright and to support each other
emo1ionally and in pursuit of legal rccomse. Nothing that Ms. Landry said in the Tille IX
irn esligation ,vas false. Every \Vorel \Vas true. See September 14. 2023 Glvll 1 Press Release &
September 14, 2023 Dorsey/Landry Press Release, anached as Exhibit Nos. 3 & 4, respectively.
]\Ifs. Landry and Ms. Dorsey have continued to engage with GMU to address their concerns about
Wright" s predatory conduct.
50. Denied. and further stated that anv professional or financial consequences Wright
has incurred Yvere only proximately cmised by his own insidious. repugnant, disgraceful condt1ct.
and furtberrnorc were not prompted even in pan by any of Ms. Landry or Ms. Dorsev' s truthful
statements.
51. Denied.
52. Denied and further stated that Ms. Landry has no knmvledge of anv such lost
client relationship, ,vhich Wright fails to specifically identify.
13
53. Ms. Landry lacks information sufficient to admit or deny and thercfrwe denies.
54. Denied. A1w statements that Ms. Landrv made to

~ • .'
aiw
~
other law\'er re2ardin2 her
~' '-- L-,
experience ,1,,ith\Vrigbl v/as entirely trne.
55. Denied. Defendants have only ever told the truth. Ms. Landry objects to
\Vright' s reference lo and reliance on pri\ikged setllement comnrnnications and negotiations.
Ms. Landry further states that as a maller of fact. \\.rights reputation \\as already ruined.
56. ]Vis. Landry does not know if the clay Wright rejected a settlement proposal \Vas
the same da\ that she created her "J\vitler account.
57. The Twitter post speaks for itself. Denied as to \Vrigbt' s silly characterization.
"[aJs if taken from a plot in a bad movie.'·
58. Ms. Landry lacks information st1fficien1 to admit or deny.
59. Admitted that Ms. Landry began following Tv,·itter accounts of people she 1s
interested in. The remainder is denied.
60. Admitted.
61. Admit1ed that Law360 published the Article attached to the Complaint as Exhibit
D. The remaining allegations are vague and therefore are denied.
62. Admitted that other news platforms \\Tote stories based upon the Article. The
remainder is denied.
63. The Article speaks for itself and any characterization of it is denied. Denied that
1he T,:=iw%0 Article states any false facts or creates any false in1plications, Wright did abuse his
position as a ]av,, professor to pressure Defendants into having umvelcome sexual relationships
,;,.,·ithhim and then retaliated against them as a result of tbern ending the relationships.
64. The Article speaks for itself and any characterization of it is denied.
14
65. The Article speaks for itself and anv characterization of it 1s denied. Further
denied that lVJs.Dorsn •s account is a lie.
66. Denied thi:11 Ms. Dorsn·s account 1s false: denied as to \Vright's puerile
characterization of it being '·straight out of a bad movie.'·
67. The Article speaks for itself and any characterization of it is denied. Denied that
it is misleading or creates false implicalions. The remainder is denied.
68. The Article speaks for itself and any chan:icterization of it is denied. Denied that
Ms. Dorse, makes any material omissions.
69. Admitted that the other (_;Mu student Wright \\'as having an affair Yvith was
anotber woman who Wright had a relationship \\ith, Lindsey Edwards. All remaining
allegations are denied.
70. The Article speaks for itself and any characterization of it is denied. l remaining
allegations are denied.
71. The Article speaks for itself and any characterization of it is denied. Admitled
that the Article states. in part:
e "Lancli-y said there \Yere often times during their relationship that she frlt she
couldn't sav no to \\'1·ight. ,me! that be often remilJcled her of his conncction.s and
sway \\'hen it came to ber career;" and
® "lf .sl,e =Landry] e\ er did something to maLe him angry in their personal
relationship. she said, it would come through in their profossional relationship
and she \ionlcl stop getting worl, from him fr-ir a period of tinw, for e:xample."
Denied that Ms. Landry made any false or dishonest statement in connection with the
Article. and further stated that her statements in the Article are her O\Vn opinion and
characterization of the relationship.
72. Denied that the relationship was truly consensual. As previously described in this
Answer, a relationship between a student and a professor \Yho controls her grade, or a rnentee
15
and a rnenlOr who controls her ernploymen1. is 1101 consensual. Even after graduating. ]Vis.
Landry felt tha1 Wright was a gatekeeper 10 her career opportunities. because he acted that way.
and did indeed impact and inJh1ence her job opportunities. Denied as 10 \Vrighf s
characterization that Ms. Landry said \\'right \\as "'what she ·wanted· and that she was ·v,illing
to clo anything 10 be \11·ith' [Wright].'. Both quoted phrases are taken from two difTeren1
communications four years aparL and out of context. As previollSly explained in Paragraph 47
of this Ans\ver. in regard to the phrase. ''1 was willing 10 do anything to be with you .. the full
sentence reads. "·I \\as willing to do anything to be \Vitb you while you manipulated me and lied
10 me and gaslighted me ... Ex. No. 1. In regard to the phrase. "ym.1 were what 1 wanted.'. that
was immediately followed by, "You can ·t blame me for leaving a toxic rela1ionsbip: l want 10
move past it: it was fucking toxic:· Compl. Ex. B. Fmthermore. the facts paint a stark picture of
the type of professional '·support" that \Vrigh1 gave to lvls. Landry when he was sleeping with
her, compared to when he was not.
73. Admitted that Ms. Landry made the tv,eet depicted in Paragraph : it speaks for
itself and all characterizations of it arc denied. Ms. Landry told Wright directly on February 22,
2020 that she thought of him as the antitrust worlcr s Haney Weinstein (the disgraced, now-
i1T1prisoned former Hollywood producer whose Yictims launched the oo social n1edia
movement). Wright chuckled at Ms. Landry's suggestion and acknowledged that Ms. Echvards
had made the same comparison.
74. The Article speaks for itself and all characterizations of it are denied. As eYident
from the Article, Ms. Landry's statement that once their relationship was over, ·'those things
stopped coming," refers to seeming Ms. Landry speaking opportunities on panels and inviting
Ms. Landry to write papers and contribute to the antitrust profession. The paragraph in the
Article that Wright refers to is:
16
During· the time \\ hen their se:,.;ual r('latinnship \\ ,le, on. Landry .~aid, \\'rig·ht
helped lwr sect11-e opportunities to s1w,1L on panels. \1ri1e papers and contribute
to tlie antitrust proft'ssion Btlt afrcT \\'right left the FTC and _ioinecl \Vilson
Sonsini, .\he saicl, all of that changed
"Once he\\ as clone\\ ith rnc tliC1se thi stopped coming," she said.
Cornpl. Ex. D. Thus. Landry slated 1ha1 Wrighl' s oflt:ring of opportunities to speak on panels.
write papers together. and otherwise \\'orL to contribute to the antitrust profession. was what
ceased \Vhen their relationship ended. \V1·ight' s statement that he '·went to great lengths to assist
her in her time of professional need·· \vhen she was ing nC\\ employment is not only false.
but it docs not disprove (nor follow) Ms. Landry s statnnent in the Article.
From approximately 2011 to 20 l 5. Wright invited Ms. Landry 10 contribute to or co-
author no fewer than 7 papers/journal articles with him on topics of antitrust law. (In three
different papers in 2012--a time period in which Defendants now know Wrigbt \\'as seeing both
of them-Wright names both l'v1s. Landry and Ms. Dorsey in footnotes as contributors."). ln
2015, \"hen Wright was once again her superior at the FTC and Ms. Landry \Vas an attorney
advisor there, he invited Ms. Landry to be a panelist or co-speaker at four different antitrust
conferences: scyeral in India and one for the 1~merican Bar Association.
Wright did not offer a single writing or speaking opportunity to ]Vls. Landrv afler their
relationship ended.
Ms. Landry expressly requests a reply pursuant to Rule 3: 11.
:iJoshua D. WrigbL The Antitn1sr!Consu111er Protec1io11 Parodox. Two Policies at War ,l'ith Each
Other, 121 Yale L.l 2216 (2012); Joshua D. \A/right & Douglas H. Ginsburg, Behcn-ioral Law
and Economics: Its Origins, Fatal Flm1·s, and lmpliccrtionsf<)r Liberty, 106 Nv1'. U. L. Rev. 1033
(2015); and Joshua D. \Vright, kfoving Beyond ]\'aive Forec!osure Analysis, 19 Geo. Mason L.
Rev. 1 163 (2012).
17
75. The CMU policies. past and present. and the Lmv360 article speak for
themselves. \\'righ1 ·s chan1cterization of those policies. and his implication that 1he violation of
anv such policies is a prercql1isi1e 10 concluding that he is a sexml predator. are denied.
76. Denied that Wrigh1 lost any as-yet-unidentified contracts as a result of the
Law360 article or any other staiement by Defendants. Further. Ms. Landry has no knowledge of
the value of any such contracts that \I/right supposedly ]osl.
Admitted that these hashtags \Vere used. bl1t denied they \Vere used for Ms.
Landn or Ms. Dorsey to "gain notoriety and fame." lnstead. they were used to gain attention 10
the concerning issue of abuse of power in the legal \Vorld.
78. Denied.
COUNT ]-Defamation and Defamation Per Se
79. The foregoing answers are incorporated herein as if fully set forth herein.
80. This paragraph states a legal conclusion to which no answer is required. To the
extent an answer is required, Ms. Landry denies.
81. Denied.
82. Denied.
83. Denied.
84. Denied.
85. Denied.
86, This paragraph states a legal conclusion 10 which no answer is required. To the
extent an ans\ver is required, J\1s. Landry denies.
87. Denied.
88. Denied.
89. Denied.
l8
90. Denied.
9]. Denied.
92. Denied.
93. Denied.
COlJNT H-Tortious lnterfrrence
94. The foregoing ans\:vers are incorporated as if se1 forth fully herein.
95. This paragraph stales a legal conclusion to which no answer is required. To the
extcn1 an answer is required. Ms. Landry denies.
96. Denied.
97. Denied.
98. Denied.
99. Denied.
100. Denied.
COl:NT HI-Statutory Conspiracy
101. The foregoing answers arc incorporated as if set forth fully herein.
102. Denied.
103. This states a legal conclusion to which no answer is required. To the extent an
answer is required. Ms. Landry denies.
l 04. Denied.
105. Denied.
106. Denied.
107. Denied.
l 08. Denied.
19
COUNT IV-Common Law Conspiracy
109. The Coregoing answers are incorporated as if'sel forth fully herein.
110. This states a legal conclusion lo which no m1sv,er is required. To the extent an
answer is required. J\,1s.Landry denies.
111. Denied.
112. Denied.
113. Denied.
114. Denied.
AFFIRMATIVE DEFENSES
1. Plaintiff fails 10 state a claim for defamation because the speech at issue is non-
actionable opinion. In the alternative. the slale::rnents are true.
2. Plaintiff fails to plead the allegedly defamatory statements in !wee ,'erba.
3. Plaintiffs claims are barred under Va. Code§ 8.01-223.2. because the statements
at isst1e pertain to a matter of public concern.
4. Plaintiff fails to plead actual malice, which is required as he is a public figure or
limited purpose public figure.
5. Plaintiff fails to state a claim for tortious interference.
6. Plaintiff fails to state a claim for common law conspiracy or statutory conspiracy.
'7
I• Plaintiffs claims are barred by judicial immunity and/or qualified privilege.
8. Plaintiffs claims are barred in par1 by the statute of limitations.
\VHEREFORK Ms. Landry respectfully requests the Court 1o enter judgment against
\Vrigbt and in favor of Ms. Landry, and for such other and additional relief sought in her
Counterclaim and/or as the Court deems reasonable and just
20
Dated: September 19. 2023 Respectfully submitted.
() 1J]P --
~~ JM !~. 1lClAlW
~) ~- ,H'ns (VSI31No. 6)887)
Allison pf' 1.z11 1a (VSB No. 96400)•
HIRSCHLER FLEISCl-IEJZ. PC
l 676 Internaiional Drive. Suite 1350
Ty sons, Virginia 22 l 0 l
Tel: 703-584-8900
Fax: 703-584-8901
Email: sbarris@hirschlcrlmv.com
aklenata;birschlerlaw.com
Counselfhr Angela l,cmdrr
21
CERTIFICATE OF SERVICE
l ccr1if\ that on Seplernbcr 19. 2023. a true and correct cupy of the this Answer \C\as
served bv hand on:
Jason C. Greaves. Esq.

Lindsay R. 1\1cKasson. Esq.
Benjamin f. North. Esq.
Bi1mall La\Y Circrnp, PLLC
717 King Slreel. Suite 200
Alexandria. VA 223 l 4
Email: jason(c1binnall.corn
lindsav(c?binnal !.com
benra;binnall. com
And by email to:
Roya Vasscghi, Esq.

Kellie Budd, Esq.
VASSEC3HI BUDD PLLC
9663-A Main Street
Fairfax, VA 22031
(703) 215-9358 Tel.
(703) 563-740 l Fax
roya@;sasseghibt1ddlaw.com
kellie@Yasseghibt1ddlav,'.com
Arrorneysfhr Defendcmr Elvse Doney
Counsel
22
E HI I 1
From: Angela (Diveley) Landry <angelamdlandry@gmail.com>
Sent: Tuesday, March 17, 2020 6:58 Plv1
To: Joshua Wright
Subject: Re: Hi
Then that's a yes. Ok.
On Tue, Mar 17, 2020 at 18:55 Joshua Wright <ioshua.wrir1ht@:gmail.com> ,vrote:

I've done everything I've told you I would do.
On Tue, Mar 17, 2020 at 6: 13 PM Angela (Diveley) Landry <angelamdlandrv:'a';gmail.com> wrote:

Have you told Mason yet about your history of taking advantage of female students? ln that effort to face
brutal truths so you can make the changes you need to make?
On Tue, Jv1ar 17, 2020 at 17:32 Joshua Wright <ioshua.wrig!W211.gmail.com> wrote:

No. It isn't. And I don't think for a second you are dumb. But l apologize to you for giving that impression.
And I will leave it at that.
On Tue, Mar 17, 2020 at 5:30 PM A.ngela (Diveley) Landry <angelamdlandrv<a:gmail.com> wrote:
Yes, I understand he didn't mean it in the context I read it when you retweeted it I am not dumb. But the
fact is that those associations can't be broken for me and probably a number of other people. Nor should it
be possible for you. Yet it is.
On Tue. Mar 17, 2020 at 17:26 Joshua Wright <joshua.wright(m,gmail.corn> wrote:

Hi Angela,
I'm sorry this bothered you. The joke Randy Picker made, that I RT'd, 'Was about wearing pants as opposed
to shorts or something more casual like that. It was not about not wearing pants at all --- at least, I did not
read it that ,vay. Didn't even think of that. Though I'm sorry that it suggests to you I'm not taking things
seriously. I am.
josh
On Tue, Mar 17, 2020 at 5:22 PM Angela (Diveley) Landry <an2elamdlandrv/a:gmail.com> wrote:
Funnily enough, remote teaching is probably the best way for you to keep your pants on. The fact that you
think this is funny and worth retweeting confirms that you are not taking anything that happened
seriously. You got fired for not keeping your pants on. People know that. HO\v many people do you think
read this and thought of that first? Can't just be me.
On Sat, Feb 22, 2020 at 14:40 Joshua Wright <joshua.wright(a;,gmail.corn> wrote:

I totally understand that. And I mean no disrespect to you or him. My apologies. I wouldn't either if l
were him based on my past behavior.
If and when you want to have it I will be available for it

On Sat, Feb 22, 2020 at 2:3 7 PM Angela (Diveley) Landry <angelamdlandry(a)gmail.com> ,vrote:
My husband isn't comfortable ,vith me having this conversation with you. I do think it's important, so
maybe eventually ,ve can.
On Sat Feb 22, 2020 at 13 :57 Joshua Wright <ioshua.wright(cu,grnail.com> wrote:

\Vant to do something in the middle? l don't know where you live. Meet at school? I'm getting a sitter -
- but could do like 3?
On Sat Feb 22, 2020 at l :50 PM Angela (Diveley) Landry <angelamdlandrv:a)gmail.com> ,vrote:
l can talk today
On Sat, Feb 22, 2020 at 10:02 Joshua Wright <joshua.wrigbt'.li;gmail.com> wrote:

l travel to LA tomorrov, after the moot court semi--finals until Vv'ednesday (the 26th). How about
Thursday or Friday? Or honestly, I could talk more or less any time today if you could find an hour
soITietime.
On Sat, Feb 22, 2020 at 9:22 AM Joshua Wright <joshua.wright(a)gmail.com> wrote:

Hi Angela,
First, let me say thank you for responding. FWIW the request not to respond was meant to be
something along the lines of communicating that I ,:vas not doing it to induce a response and would
get it if you didn't ,vant anything to do with a discussion with me (or even communication \Vith me).
I'm sorry it came off how it did.
I understand why you are frustrated and maddened by it. I truly do. I wanted to be honest about the
selfish reasons and not hide them. Nor do r or did I ever begin to believe even for a second that
jotting dovm a quick apology and my reasons would be sufficient end the discussion, or make
things OK (for me or you). It is not. I know it is not. It is neither cathartic nor does it make me feel
• like I've done anything particularly meaningful. But I do mean it as a start -- a first step to take of
what I acknowledge are hundreds if not thousands of steps I will have to take to own the
consequences of what I've done and start to make tbe changes I want to make. I'm committed to
taking those steps. l am taking n1any of those steps now. And I'm committed to changing the way I
treat others and myself among other things. I know you do not need apology. But as a next step,
I'd like have the conversation you describe belovv if you are willing.
jdw
On Sat, Feb 22, 2020 at 7:01 AM Angela (Diveley) Landry <angelamdlandrv(a)gmail.com> ,vrote:
I've been struggling with whether I want to respond to you or not, and I decided that I might as well do it or else
I'm going to drive myself crazy thinking about it.
Mainly, J feel obligated to tell you that l deserve better than the apology you've given me, and I think you know
that.
2
Don't get me wrong, I believe you when you say you want to be better, and I appreciate that you reached out.
Also, I'm not mad at you as a general rnatter~I've made my peace with it. I've had the benefit of several years
to process what happened between us, as well as a man who treats me the way I deserve to be treated and who is
legitimately the love ofmy life.
I know no\\· that what you showed me was not love. You acknowledge that you were manipulative and
deceptive, and l suspect I know what you mean when you say that even though you are being really vague. I
have to say it doesn't surprise me now.
But your email is frustrating and maddening, and I deserve so much better than this. You started by saying not to
respond. Then you explained your selfish reasons for sending the email. Then you briefly, and at a high level,
touched on the horrible way you treated me. l was suicidal because of you. I was miserable for years with you.
And I was willing to do anything to be with you while you manipulated me and lied to me and gaslighted me.
J don't know if you thought sending me this email would be cathartic, but 1 want you to know that it shouldn't
be. lfyou want ro apologize for real, it includes a conversation where you are honest with me and you have to
actually intcrna lize the things that you did to me. I don '1 need that conversation to get on ,,,ith my life happily-
though I have to admit, I have a morbid curiosity about what you have to say. But i'fyou really want to be, in
your words, brutally honest with yourself about what you've done, it means facing the brutal truth and the
consequences of your actions.
To be clear: J don't need to feel better about all of this, and I don't need your apology. But I don '1 ,rnnt you to
treat others the way you treated me. No one deserves it. So if you want to change, you should do whatever you
can to change, and 1 support it wholeheartedly, even if that means dredging up the past and re-experiencing the
pain and trauma you caused me.
So let me know if you want to talk.
On FrL Feb 21. 2020 at 00: 14 Joshua Wright <joshua.wrightr'Zl:gmail.com> wrote:

Angela,
Please don't respond nm.v to this be I don't want you to think I'm soliciting a response or doing it
for any reason other than to communicate my sincere apology to you.
I am doing a lot of rearranging and re-organizing of my life right now. It's a project Some of it is
really long overdue. Some of those changes require me being brutally honest with myself about
what I've done and vvho I want to be from here on out. That includes this apology. I need to come
to grips ,vith that before I can meaningfully move forward, make meaningful and honest and real
commitments to myself and to others, and more generally to be happy with myself much less to
bring something to the table for as a genuine and deserving partner. lt's a process. But that's
vvhere I'm working to get. And I'm determined to get there. I know those sound like really selfish
reasons to apologize - and that's probably right. But here I am. As late as it is.
Again, please don't feel the need to respond to me. I knovv you understand at least some of the
context here. But this is a message to you and, all things equal, I'd prefer you keep it that way -
though that is up to you obviously. I want you to knO\v 1 am genuinely sorry for how I lrealed
you. I was emotionally manipulative, deceptive, and not capable of honest emotional exchange.
I'm sorry. I know you are long past all of that and happy and do not need to hear any of that from
me. And I'm so pleased for you! But J need to tell you - even if you don't want or need it or
have any use for it - that I am sorry and that if you ever want to talk to me about anything I'm
here for it.
Thank you for listening.
3
Josh
Angela Landry
**please note new email address**
Sent from my iPhone. Please excuse brevity and typos.
Angela Landry
Sent from my iPbone. Please excuse brevity and typos.
Angela Landry
Angela Landry
Angela Landry
Angela Landry
Angela Landry
4
E HIBIT 2
If I wake up in time I'll come to yoga! I'm so tired I'm not sur·e that will
happen. I should be able to stop by tomorrow night though.
Ok!
My afternoon has devolved into a ton of work so I prnbably won't be able to

make it tonight. How was yoga??
Missing you! Sorry you got so much work! Yoga was good. I almost did a
headstand lol. I thi:11<I'm gonna try to go to that class weekly
Wow!! That's gr-eat. I don't think I'll eve1· be able to do that lol
I love that class though the instructor is awesome
Yeah she was super helpful with the headstand too!
Was it as packed today?
Almost. I still had my face in people's butts haha
So we're out at dinner· but gonna head to dogwood tavern soon. You wanna
join??
He sent me a (bullshit) apology email ...
Wow
So much has happened
I'll have to fill you in
I finally blocked his numbei-
The long and short of it is - he spent a month begging me to forgive him

and telling me all this shit ... he wanted to build his life around me, was
getting help, etc .... and just when I was (stupidly) about to forgive him, he
changed his mind and decided he's going to try to make it work with-·
Completely gutted me all over again.
Oh Jesus
Well, I blow it doesn't feel like it, but I really feel like this is the 1·ight
outcome for you. You deserve so much better
I know that I do. I just loved him so much. I know I shouldn't have even
considered it but I couldn't help myself.
But I have finally accepted he can't give me what I want.
It was the most crushing thing in the entire vvorld for him to choose her
after everything.
Also he had wr·itten her an email saying all the same things he was saying
to me
He loves a good sentimental email apparently
Wowwww
1'111so sorry
I'm just so fucked up over all of it
I'll be in therapy the rest of my life trying to get past this
Oh mine isn't sentimental. It's a copy paste that's all filler and one line
acknowledging what he did to me
Jesus
You'll make it past this. If I did, you will too
It actually doesn't acknowledge anything at all
I wonder if that means he told her about you
And she's making him do that
It admits he was "emotionally manipulative, deceptive, and not capable of

honest exchange"
And that's it
LOL
The rest is a bunch of stuff about how he needs to say he's sori·y (without
actually saying it till later)
I told him if he's going to ask her to let him stay then he needs to tell her
the truth about everything ... all of it
It's not the apology I deserve, and it sc1eams that he's doing it to make
himself feel better. It's not sincere
And then I called her and said you have a lot to learn, lady. Good luck.
Ha wow
Good for you
He told me everything and I SOMEHOW was willing to forgive him. And took
it as him owning up to things. But now I know all of it.
And I have her numbei- ready to go anytime he thinks he can just get away
with all of it.
(Obviously I would neve1· give her your name)
Savage. I love it
And thank you
I was 1·ight about everything
Yep
!\Jot related, are you gonna be at the symposium? (Obviously nothing to talk
about the1·e)
Or the moot court competition tmrw
Absolutely not
Absolutely not
Thought you might say that ...
I pulled out of the moot court thing after he did this
Makes sense
Ugh
I was actually thinking about you
My heart is broken for you. I'm so so1-ryabout all of this
I don't k11owhow you ever walked back into that building
I can't
I stepped back from things fm a bit, which helped
He bette1· hopes he never fucking sees me at a professional event
Yeah I get it
It was hard to rnalize that I wasn't pa1·t of the in crnwd anymme (and still
sometimes was until you and I talked--which has put a whole new
perspective on everything)
But it felt good to not feel so despe1·ate for attention and to know that I'm
doing things on my own and without that cloud of "do I 1·eallydeserve this"
over it
Yeah I get that
I just have no desire to be a part of any of it anymore
I just know too much now
I don't. I\Jot that crowd anymore
Yeah
He's disgusting Angela
I know!
Like he should be fired from George mason. He's a fucking predator.
I 1·eally want to reply to the email and tell him that this isn't the apology I
deserve. I don't want him to feel better because he sent some stupid email
I agree
You should. That's such bullshit. I wonder if I'll get one.
I was hoping you at least got a conversation
Oh I made him tell me he was choosing her over me
He was just trying to disappear
What a dick
And I said absolutely fuck that, I will show up at your front door
Then he called pretty quick
Hahaha
Ok about to get to mason, so let's catch up later ...
Loi ok tell him I say hi if you see him
Please
Just to watch him fucking cringe
Hahaha oh god
Please do it Angela
Obviously with a smile so others don't know
But then he'll know we talked (which is fine with me)
I don't earn
I told him I'm talking to every single person he's slept with
That will make him realize I make good on my prnmises
Do you know for sure who the others are now?
Yep
I have to know ...
We'll get d1·inks
You really don't ... want to know
It's fucking honendous
I just need confirmation on two ...
The answer is yes
Loi so he didn't admit that one to me but I'm sure it happened
Also, \rJhile he was with me and you
■ when he was with you
when he was with me
Some other r·andom woman from CA when he was with you
The reason I ask about - is that she told me a year or so ago that she
was seeing someone I know and that they'd make it public when it was
approp1·iate
1-1,L\H/-\HAHAHAHA
OrviG
So absolutely yes
I hope you make him fucking squirm today
It is so tempting
Also you should listen to that song
It's amazing
lwill!
I think - has heard something ...
What do you 11"1ean?
She mentioned wanting to have a chat about something WSGR related but
it's i-eserved for another· time and place
Oh interesting ... I wonder what it is. I think she was applying for a job there.
Ohh
lnter·esting
/l,nd not awkwar·d in any way whatsoever· for any of us. Ha
{I'm not supposed to know that)
I saw on calendar that she was meeting - for coffee to

soeen her ...
Loi yes obviously not awkward at all
Did you say anything about it??
No, I haven't told her any of that

I drunkenly told her about Josh one night a long time ago and we talked
about it once after that
Oh I meant about B to
What would I tell about - that's bad?? I told her - is g1·eat
Oh I see
Nothing bad. Just that you saw it 01·something
Ohhh yes I did say that I saw it!
Like "oh hey what's this meeting??"
/.\h ok
told me not to mention it to her that I knew
Ohhh ok
Because she didn't want - to think she was telling ever-yone
Before - was ready to formally come in
Gotcha
So she's interviewing or just talking?
I think just talking because she hasn't come back for a full rnund of
interviews
Gotcha
How was symposium?
Did you talk to him?
It was good. He let's rally was only there for the Chopra part
*literally
I know he noticed me there though. It was a lot wei1·der than I thought it

would be
1 satnext to mis KA wno stanea our conversation ta1K1ngaoout now mucn
he fucking loves him
I can't decide if I should 1·eplyor not
I just really don't want him to feel better fo1·sending it lol
You should absolutely tell hi1,1that it's not sufficient
So he knows that you know it's bullshit
God I really fucking hate him
I think I've decided on - I don't need your apology, but I deserve a better
one than this, and if you i-eally want to change, it means a real apology,
facing the brutal truth, and having to hear· and internalize the actual
consequences of your actions, which I'm happy as hell to make happen
It's the only way he's ever going to be able to be not a shithead. Face the
consequences of his actions
Totally agree. And I think that's a good response. I don't want to influence
your decisions about what to say/not say to him. I just want him to finally
have to face all the fucked up shit he's done.
Agreed
He s~id he wants to change. If that's true, it means actually knowing the

pain he's caused, not just saying so1·ry in an email
I don't think he's actually capable of changing. And it makes me sick to

think about some other ambiguous, eager woman going through this.
What if she isn t as strong as you were? And as I was?

1
Yeah that too. I was actually just about to say that I don't think he should
be allowed to be in a position of power like that anymore. He s only shown
1
that he wants to abuse it
l 1 ve been thinking a lot about reporting him. But it has to be after a new
dean comes in because Henry will just sweet it under the rug.
Ugh
He's actually a fucking predator
He is
And I think I need time to step back and process and deal with it myself
before I could do sornething like that.
That makes a ton of sense
But the more I think about it the more difficult it becomes to swallow that
this can/likely will happen to someone else
I don't know that I have the stt-ength to do it in my ovvn, but if/when you're
ready, I'll do it with you
I already let it happen to you and god knows who else. He can't be allowed
to do it again
I'll definitely let you know if I decide to do it befo1-e I go. Like I said, I can't
do it now. It would be too traumatic and I don't think I can behave rntionally
1·ight now.
But he should have to own up to and pay for the shit he's done.
There have been at least 5 won,en over 9 yea1-sthat he's done this to
That's already way too many
It is
I sent him the email, and i ended up talking to him today
Oh wow
I told him that ther·e's no way he can ever be honest with himself and
change if he continues to let the school think nothing evei- happened
He said he's going to tell the school
/\nd ■
What
f\Jo way he tells the school
I know
I don't buy a fucking word he says. I told him to tell me when he's told the
school. I'm not going to back down on this
Did he say he's staying with her?
No, but I didn't ask
I told him to stay the fuck away frorn you
And that if he ever tries to convince you he's changed, I will intervene
I doubt I even get so rnuch as a bullshit apology like you
FWIW (and his word has no actual meaning, of course) he said he's not
going to talk to you again until he feels like he's made changes blah blah
blah
So I said oh you mean neve1·.K.
Wow
He just needs to do you a favor and let you move on with you1· life. He
doesn't dese1·ve a place in it
I mean I'm so interested in him saying he's going to tell the school
Right??
What is he going to tell them?
I don't want him controlling the conve1·sation
Yeah, I know
I also don't want it to end up fucking my degree over
Because he was grading me
I thought of that too
I want to control that
I don't think it will
There's no situation whe1·e he admits something happened (and I am a

subject of this too) and they punish us
•••••• , I Ic::;01Iy 11Ut-JC:: yvu IC:: !!~Ill
I still think it's highly less likely something happens if we are affirmatively
the ones going to them
But maybe not
This is a man who was in a position of power and used it to have

relationships with at least three of his students
I can tell him to just tell them about me if that would make you feel better
!\Jo no, I just want assurance that he's not going to fuck ove1-my degree
I don't know what I would do if that happened, I feel like I've literally
already lost eve1-ything else
I .iust really can't see that happening
Ok, I trust you
I can't believe he talked to you about it today
I was su1-1xisedtoo
And on short notice
Yeah
Did he say anything else about me?
Yeah, but it was really in the context of these are all the women
Did you ask him about-?
I mostly just gave him a lot of shit for what he did to me
Good for you
He said nothing happened with her
Hmmm
I asked him to tell me everyone
He gave me the list he gave you

Probably just gave you the same list he gave me
Yup
Took him a minute to think of ■
He swears he only slept with her once
I oon't think that's the truth
For many reasons
Hahahahaha he said he didn't sleep with her
Hahahaha
He said that to me first and I screamed at him to get out if he couldn't tell
the truth
And he said "ok fine, I slept with her once"
Because I knew she had gone to I\JYwith him once
Because saw them on the Amtrak back together
Oh wow
Which of course was not just a weird coincidence
Ha, so he even lied to me again today
Yup
Shocking
He can't help himself
Yeah
I asked him to list everyone

He gave me everyone but. and was like "well what do you mean, like
slept with or had inappropriate texts or what"
And I said a step after texting
He didn't tell me about but I'm cet"tain that happened
- has made comments before about how she knows they talked
inappropriately
And she probably went off the deep end because he made her crazy, like
he did to all of us at one point or another
Oh veah!
Yep
Btw I did talk to - today ...
I had forgotten about her when I had the conversation with him though so
didn't bring her up
What did - sav
She knows, and other people at know
-told her
About all of it?
And he told-
She said other people she's hea1·dfrom don't know it's vou
l\lo, and I can't remember his lust nume now, but her friend -
Oh ... I wonder how he knows
Yes
So they just think Josh was fired for having a relationship with an
associate?
Well he's at WSGR, so ever·yone knows

E HIBIT 3
Strengthening systems to prevent and respond to employee
misconduct
Septe,1,ber "1'1, 2023
rcvisec ano stre,:gu1e1ecj Policy ··)0,1 u· expanc ar·1cff\Drc cicarlv deiP!(~ w?,,:it art· p:'o!:ihitf:"C' v,;pl prohli):l1qg
otte1-r1ptsat 1nit:ati 11g prohibiteo \110:at1on::, policy wii result d1supi::1e \/P to c11w1~c1~(.l1r·,g tenn1nat1c•; /.~i,facult} an<'. CC
et:!l1plelc
" l\l:a'.:>o(•
:·;as cii'ianced prtvet1tiu1: ,:1:·1ci
educat10;·. p1ogcam:: 1r1creasedr1t. number of tl",=:w1ings offere.c: We. !·;0ve !:':XpGnciecoui
reporting to allow an ano:"1y:-r,ousself-rrporting opt:oi: for Tille I)<report:-,. !V,usun wii aise:
1
c for:r1ai ci·;anne: tc seek feecfoack frorc i;1div:d;Jais
wno engage \Nitr. t'."'leTitle I/~office al tt1e rnnck1sior: of U1eir rnau.r:1, (:q(. Wf v,,t <JSZ·'.
thal feedbocL ru c.onlinuously :rnprove the serviu~s and rcsp:)nses
w0 provide.
1,tiasonwil: be ;;ddi•1g rnorr s1gnagF on carnp:Js witi: 1:\formatior about Fol icy··: 2.0/4cine!its sexua: misc1ndi.JC'.policy fiow to repon vic1ations, ano
resour~~esavaiiab!e tc stude·1t:, and It v,1d: also cont1;111cl{) cornrnun1caLE-t!1i~ informat1or- t"c stucic,rw: 111roug~- ;-mt~::)ther means
" (v\as-::v:wil' enhd;Ke the tT~-J1ni11g and supp:Jrt (incl\idlng ,;1l!o::,;-1t1ng
appropnc1te tirnc ouring work hot w;) fo1 its crnployee..:.1,vt10voiLnleer serve
2,dvisnrs ~·er inv::1!-vcci the Titie :>;process. Tr1c,seemployee:: pro\-':de support 2'ic.i aovicc re those involVt'Ci in i::;Title IX Tlai"lrr
iJlason \Vil; continue le use externa: heanng officer,·, to cr:ind:Jct Title iX hcar1r:g~ a11dwii· erisure rhat i'ieutrolity c,pz;1·arno,H1t
v,1r1er~ ch~:;osi1·1g fuwrE twarit"J,gofficers
nevv policies anci prac:1n::~,tc prevc!1t

'.onNa1<~
to hrmg alit:gaU.ir1:, of scxua! 1rn::,c;_,r1duc~ an:entic;n.
recently is~<.1eoc press rejeas_ev.rhich can he-fpL.JrH:here
I GlobeNewswire
I
Elyse Dorsey and Angela Landry Commend George Mason

University on Important Changes to its Policies and Practices ford
Policy changes include stricter prohibitions on faculty-student romantic and sexual
·isler
relationships 5 enhanced training for employees; and additional procedural safeguards
in Mason's Title IX Process
!~EWSPROVIDEDBY
SanfNd Heisler Sha1·p LLP
Sep 14, 2023, 9:00 AM ET
ARLINGTON, Va., Sept. 14, 2023 (GLOBE NEWSWIRE)-- Elyse Dorsey, Esq. and Angela Landry, Esq. today commended George
lv\ason University ("Mason") on a I·ange of efforts to address and st1·engthen the pI·evention of sexual misconduct. Ms. D0I·sey
and Ms. Landry aI·e graduates of George Mason's Antonin Scalia Law School and worked with Mason to help info1·m the
changes.
"No person should be denied the benefits of a Mason expe1·ience because of thei!· sex, or face discrimination or sexual
harassment," said Ms. Dorsey. "We commend Mason for taking important steps to expand its commitment to protect students
and employees from sexual discrimination and ha1·assment."
The following are among the changes that Mason is implementing, some of which were announced in August:
., Mason has revised its policy t·egarding romantic and sexual relationships between employees and students to expand and
mot·e clearly define when such relationships are prohibited and to explicitly prohibit attempts to initiate such
relationships. In addition, the policy also states that violations will result in discipline up to and including tern1ination.
,. Mason t·equires that all employees take a training on its revised prohibited 1·elationships policy and 1·equiresall employees
to certify that they understand the 1·evisedpolicy, are in compliance with the policy, and will comply with it going forwa1·d.
e Mason will continue to info1·m students of its prohibited relationships policy and provide 1·esou1·ces
and reporting options
via postings on ca111pusand email communications throughout the year .
., Mason will enhance the training and resources (including allocating appropriate time during work hours) for its internal
Title IX adviso1·swho provide support for individuals seeking to engage with or al1·eadyinvolved in the Title IX process .
., Mason will establish a fonnal channel to seek feedback from individuals who engage with the Title IX office at the
conclusion of their mattei- for continued improvement.
., Mason will continue to use neutral external hea1·ing officers for its Title !X hearings and will enslHe that neut1·ality is a
paramount selection uit:e:-ia when choosing futu1·e hearing officers.
"Not all students have known where to turn fo1·advice about discrimination or have confidence that they will get the help they
need," said Ms. Landry. "We are hopeful that these changes at Mason will assure individuals that the university has increased
protections in place, resources for those who may experience disuimination, and that the school takes their concerns
seriously," she concluded.
Ms. Dorsey and lv'!s.Landry r·eported sexual misconduct in late 2021 and eady 2022.. It has been previously reported in the
media that, at the conclusion of an exhaustive investigation into allegations of misconduct, Professor Joshua D. Wright
1·esignedhis tenu1·ed position r·ather than face a termination proceeding.
"Power dynamics at work or in school are real," added Russell Kornblith, Pa1·tnerand Gene1·alCounsel of Sanfmd Heisler Sharp,
LLP and an attorney for· Ms. Do1·seyand Ms. Landry. "We are pleased to see Mason taking steps to strengthen guardrails on
relationships and to protect against the possibility of abuse. \Ne are proud to have assisted our· clients in sharing their
expe1·iencesand informing these changes," he said.
About Sanford Heisler Sharp
Sanford Heisler Shar-p is a public interest and civil 1·ightslaw fir'm with offices in New Yo1·k,Washington, DC, San F1·ancisco,Palo
Alto, Atlanta, Baltimo1·e, t'1ashville, and San Diego. The firm focuses on employment discrimination, Title iX, wage and hour,
whistleblowe1· and qui tam, criminal/sexual violence, financial services, and Asian Ame1·ican litigation and finance matters. Our
lawyer·s have 1·ecovei-edove1·$1 billion for om clients through many ,1erdicts and setticrrn:»,ts.
In 2022, The National Law Journal named Sanfo1·d Heisler Sharp Civil Rights Firm of the Year, and it recognized the finn in 2021
as both the Employment Rights Firm of the Year and the Human Rights Firm of the Year. Law360 recognized the firm as
Employment Practice Group of the Yea1 in 2021, 2019, 2018, and 2016. Benchmark Litigation recognized the firm as the Labor &
Employment Firm of the Year in 2021 and 2020.
For the latest news about Sanford Heisler Sharp, visit the fam's news1oom 01·follow the firm on Facebook, Lir,kedin, or Twitter.
If you have potential legal claims and a1·e seeking counsel, please call 646-768-7070 or
email dc1vid.sanfo1dtg:sanfmdheisler.com. Attorneys at Sanford Heisler Sha1·pwould like to have the opportunity to help you.
1
For more info1·mation, contact Jamie Moss, newsPRos, at 201-788-0142 or Jamie@newsprns.com.

NOTE: This content is not written by or endorsed by "8News", its adve1·tise1·s,or Nexsta1·Media Inc.
For inquiries or corrections to PressReleases.,please reoch out to C.!c!:,cNc,,,,s1vi1e.
VIRGIN I A:
r-:·! I_ r::. r.,
IN THE CIRCUIT COURT OF FAIRFAX COUNlf:l'_: , ·:~ -:-:'.-~':·:•-;
JOSHUA WRIGHT, ~.:Pl 9 P 2: 0 I

1.CZ3
McLean, Virginia 22101 ...r
I I\:; , t '· / ' ./:\
Plaintiff,
vs. Civil Action No.2023-12232
ELYSE DORSEY,
and
ANGELA LANDRY,
Defendants.
DEFENDANT ANGELA LANDRY'S DEMURRER
Defendant Angela Landry ("Ms. Landry" or "Defendant"), by counsel and pursuant to Rule
3 :8 of the Rules of the Supreme Court of Virginia, submits this Demurrer to Plaintiff Joshua
Wright's ("Plaintiff' or "Wright") Complaint, and in support thereof, states as follov,'s:
1. As to Count I (Defamation and Defamation Per Se):
a. The Complaint fails to allege the defamatory words with particularity or, "in haec
verba," as the lav,, requires. Plaintiff fails to plead the precise defamatory words at issue and
therefore cannot meet the threshold pleading requirement.
b. To the extent Ms. Landry can discern the alleged defamatory statements attributed
to her, they are protected, non-actionable opinion speech and/or they lack requisite defamatory
"sting."
') As to Count H (Tortious Interference):
a. The Complaint fails to state a claim against .Ms. Landry: fails 10 properly identif)
the contracts at issue: fails to allege facts to shmv that Ms. Landry interfered ,;vith those particular
contracts: and fails to allege improper means required for tortious interference with an at-will
contract.
3. As to Count HI (Statutory Conspiracy):
a. The Complaint fails to state a claim for statutory conspiracy (Count IlJ) because
individual employment interests are not protected under the Virginia business conspiracy statute.
b. The conspiracy is not pled ,vith sufficient particularity.
4. As to Cm.mt IV (Common La,v Conspiracy):
a. The conspiracy is not plecl \Vith sufficient particularity.
5. As to aH Counts:
a. As set forth in Defendants' Plea in Bar filed concurrently hercwitb. Plaintiffs
claims are barred by Va. Code§ 8.01-223.2.
b. To the extent Plaintiffs claims rely on acts and conduct in connection v,ith pursuing
the Title IX Complaint including acts incident to raising the claims, discussing 1l1eclaims ,vith
uniwrsity officials. preparing the complaint. participating in the claims, or settling the claims,
those acts are judicially privileged and cannot be the basis of anv tort claim. To the extent
Plaintiffs claims depend or rely on these acts. they fail.
c. To the extent Plaintiffs claims rely on Count I (defamation) to survive. they fail
because Count I fails.
2
cl. To the extent that Plaintiff is pleading negligent or intentional infliction of
emotional distress. there is no cause of action Cor conspiracy to intentionally inflict emotional
distress in Virginia and further. Plaintiff fails to plead facts to support either claim.
e. Plaintiff fails to plead any facts sufficient to support his requests for special or
punifrve damages.
f. Plaintiff also fails to plead any facts sufficient to support his request for injunctive
relief.
Ms. Landry will file a memorandum in support of this Demurrer \Vhen this rnaller is noticed
for hearing.
WHEREFORE, Defendant Angela Landry respectfully requests that this Court sustain her
demurrer and dismiss the Complaint in its entirety. witb prejudice: strike Plaintiffs requests for
special damages, punitive damages, and injunctive relief; and grant Stich other and further relief
that the Court may deem appropriate.
Dated: Septernber 19, 2023 Respectfully submitted,.
SB No. 887)
Allison P. No. 96400)
HIRSCHLER FLEISCHER, PC
1676 International Dri-ve, Suite 1350
Tysons, Virginia 22101
Tel: 703-584-8900
Fax: 703-584-8901
Email: sbarris(ahirschlcrlaw.com
aklena aihirschl erlaw.corn
1
Counse!fi:x Angela Lam.by
3
1 hereby certify that on this 19th day of September, 2023. a true and correct copy of the
foregoing DEMURRER was served by hand delivery upon the following:
Jason C. GreaYes
Lindsay R. McKasson
Benjamin F. North
BINNALL LAW GROL'P. PLLC
717 King StreeL Suite 200
Alexandria.VA 22314
T: (703) 888-1943
· F: (703) 888-1930
jason@;binnall.com
l indsey(q:binnall .com
ben(cii,binnall .com
Attorneys/or Plainrif(Joshua TFright
And by email to:
Roya Vasseghi (VSB No. 85122)

Kellie Budd (VSB No. 72084)
VASSEGHJ BUDD PLLC
9663-A Main Street
Fairfax. VA 2203 l
(703) 215-9358 Tel.
(703) 563-7401 Fax
roya@vasseghibuddla\v.com
ke l lie(d'vasse2:hibuddlaw. com
"--' l..,
AtrorneysfiJr Defe11dc1111
Elyse' Dors(v
4
VIRGINIA:
IN THE CIRCUIT COURTOF FAIRFAXCOUNTYZGZ3

S~?'9 P I: :·b
JOSHUA WRIGHT,
1115 Theresa Ano Street
I •, • I 1 1
McLean, Virginia 22101
Plaintiff,
vs. Civil Action No. 2023-12232
ELYSEDORSEY,
and
ANGELALANDRY,
Defendants.
Defendant Elyse Dorsey's

Answer to Plaintiff's Complaint
Joshua Wright first sexually assaulted Elyse Dorsey when she was twenty-three years old
andhad just finished her first year of law school at George Mason University Antonin ScaliaLaw
School. At the time, Wright was Ms. Dorsey's law professor, a decade older than her, and he had
been laying the groundwork to force a sexual relationship on Ms. Dorsey from the moment that
they met, making flirtatious comments and providing her with opportunities such as serving as his
research assistant so that be could be close to her. Wright was also married and openly discussed
his familyto lure Ms. Dorseyand other young and susceptiblefemale students into feelingsafe
around him. In the summer after her first year of law school, Wright invited Ms. Dorsey to join
him on a trip to California to meet clients. When they arrived, Ms. Dorsey realized that Wright
had only bookedone hotel room, with one bed, and that there were no client meetings set up.
Instead, the two went wine tasting. Ms. Dorsey was thousands of miles from home, in a remote
location away from any friends or family, and she felt very vulnerable.
At the end of that trip, while the two were alone in the single hotel room and on the single
bed that Wright gave Ms. Dorsey no choice but to sleep in, Wright asked if he could touch Ms.
Dorsey. In that moment, Ms. Dorsey felt powerless to say no to her law professor and now her
direct manager-especially since he had made it clear that he was the gateway to obtaining a job
in antitrust law. She did not verbally say "no" and Wright proceeded to touch Ms. Dorsey's
genitalia and asked her to touch him in a similar way. When they returned to Virginia, Wright
continued to pressure Ms. Dorsey to have sex with him, including in his office on the law school's
campus. Ms. Dorsey resisted at times, but eventually gave in, feeling unable to say no to Wright
given that he was her direct manager and knowing his position and reputation with GMU and the
legal community as a whole.
While Wright cherry picks facts and communications to paint a picture of a consensual
relationship and a "scorned former lover[,]" the full story shows a sexual predator, who by his own
admission had sexual relationships with many of his law students and subordinates, 1 who rewarded
Ms. Dorsey when she submitted to his sexual demands by offering her connections to prestigious
opportunities, and who iced Ms. Dorsey out either when she would not submit, or when he was
occupied with a new female student distraction. This pattern continued until Ms. Dorsey was
finally able to get physical distance from Wright in the fall of2021 and realized the years of trauma
and psychological abuse that Wright had subjected her to.
1 These women include Lindsey Edwards, who is referenced in the text messages attached to
Wright's Complaint and who is identified by Wright as his "live-in" girlfriend and numerous other
women named in Ms. Dorsey's Title IX Complaint, some of whom have made their own
allegations against Wright. See Compl. ~ 24.
2
In December of 2021, Ms. Dorsey finally had the courage to file her Title IX Complaint,
which launched multiple investigations into decades of sexual harassment, assault, and abuse of
power by Wright. Wright ultimately resigned his tenured position-after approximately twenty
(20) months of investigation-rather than face termination proceedings. After Defendants declined
to continue with settlement discussions in the Title IX proceedings because they refused to keep
their stories quiet in an effort to educate and empower other women who had been subjected to
similar abuse, Wright went on the attack in a complaint that willfully ignores and distorts critical
facts in an attempt to control the narrative and immunize himself from liability for his own false
statements and omissions. 2
Ms. Dorsey submits the following in support of her Answer to the allegations in Wright's
Complaint:
JURISDICTION
1. The allegations in Paragraph 1 of the Complaint comprise a legal conclusion to
which no response is required.
THE PARTIES
2. Ms. Dorsey admits that Wright is a Virginia resident residing at 1115 Theresa Ann
Street, McLean, Virginia, 22101, and is therefore a resident of Fairfax County, Virginia, and that
Wright was a law professor at George Mason University Antonin Scalia Law School ("GMU").
Ms. Dorsey lacks knowledge and information sufficient to form a belief as to the truth of whether
Wright is currently a lawyer in private practice, and the same is, therefore, denied.
2 Because Wright has pursued claims based on statements immunized from tort liability under
Virginia's Anti-SLAPP (strategic lawsuits against public participation) statute, Va. Code§ 8.01-
223.2, Ms. Dorsey is simultaneously filing a demurrer, plea in bar, and counterclaim for dismissal
of this action and recovery of her fees and costs.
3
3. Ms. Dorsey admits the allegations in Paragraph 3 of the Complaint.
4. The allegations in Paragraph 4 of the Complaint are not directed at Ms. Dorsey,
therefore, Ms. Dorsey is not required to respond to the factual allegations in Paragraph 4 of the
Complaint.
THE FACTS
5. Ms. Dorsey admits that Wright is an attorney. Ms. Dorsey denies the allegation that
Wright resigned from his position voluntarily-Wright resigned from GMU in lieu of termination.
6. Ms. Dorsey lacks knowledge and information sufficient to form a belief as to the
allegations in Paragraph 6 of the Complaint, and the same are, therefore, denied.
10. Ms. Dorsey admits that Wright worked at the Federal Trade Commission ("FTC")
and served as FTC Commissioner at some point in time.
12. Ms. Dorsey admits that "[w]hile teaching at GMU, Mr. Wright met Defendant
Dorsey[,]" that"[ e ]ventually, they began a romantic relationship[,]" and that both were married at
the time. Ms. Dorsey also admits that both were aware of each other's marital status; however, at
the time, Ms. Dorsey was in the process of obtaining a divorce, which Wright also knew.
4
13. Ms. Dorsey denies the allegation as phrased that "Mr. Wright and Ms. Dorsey
maintained a close relationship over the next eleven years, sometimes in a romantic capacity and
sometimes not, but always as close friends and colleagues." When Ms. Dorsey refused to submit
to Wright's sexual demands or when the two were otherwise not engaged in regular sexual activity,
Wright ignored Ms. Dorsey, did not "support[]" her "career," and did not actively help her. Ms.
Dorsey denies the remaining allegations in Paragraph 13 of the Complaint.
14. Ms. Dorsey admits that she graduated from law school in 2012 and that Wright
wrote her a letter of recommendation for her clerkship; however, other professors also wrote her
letters of recommendation-a letter of recommendation from whom one has worked, or been a
student of, for several years is not atypical. Ms. Dorsey further admits that she ultimately accepted
a position with Wilson Sonsini Goodrich & Rosati ("WSGR"). Ms. Dorsey denies that when she
"finished with her clerkship, Mr. Wright helped her secure interviews with several firms, including
Wilson Sonsini Goodrich & Rosati, where she accepted a position." Wright merely provided Ms.
Dorsey with the name and contact information for a connection of his whom he told her that she
should reach out to. Ms. Dorsey received her offer from WSGR in the fall of 2012, at the beginning
of her clerkship and not when she "finished with her clerkship[.]"
15. Ms. Dorsey denies that Wright "continu[ed] to support her in any way he could,"
or that he "helped her interview with different 'think tanks,"' or government agencies. Ms. Dorsey
did not interview with any "think tanks." Ms. Dorsey denies the remaining allegations in Paragraph
15 of the Complaint.
16. Ms. Dorsey admits that she successfully secured positions at the FTC and the
Department of Justice ("DOJ"). While Ms. Dorsey and Wright were in an ongoing sexual
relationship when Ms. Dorsey interviewed for the FTC and DOJ positions Wright references, Ms.
5
Dorsey denies that she secured these positions because of Wright. Ms. Dorsey denies the remaining
allegations in Paragraph 16 of the Complaint.
17. Ms. Dorsey denies the allegations in Paragraph 17 of the Complaint. When Ms.
Dorsey left the DOJ, she was sure at that time that she did not want to enter academia immediately,
nor did she have any desire to go to graduate school. At this time, Ms. Dorsey was continuing to
regularly engage with Wright sexually, and Wright pushed the idea of entering academia or
completing a fellowship on Ms. Dorsey as an added "bonus" of joining his own law firm, Lodestar
Law and Economics, PLLC ("Lodestar"). At that point in time, Ms. Dorsey wanted to either move
to big law, private practice, or in-house. Ms. Dorsey seriously explored the possibility of moving
in-house with both Apple and Amazon and ultimately turned down the positions, both which she
was highly interested in, so that she could pursue the path that Wright pushed her towards in his
effort to keep Ms. Dorsey close.
To the best of Ms. Dorsey's understanding, Wright mentioned to a couple of professors
that she was looking for a fellowship. While Wright told her that he had successfully raised funds
for her fellowship, which she would allegedly begin receiving in fall of 2021 as her fellowship
began in August of 2021, she received no funding in 2021. Indeed, once Ms. Dorsey made clear
that she would not continue in a sexual relationship with Wright, Wright stopped responding to
her inquiries about the funding and its status altogether. While Wright paints a picture of a "scorned
lover" who would not stop contacting Wright after he broke off the relationship, he omits the fact
that Ms. Dorsey was his employee and reliant upon him for multiple streams of income, and thus
her efforts to reach out in October and November of 2021 were to obtain payment for her work.
To the best of Ms. Dorsey's knowledge, Wright stopped actively working on the funding after
their sexual relationship ended and did not resume working on the funding until he was notified
6
that GMU was investigating him. Ms. Dorsey did not receive any funding until after the Title IX
investigation was opened.
18. Ms. Dorsey denies the allegations in Paragraph 18 of the Complaint as phrased.
Wright pushed Ms. Dorsey into the University of Virginia ("UVA") fellowship and working for
his finn in conjunction with the fellowship. Ms. Dorsey did not work for Wright's firm so Wright
could "help her financially while (she waited] for her fellowship at UV A to begin." Both her
contract at Lodestar and her fellowship began in August of 2021. Moreover, Wright had been
recruiting Ms. Dorsey to work at his law firm for months-telling her she could help to shape the
firm's workload and run her own matters, all while seeking her input on matters, including what
to name the firm, potential website designs, and who to hire. Ms. Dorsey had other lucrative job
offers and opportunities, which she ultimately turned down, relying on Wright's assurances about
being able to make a significant amount of money through his firm on an ongoing basis. Indeed,
Wright was assuring Ms. Dorsey that he "clearly had the work" for her to continue with and was
planning to send her additional projects and firm equipment as late as October of 2021-but he
abruptly and unilaterally, and with no prior notice to Ms. Dorsey, terminated her contract once the
sexual relationship ended. Wright was in no way doing Ms. Dorsey a favor with the position at
Lodestar.
19. Ms. Dorsey admits that she and Wright authored five (5) academic papers together.
However, Ms. Dorsey and Wright only published papers together while they were actively
involved in a sexual relationship.
20. Ms. Dorsey admits that she and Wright traveled together, however, she only
traveled with Wright when they were sexually involved.
7
21. Ms. Dorsey admits that she, at times, shared personal details with Wright. Ms.
Dorsey denies the remaining allegations in Paragraph 21 of the Complaint. Unfortunately for Ms.
Dorsey, Wright felt the need to disclose deeply personal details regarding her family, which are
wholly unrelated to any of Wright's meritless allegations, publicly in the body of the Complaint.
22. Ms. Dorsey admits that she shared with Wright that on one occasion she was
sexually assaulted by a prominent member of the antitrust bar. Ms. Dorsey denies the remaining
23. Ms. Dorsey denies that "in late October 2021, Mr. Wright ended the off-an-on [sic]
romantic relationship with Defendant Dorsey in a text message[.]" Ms. Dorsey had already ended
the relationship with Wright prior to that text message. Ms. Dorsey admits that, in that text
message, Wright admitted that he was seeing another woman and that Wright admitted who it
was-Lindsey Edwards, Ms. Dorsey's former colleague at WSGR and Wright's former student,
research assistant, intern at the FTC, and subordinate at WSGR. See Ex. 1. Ms. Dorsey denies the
remaining allegations in Paragraph 23 of the Complaint.
24. Ms. Dorsey admits that Wright has described Ms. Edwards as now Wright's live-
in girlfriend and has no reason to contest this assertion. Ms. Dorsey denies Wright's
characterization that Ms. Edwards "was not just any other woman." Ms. Dorsey admits that she
had previously worked with Ms. Edwards at the same firm. Ms. Dorsey had known Ms. Edwards
since Ms. Edwards was in law school, and Ms. Dorsey helped Ms. Edwards obtain her position at
WSGR.
Ms. Dorsey denies that "[ d]uring that period, Mr. Wright and this other woman had been
in a romantic relationship[]" and that Ms. Dorsey "knew about the relationship at the time .... "
Indeed, Wright adamantly denied to Ms. Dorsey until early 2020-well after Ms. Dorsey left
8
WSGR in May of 2018-that he had any romantic relationship whatsoever with Ms. Edwards. At
that point in early 2020, Wright admitted only that he had engaged in a sexual relationship with
Ms. Edwards for a few months in 2019, but that he had ended that relationship, had no interest in
seeing or speaking with Ms. Edwards, and had cut off all communications with Ms. Edwards. Ms.
Dorsey chose to believe Wright because, during this time, Wright would regularly speak ill of Ms.
Edwards, both personally and professionally, via WhatsApp messages to Ms. Dorsey. Wright
called Ms. Edwards names and informed Ms. Dorsey that Ms. Edwards was the "absolute worst"
and that Ms. Edwards had called and harassed his now ex-wife multiple times. See Ex. 2.
On February 13, 2020, after Wright profusely apologized to Ms. Dorsey for his
manipulative behavior, as he often did, at 1:00 AM, Wright and Ms. Dorsey had the following
message exchange regarding Ms. Edwards:
Joshua Wright: Also, Lindsey does have to die.

I know you'll keep feeling badly
And I'm sorry
And yes we should keep talking
Also remember how I told you that I spoke to Lindsey and told her
no chance all over?
Remember?
Like just now
Wanna know what happened after
Elyse Dorsey: Lol. Yes, I do
Joshua Wright: That I JUST learned about?
Elyse Dorsey: Oh God

What now?
Joshua Wright: This bitch called vinh 3 again
Ex. 2 at 1.
3 Vinh Wright was Wright's wife at the time of this exchange.
9
On August 11, 2020, at 9:34 PM, Ms. Dorsey reached out to Wright via WhatsApp after
Ms. Edwards' had her name included on a published paper with Wright, despite that Ms. Edwards
herself contributed very little to the paper. See id. at 2. In response, Wright messaged Ms. Dorsey,
only one to two minutes later, and the following conversation ensued:
Joshua \i\/right: She's not winning at the profession
Elyse Dorsey: There just seems like very little good incentives
Joshua Wright: She is on a piece where everyone knows she was basically RA and
drafted to help judge [Judge Ginsburg] and I
Nobody giving intellectual credit
Also - I say nice things online because I want people to think I'm
nice
It helps w the job
She is an associate
And will be
And not a principal either as a thinker or whatever
And won't be
You will be
Her being on a paper doesn't change that
I'm sorry she was on paper
And I'm sorry I had looser policies on co authoring later in career
than I did before
And also was at wsgr and needed the help etc
But also you're on a ton of papers and everyone knows how smart
you are
Ex. 2 at 2. Approximately one (1) month later, on October 13, 2020, in another conversation, this
time at 4:05 PM, Wright proceeded to tell Ms. Dorsey intimate details about his assumptions
regarding Ms. Edwards' sex life and call Ms. Edwards a liar, including saying, among other much
more explicit and personal things:
Joshua Wright: Just know she was sleeping around a bunch ...
... she slept around
And she lies and says things sometimes
10
Id. at 3-4. Ms. Dorsey understands Wright is now admitting to a much longer sexual relationship
with Ms. Edwards, which likewise began while Ms. Edwards was his law student and Research
Assistant at GMU. Wright engaged in the same grooming and predatory behaviors with Ms.
Edwards that he did with Ms. Dorsey, rewarding her for engaging in a sexual relationship with
him by promising her opportunities and prestige in the antitrust world.
Ms. Dorsey denies the remaining allegations in Paragraph 24 of the Complaint.
Ms. Dorsey expressly requests a reply pursuant to Rule 3: 11.
25. Ms. Dorsey denies Wright's characterization that she was "incensed." Paragraph
25 of the Complaint refers to Exhibit A, which shows that Wright told Ms. Dorsey not to join a
professional call because he was sleeping with another former student, and which speaks for itself.
Any allegations beyond the face of Exhibit A are denied.
26. Ms. Dorsey denies the allegations of Paragraph 26 that "[ s]he proceeded to send a
series of angry text messages" as phrased. Further, Paragraph 26 of the Complaint appears to refer
to Exhibit A, which speaks for itself. Wright omits that Ms. Dorsey was his employee at the time
and was reliant upon him for multiple primary streams of income and that Wright refused to
provide her with any information regarding her ongoing work or payment for the same. Any
allegations beyond the face of Exhibit A are denied.
27. Ms. Dorsey denies the allegations in Paragraph 27 of the Complaint. Ms. Dorsey
did stop by Wright's office toward the middle of November of 2021. She did so because she had
reached out to Wright, as well as his staff, regarding several outstanding professional items,
including funding for her fellowship-as she had received no money and no word on status and
was concerned about paying her bills-the ongoing research projects Wright and Ms. Dorsey had,
11
the GMU LLM class Wright had offered Ms. Dorsey to teach, again, in the Spring 2022 semester,
and their joint leadership positions in professional groups. See Exs. 3-9.
Wright failed to respond to Ms. Dorsey's emails inquiring about her fellowship money and
firm projects. See Ex. 3. As of November 15, 2021, Ms. Dorsey still had not heard from anyone
about the payment for her fellowship funding, and she still would not know or have received her
funding come late-January of 2022, despite her repeated attempts to reach out and inquire as to the
status of such. See Exs. 4-6, 10. Likewise, Wright completely stopped responding to Ms. Dorsey
concerning several projects that they were in the middle of. See Ex. 11.
28. Ms. Dorsey denies the allegations in Paragraph 28 of the Complaint. As stated
above, Ms. Dorsey visited Wright's GMU office to discuss payment regarding several professional
matters which were critical to her financial safety, including funding for her fellowship. Wright
invited her into his office and had a conversation with her. At the end of the conversation, Wright
asked her to leave his office because he was late for a call. Ms. Dorsey did so and sat in the Global
Antitrust Institute ("GAi") office to collect herself after the conversation. Ms. Dorsey then left
GMU in an Uber to get back to her hotel.
29. Ms. Dorsey denies that her communications "were unwelcome by Mr. Wright's
girlfriend." Ms. Edwards never told Ms. Dorsey that her communications were unwanted. See Ex.
12. Ms. Dorsey had Ms. Edwards' phone number and had been in contact with her previously as a
former colleague and someone whom she recommended to and advocated for an associate position
with her former firm, WSGR. After Ms. Dorsey learned that Wright had been lying to her and had,
in fact, been seeing Ms. Edwards during the same time that he was with Ms. Dorsey in October of
2021, Ms. Dorsey reached out to Ms. Edwards and the two exchanged text messages. See id.
12
30. Ms. Dorsey denies the allegations that she repeatedly contacted Wright's assistant
in an attempt to reach Wright or to disparage him. Ms. Dorsey only contacted Wright's staff
regarding professional issues, including funding for her fellowship, as stated in Paragraph 27
above, and information regarding the teaching positions that Wright promised her at GMU' s law
school, but later gave to someone else. See Exs. 3-10. Again, these communications were in
October through early December of2021-when Ms. Dorsey was back in DC and was finally able
to collect from Wright's assistant several of her personal belongings that Wright had kept in his
home for months and to return her Lodestar laptop. See Ex. A at 7 ("And can I just come grab my
things from you?"); Ex. 11.
did continue to follow up with Wright and his staff periodically for information on professional
matters that implicated her ongoing financial stability and professional opportunities.
32. Ms. Dorsey denies the allegations in Paragraph 32 of the Complaint.
35. Ms. Dorsey admits that she filed a Title IX Complaint with GMU on December 12,
2021, based on Wright's sexual harassment, abuse, and retaliation from the time that she was a
first-year law student through the fall of 2021, in an effort to protect other vulnerable students from
continuing to experience the same misconduct. By December of 2021, Ms. Dorsey was deeply
concerned that Wright had engaged in a clear pattern of abuse, extending across his entire time as
a law professor at GMU, in which he subjected female students to inappropriate sexual comments,
advances, and relationships, and frequently conditioned professional support on their acquiescence
to this conduct-or retaliated for non-acquiescence. At the time of this filing, Ms. Dorsey was
13
aware of at least eight (8) other women with whom she believed Wright solicited a sexual
relationship with and provided allegations and evidence of the same. See, e.g., Ex.13. In response
to this filing, GMU opened multiple investigations into Wright's alleged misconduct and hired
outside investigators, who spoke with multiple former and current students, as well as faculty and
staff, over the approximately twenty (20) months that followed. Ultimately, in August of 2023,
Wright resigned his tenured position at GMU rather than face termination proceedings.
In a September 14, 2023, press release, GMU announced policy changes made in light of
revelations from these investigations, and stated: "Mason wants to thank Elyse Dorsey and Angela
Landry, two alumni of Mason's Scalia Law School, for working with Mason to inform and
implement several new policies and practices to prevent and respond to sexual misconduct. With
their consent, Mason can share that these brave women courageously came forward to bring
allegations of sexual misconduct to the university's attention. Mason is proud to count Ms. Dorsey
and Ms. Landry as alumni." See Ex. 14.
Ms. Dorsey denies the remaining allegations in Paragraph 35 of the Complaint.
Ms. Dorsey expressly requests a reply pursuant to Rule 3: 11.
36. Ms. Dorsey denies the allegations in Paragraph 36 of the Complaint. Paragraph 36
of the Complaint refers to Ms. Dorsey's Title IX Complaint, which speaks for itself, and Ms.
Dorsey denies any allegations in Paragraph 36 that are inconsistent with the language of the Title
IX Complaint itself.
37. Ms. Dorsey denies the allegations in Paragraph 37 of the Complaint. Paragraph 37
of the Complaint refers to Ms. Dorsey's Title IX Complaint, which speaks for itself, and Ms.
Dorsey denies any allegations in Paragraph 37 that are inconsistent with the language of the Title
IX Complaint itself. Paragraph 37 of the Complaint further refers to the text messages of Exhibit
14
A, which speak for themselves. Any allegations inconsistent with the content of the text messages
in Exhibit A are denied.
and Ms. Landry were not in contact for several years after graduating from law school, as a result
of Wright pitting the two of them against one another and sowing distrust between them while they
were both his law students and research assistants and while he was engaging in sexual
relationships with both of them. At the ABA Antitrust Section Spring Meeting in April of 2022,
Ms. Dorsey confided in a mutual friend as to what she was going through relating to Wright. Ms.
Dorsey understands that this mutual friend shared Ms. Dorsey's story with Ms. Landry, who then
reached out to Ms. Dorsey and confided her own experiences with Wright while Ms. Landry was
a law student and Wright's subordinate at the FTC, and Ms. Landry expressed her desire to help
protect other vulnerable women from experiencing the same feelings of abuse and isolation at
Wright's hands.
39. Ms. Dorsey denies that she spoke with anyone to attempt to "recruit" them to falsely
accuse Wright of sexual misconduct. Wright groomed and preyed on Ms. Dorsey, Ms. Landry,
Ms. Edwards, and other female students and subordinates. While Wright may not view abusing
his position and power by coercing his female students and subordinates into having sex with him
as "sexual misconduct," it is not illegal for Ms. Dorsey or any other woman that he preyed on to
share their story and it is necessary for more women with similar stories to have the courage to
come forward.
Complaint. Wright always denied any sexual relationship with Ms. Landry to Ms. Dorsey
15
whatsoever. To the extent any response is required and/or Paragraph 40 makes allegations against
Ms. Dorsey, Ms. Dorsey denies the allegations in Paragraph 40 of the Complaint.
Complaint. To the extent that any response is required and/or Paragraph 41 makes allegations
against Ms. Dorsey, Ms. Dorsey denies the allegations in Paragraph 41 of the Complaint. Further,
Paragraph 41 of the Complaint refers to the WhatsApp messages attached as Exhibit B, which
speaks for itself. Any allegations beyond the face of Exhibit B are denied.
Complaint. Further, Paragraph 42 of the Complaint refers to Exhibit C, which speaks for itself.
Any allegations beyond the face of Exhibit Care denied.
Any allegations beyond the face of Exhibit C are denied.
16
Complaint. Wright told Ms. Dorsey in 2019 that he had heard from someone else at Ms. Landry's
previous firm that she would be leaving, but he denied being directly in contact with Ms. Landry
herself and, instead, told Ms. Dorsey that Ms. Landry accepted a job at her current firm without
telling him. Paragraph 46 of the Complaint appears to refer to Exhibit C, which speaks for itself.
Any allegations beyond the face of Exhibit Care denied. Further, there are no emojis in any of the
emails from March of 2019 contained in Exhibit C, and the same is, therefore, denied.
Complaint.
Complaint.
50. Ms. Dorsey denies the allegations in Paragraph 50 of the Complaint. Defendants
engaged in protected activity and made truthful statements regarding Wright's predatory behavior
and abuse of power. That Wright has faced negative professional or financial consequences as a
result of his own actions is not attributable to Defendants.
17
only made truthful statements. Further, other woman have come forward with similar allegations
against Wright. See Ex. 13.
only made truthful statements regarding Wright's conduct.
only made truthful statements regarding Wright's conduct. Further, to the extent Wright is relying
on privileged settlement negotiations, Ms. Dorsey objects to the same. Ms. Dorsey denies any
responsibility for Wright's already tarnished reputation. See, e.g., Ex. 13 ("Wright's questionable
behavior was an 'open secret' for years, and current and former George Mason law students
described a whisper network warning women to steer clear of him.").
57. To the extent that Paragraph 57 of the Complaint refers to the tweet and meme
included in Paragraph 57, those speak for themselves. Wright's unnecessary commentary- "[a]s
if taken from a plot in a bad movie"-and any allegations beyond the face of the tweet and meme
are denied.
58. Ms. Dorsey denies the allegations in Paragraph 58 of the Complaint. To the extent
that Paragraph 58 of the Complaint refers to the tweet and meme included in Paragraph 57, those
speak for themselves. Any allegations beyond the face of the tweet and meme are denied.
18
61. Ms. Dorsey admits that Law360 published an article on August 14, 2023, but denies
that the Law360 article was the beginning of any public information that Wright is a sexual
predator, as this first hit the news at least as early as August 7, 2023, seven (7) days prior to the
publication of the Law360 article, after an X (formerly, Twitter) post by Professor Christa Laser
tagging Wright and detailing her own inappropriate experiences with him as hiring chair at
GMU-which Wright notably omits from his Complaint. Two (2) days later, on August 9, 2023,
Above the Law published an article entitled "We Shouldn't Have To Say This, But Job Interviews
Are Not Your Personal Dating App" discussing Wright's misconduct and attaching the August 7th
tweet, and other news platforms re-printed it. See Ex. 15. Moreover, at least one (1) online account
began posting "harmful memes" relating to this inappropriate conduct at least as early as August
101\ i.e., four (4) days prior to the publication of the Law360 article. See Ex. 16. Further, as stated
above, Wright's reputation amongst students was well known long before any article was
published. See, e.g., Ex. 13 ("Wright's questionable behavior was an 'open secret' for years, and
current and former George Mason law students described a whisper network warning women to
steer clear of him."). Indeed, Wright made his own very public X account private no later than
August 8th,as a direct result of the "public devastation" that began well before the Law360 article
was published on August 14th . See Ex. 17.
62. Ms. Dorsey admits that other news platforms published their own articles, including
The Daily Mail UK, Law.com, and Above the Law. However, Ms. Dorsey lacks knowledge and
information sufficient to form a belief as to what the other news platforms based their articles on,
and the same is, therefore, denied. See Exs. 18-20.
63. Paragraph 63 of the Complaint refers to Exhibit D, which speaks for itself. Any
allegations beyond the face of Exhibit D are denied. Wright used his position of power as Ms.
19
Dorsey's law professor and direct manager to coerce Ms. Dorsey into having a sexual relationship
with him that lasted on-and-off for years. Wright dangled professional opportunities in front of
Ms. Dorsey to entice her to submit to his sexual demands whenever he wanted to resume the sexual
relationship.
64. Paragraph 64 of the Complaint refers to Exhibit D, which speaks for itself. Any
allegations beyond the face of Exhibit D are denied. As stated above, Ms. Dorsey was under the
impression that the trip to California in 2010 was business related and she was surprised to find
that Wright had booked one hotel room, with one bed, for the two of them. On the day that Wright
made sexual advances, Ms. Dorsey did not feel like she could say no to her law professor, direct
manager, and self-proclaimed gatekeeper to the antitrust profession. This was the first time that
the two were intimate.
65. Ms. Dorsey denies the allegations in Paragraph 65 of the Complaint. This trip was
the first instance of sexual contact between Wright and Ms. Dorsey. Ms. Dorsey thought that the
trip was a business trip. Prior to this trip, Wright was flirtatious, but Ms. Dorsey did not think
anything of it because Wright routinely spoke openly about being married and having children.
Further, the allegation that a trip with a second-year law student-Wright's law student 4 and
research assistant-was "a romantic getaway for two lovers to spend time in wine country" is
ridiculous and contradicts Wright's prior characterization of the trip and his own desire to keep
the relationship with Ms. Dorsey a secret. To the extent that Paragraph 65 of the Complaint refers
4 While Ms. Dorsey was not in a class with Plaintiff during the Fall 2010 semester, she was in
classes and independent studies with Plaintiff every other semester of law school (i.e., Fall 2009,
Spring 2010, Spring 2011, Fall 2011, and Spring 2012). Ms. Dorsey began working as a research
assistant for Plaintiff in the spring of 2010 and continued through her graduation in August of
2012.
20
to Exhibit D, the exhibit speaks for itself and any allegations beyond the face of Exhibit D are
denied.
only made truthful statements about Wright's abuse of power and predatory behavior that lasted
for years and Wright's retaliation against Ms. Dorsey when that relationship ended. Further, to the
extent that Paragraph 66 of the Complaint refers to Exhibit D, the exhibit speaks for itself and any
allegations beyond the face of Exhibit D are denied.
67. Ms. Dorsey denies the allegations in Paragraph 67 of the Complaint. Wright was a
law professor at GMU's law school, Ms. Dorsey's former professor, and direct manager. Wright
was incentivized to keep his sexual relationship with Ms. Dorsey a secret and insisted that Ms.
Dorsey remain silent. Additionally, Wright was aware that Ms. Dorsey was in the process of
getting divorced at the time. Discretion to protect her already-ending marriage was not Ms.
Dorsey's primary concern; rather, she was afraid of how Wright would behave if she said anything
at GMU or tried to report Wright's conduct-fears which have now become reality. To the extent
Paragraph 67 of the Complaint refers to Exhibit D, which speaks for itself. Any allegations beyond
the face of Exhibit Dare denied.
68. Ms. Dorsey denies the allegations in Paragraph 68 of the Complaint as phrased.
Over the years, Wright discarded Ms. Dorsey and forced his way back into her life. Any
opportunities Ms. Dorsey took that involved working with Wright were at Wright's insistence and
in an effort to keep Ms. Dorsey close and to continue to manipulate her. The allegations in
Paragraph 68 of the Complaint, as phrased, constitute a misrepresentation of the facts. Further, to
the extent that Paragraph 68 of the Complaint refers to Exhibit D, the exhibit speaks for itself and
any allegations beyond the face of Exhibit Dare denied.
21
69. Ms. Dorsey admits that she knew Ms. Edwards since Ms. Edwards was in law
school, and Ms. Dorsey helped Ms. Edwards obtain her position at WSGR, where the two women
worked together for a period of time. As described in Paragraphs 24 and 29 above, Wright denied
to Ms. Dorsey that he had any sexual relationship whatsoever with Ms. Edwards for years. In early
2020, Wright admitted to Ms. Dorsey that he had a sexual relationship with Ms. Edwards for a few
months in 2019, but he further told Ms. Dorsey that he terminated the relationship and cut off
communication with Ms. Edwards by the beginning of 2020. From that point on, Wright denied
any sexual or romantic relationship with Ms. Edwards until Ms. Dorsey confronted him in October
of 2021. Indeed, as late as August of 2021, Wright told Ms. Dorsey, "I'm not in contact with
Lindsey." See Ex. 21. Ms. Dorsey understands that Wright is now alleging that he lied to Ms.
Dorsey for years about his relationship with Ms. Edwards and several other former students.
Additionally, to the extent that Paragraph 69 of the Complaint refers to Exhibit D, the exhibit
speaks for itself and any allegations beyond the face of Exhibit D are denied. Ms. Dorsey denies
the remaining allegations in Paragraph 69 of the Complaint.
70. Paragraph 70 of the Complaint refers to multiple documents, including Exhibits A
and D and the Title IX investigation, which speak for themselves. Any allegations beyond the face
of Exhibits A, D, and the Title IX investigation are denied. Further, not a single document
submitted in the Title IX investigation contradicts the allegations that Wright stopped interacting
with or assisting Ms. Dorsey regarding any professional issues or activities-including her
fellowship funding; her position at Lodestar; redirecting her adjunct teaching position at GMU;
their ongoing joint research and academic projects; and their leadership positions on professional
organizations-once the sexual relationship ended. Instead, these materials confirm that Wright
never responded to Ms. Dorsey directly about professional matters once the sexual relationship
22
ended, that he did not even reach back out to donors about Ms. Dorsey's funding until he was
notified of the Title IX investigation, and that he instructed GMU to send the teaching contract for
an LLM class which Ms. Dorsey had taught several times before, and which Wright had offered
to Ms. Dorsey in October of 2021, to a different adjunct-a male who had graduated less than two
(2) years prior. See Exs. 7-9. Indeed, Ms. Dorsey maintains that Wright retaliated against her when
she refused to submit to his sexual advances or attempted to pull away from him. Any remaining
allegations in Paragraph 70 of the Complaint are denied.
Complaint. To the extent that any response is required and/or Paragraph 71 makes allegations
against Ms. Dorsey, Ms. Dorsey denies the allegations in Paragraph 71 of the Complaint. Further,
to the extent that Paragraph 71 of the Complaint refers to any documents or attached exhibits, those
documents and exhibits speak for themselves, and any allegations beyond the face of the
documents and/or exhibits are denied.
Complaint. To the extent that any response is required, Paragraph 72 of the Complaint refers to
Exhibits B and C, which speak for themselves, and any allegations beyond the face of Exhibits B
and C are denied.
Complaint. To the extent that any response is required, Paragraph 73 of the Complaint refers to an
included tweet, which speaks for itself, and any allegations beyond the face of the tweet are denied.
23
Complaint. To the extent that any response is required, Paragraph 74 of the Complaint refers to
Exhibits, B, C, and D, the Exhibits speak for themselves, and any allegations beyond the face of
Exhibits B, C, and Dare denied.
75. Ms. Dorsey admits that she graduated from GMU's law school in May of 2012.
During the time Ms. Dorsey was in law school, and prior to 2012, University Policy Number 1202
("Sexual Harassment Policy") was in effect and had been in effect since April 20, 2006. See Ex.
22. The fact that Wright is trying to escape responsibility for his predatory behavior by stating
there was no explicit policy prohibiting him from having sexual relationships with his law students
and direct supervisees is appalling. Finally, Paragraph 75 of the Complaint refers to the Law360
article attached as Exhibit D, which speaks for itself, and any allegations beyond the face of Exhibit
D are denied. Ms. Dorsey admits that "the consensual relationships policy is a disclosure policy
that went into effect on June 28, 2012." However, the policy speaks for itself.
COUNTI
DEFAMATION AND DEFAMATION PER SE
(Against Both Defendants)
79. Defendant incorporates her answers to the preceding paragraphs as if fully set forth
herein, and to the extent not inconsistent and further answers as follows:
24
81. To the extent that the allegations are directed at Ms. Dorsey, Ms. Dorsey denies the
83. Paragraph 83 of the Complaint refers to Exhibit D and tweets, which speak for
themselves. To the extent that the allegations are directed at Ms. Dorsey, any allegations beyond
the face of Exhibit Dare denied.
25
COUNT II
TORTIOUS INTERFERENCE
COUNT III
STATUTORY CONSPIRACY
26
l 03. The allegations in Paragraph 103 of the Complaint comprise a legal conclusion to
COUNT IV
COMMON LAW CONSPIRACY
110. Ms. Dorsey denies the allegations in Paragraph I 10 of the Complaint.
27
AFFIRMATIVE AND OTHER DEFENSES
Without admitting liability for any claims or causes of action set forth in the Complaint,
Defendant asserts the following affirmative defenses:
FIRST DEFENSE
Plaintiffs Complaint fails to state a claim upon which relief may be granted and the
requested relief is not permitted as a matter of law.
SECOND DEFENSE
The publication complained of was privileged in that the Title IX Complaint was judicially
privileged.
TIDRD DEFENSE
The publication complained of was privileged in that the Law360 article dealt with matters
of public interest. Publication thereof was made in good faith without actual malice and was
entirely within the scope of the privilege afforded Defendant by law.
FOURTH DEFENSE
The statements alleged are expressions of opinion that are protected by the First
Amendment to the Constitution of the United States and Article I, Section 12 of the Constitution
of Virginia.
FIFTH DEFENSE
Plaintiff is a public or semi-public figure, and any alleged defamatory statements were not
made with actual malice.
28
SIXTH DEFENSE
Any alleged injuries suffered by Plaintiff were not caused by Defendant, but instead were
caused by Plaintiffs own negligence, conduct, actions, or inactions, or were as a result of other
alternative causes, or a combination thereof.
SEVENTHDEFENSE
Any alleged injmies suffered by Plaintiff were not caused by Defendant, but instead were
caused by someone else.
EIGHTHDEFENSE
Plaintiff cannot state any claim based on the title, "'I Suffered Silently': Ex-Law Prof
Allegedly Preyed On Students" or any of the other article titles. Defendant did not write or author
this title or any of the other article titles. Pursuant to Rule 3: 11 of the Rules of the Supreme Court
of Virginia, a written reply to this paragraph is expressly requested.
NINTHDEFENSE
Plaintiffs claims are barred by the applicable statute of limitations.
TENTHDEFENSE
Defendant's Title IX Complaint and administrative/judicial statements from her Title IX
Complaint and investigation cannot form the basis for any claim for relief or otherwise support
any claim for relief by Plaintiff against Defendant as such statements are not actionable as a matter
of law, are absolutely privileged and/or subject to qualified privilege and are judicially immune
from supporting a claim for defamation.
29
ELEVENTH DEFENSE
Plaintiffs Exhibit A cannot form the basis of any claim for relief or otherwise support any
claim by Plaintiff because it was a confidential exhibit provided by Defendant to the Title IX
investigator and was not to be used outside of that investigation or proceeding.
RESERVATION OF ADDITIONAL DEFENSES
Defendant reserves any and all additional defenses that become known and/or available to
her, including those which may be disclosed or discovered through discovery or trial.
PRAYER FOR RELIEF
Any statements or allegations in the Complaint are denied unless expressly admitted above.
WHEREFORE, and in response to Plaintiffs Prayer for Relief, Defendant Elyse Dorsey
denies that Plaintiff is entitled to any relief and respectfully requests that the Court dismiss
Plaintiffs Complaint with prejudice and that Defendant be awarded all reasonable attorneys' fees
and costs incurred by her in answering this Complaint, as well as any other relief that the Court
deems just and proper.
DEMAND FOR JURY TRIAL
Defendant hereby demands trial by jury in this action of all issues so triable.
Date: September 19, 2023

Roya Vasseghi (VSB No. 85122)
Kellie Budd (VSB No. 72084)
VASSEGHI BUDD PLLC
9663-A Main Street
Fairfax, VA 22031
(703) 215-9358 Tel.
(703) 563-7401 Fax
roya@vasseghibuddlaw.com
kellie@vasseghibuddlaw.com
Attorneys for Defendant Elyse Dorsey
30
I hereby certify that on this 19th day of September, 2023, a true and correct copy of the
foregoing Answer to Plaintift's Complaint was served by hand delivery upon the following:
Jason C. Greaves
Lindsay R. McKasson
Benjamin F. North
BINNALLLAW GROUP,PLLC
717 King Street, Suite 200
Alexandria, VA 22314
T: (703) 888-1943
F: (703) 888-1930
jason@binnall.com
lindsey@binnall.com
ben@binnall.com
Attorneys for Plaintiff Joshua Wright
And by email to:
Stacey Rose Harris (VSB No. 65887)

Allison Palmer Klena (VSB No. 96400)
HIRSCHLER FLEISCHER, PC
1676 International Drive, Suite 1350
Tysons, VA 22102
(703) 584-2172 Tel.
(703) 584-8901 Fax
sharris@hirschlerlaw.com
aklena@hirschlerlaw.com
Attorneys for Defendant Angela Landry
<{)M
Roya Vasseghi
31
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IN THE CIRCUIT COURT OF FAIRFAX couWtv~ -'"''-'·~
2GBSEPI 9 P I: 4 b
JOSHUA WRIGHT,
McLean, Virginia 22101 .
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Plaintiff,
vs. Civil Action No.2023~12232
ELYSE DORSEY,
6147 Beachway Drive
Falls Church, Virginia 22041
and
ANGELALANDRY,
6857GrandeLane
Falls Church, Virginia 22043
Defendants.
DEFENDANTS ELYSE DORSEY AND ANGELA LANDRY'S PLEA IN BAR
Defendants Elyse Dorsey ("Ms. Dorsey") and Angela Landry ("Ms. Landry") (collectively,
"Defendants"),by counsel and pursuantto Rule 3:8 of the Rulesof the SupremeCourt of Virginia,
submit this Plea in Bar to Plaintiff Joshua Wright's ("Plaintiff' or "Wright") Complaint, and in
support thereof, state as follows:
l. Plaintiff filed a Complaint for defamation/defamation per se, tortious interference,
statutory conspiracy, and common law conspiracy against Defendants relating to the publication
of a Law360 article concerning sexual misconduct by Plaintiff and a Title IX Complaint and
investigation concerning the same.
1
2. Plaintiffs defamation/defamation per se claim (Count I) must be dismissed, with
prejudice, because Defendants are immune from defamation liability under Virginia's Anti-
SLAPP statute, Va. Code§ 8.01-223.2.
3. Plaintiff also alleges tortious interference (Count II), statutory conspiracy under
Virginia's business conspiracy statute (Count III), and common law conspiracy (Count IV) based
on the alleged defamatory statements from Count I.
4. Defendants are immune from defamation liability tmder Va. Code§ 8.01-223.2 and,
therefore, any claim based on the alleged defamatory statements must fail as a matter of law.
5. Because Plaintiffs counts for tortious interference and statutory and common law
conspiracy are based on the alleged defamatory statements from Count I, those claims must also
be dismissed, with prejudice.
6. To the extent that Plaintiff is pleading negligent or intentional infliction of
emotional distress based on the alleged defamatory statements that are the subject of Count I, those
claims must also be dismissed, with prejudice, for the same reasons as Counts II, III, and IV.
7. To the extent that Plaintiffs claims rely on acts and conduct in connection with
pursuing a Title IX Complaint, including acts incident to raising the claim, discussing the claim
with university officials, preparing the complaint, participating in the claims, or settling the claims,
those acts are judicially privileged and cannot be the basis of any tort claim and, accordingly, they
must fail.
Defendants will file a memorandum in support of their Plea in Bar when this matter is
noticed for hearing.
WHEREFORE, Defendants Elyse Dorsey and Angela Landry respectfully request that this
Court grant their Plea in Bar and dismiss Plaintiffs entire Complaint, with prejudice; award them
2
reasonable attorneys' fees and costs as authorized by Va. Code § 8.01-223 .2(B); and grant such
other and further relief that the Court may deem appropriate.
Dated: September 19, 2023
Roy~SB No. 85122) Stace ose Harris (VSB No. 65887)

Kellie Budd (VSB No. 72084) Allison Palmer Klena (VSB No. 96400)
VASSEGHI BUDD PLLC HIRSCHLER FLEISCHER, PC
9663-A Main Street 1676 International Drive, Suite 1350
Fairfax, VA 22031 Tysons, VA 22102
(703) 215-9358 Tel. (703) 584-2172 Tel.
(703) 563-7401 Fax (703) 584-8901 Fax
roya@vasseghibuddlaw.com sharris@hirschlerlaw.com
kellie@vasseghibuddlaw.com aklena@hirschlerlaw.com
Attorneys for Defendant Elyse Dorsey Attorneys for Defendant Angela Landry
3
CERTIFICATEOF SERVICE
I hereby certify that on this 19th day of September, 2023, a true and correct copy of the
foregoing PLEA IN BAR was served by hand delivery upon the following:
Jason C. Greaves
Lindsay R. McKasson
Benjamin F. North
BINN ALL LAW GROUP, PLLC
717 King Street, Suite 200
Alexandria, VA 22314
T: (703) 888-1943
F: (703) 888-1930
j ason@binnall.com
lindsey@binnall.com
ben@binnall.com
Attorneys for Plaintiff Joshua Wright
4
VIRGIN I A:
r-1I I
IN THE CIRCUIT COURT OF FAIRFAX COUNa7V;;__1~--(1~~c:-,,,,,,

-...~ -\~:01,•lG
SEPI 9 p 2: 0 I
102.1
)
JOSHUA \\ 1RIGHT, )
)
Plaintiff, )
)
v. ) Case No.: 2023-12232
)
)
ELYSE DORSEY, ET AL., )
)
Defendants. )
)
ELYSE DORSEY, )
)
-and- )
)
ANGELA LANDRY, )
)
Counterclaim Plaintiffs, )
)
v. )
)
JOSHUA WRIGHT, )
)
Sen e: 1115 Theresa Ann Street
1 )
McLean, VA 22101 )
)
Counterclaim Defendant. )
ELYSE DORSEY AND ANGELA LANDRY'S COUNTERCLAIM
Defendants and Counterclaim Plaintiffs Elyse Dorsey ("Ms. Dorsey") and Angela Landry
("Ms. Landry"), by counsel and pursuant to Rule 3:9 of the Rules of the Virginia Supreme Court,
for their Counterclaim against Joshua Wright ("Wright") for his violation of Virginia's Anti-
SLAPP statute, Va. Code§ 8.01-223.2, state as follows:

INTRODUCfION
1. Joshua \\!right a former Commissioner at the Federal Trade Commission ('"FTC")
and \vell-known law professor at one of Virginia's largest public law schools. has sued Ms. Dorsey
and Ms. Landry for OYerone-hundred million dollars in retaliation for their public statements about
Wright's sexual misconduct.
2. In his Complaint. \\'right fails to allege any defamatory statements. fails to
meaningfully dispute Ms. Dorsey's and Ms. Landry· s accounts of his sexual misconduct. and goes
oul of his \Vay to disparage and belittle Ms. Dorsey and Ms. Landry. seemingly for the purpose of
opening up Ms. Dorsey and J\,1s. Landry to public ridicule, harassment, and professional
consequences.
3. Accordingly. \\'right ·s lawsuit is a transparent attempt to punish Ms. Dorsey and
J\1s. Landry frir their protected speech on a topic of ongoing public discourse and is precisely the
type of action that Virginia's Anti-SLAPP (strmegic lawsuits against public participation) statute
is intended to deter.
4. Pursuant to Va. Code 2 8.01-223 .2( C). \\'right is therefore liable to Ms. Dorsey and
l\1s. Landry for the attorneys· fees and costs they have incurred and continue 10 incur in defense
of this action.
PARTIES, JlTRJSDJCTlON, AND VENlJE
5. Ms. Dorsey is a natural person residing in the Commonwealth of Virginia.
6. Ms. Landry is a natural person residing in the Commornvealth of Virginia.
7. Wright is a natural person residing in the Commomveahl1 of Virsini:::i
8. This Court has jurisdiction over this Counterclaim and venue is proper pursuant to
Va. Code§ 17.1-513, Va. Sup. Ct. R. 3:9, and Va. Code§§ 8.01-257, ct seq., because Wright
2
brought his defamation action in violation of Virginia's Anti-SLAPP statute against Ms. Dorsey
and Ms. Landr) in this Court.
FACTUALBACKGROUND
9. On August 14. 2023. the legal news publication Lcm360 published an article
detailing l\1s. Dorsey"s and Ms. Landry"s personal experiences with WrigbL which inclmled
Wright le\ eraging promises of professional opportuni1ies to pursue sexual relationships \\ ith Ms.
Dorsey and Ms. Landry \\bile he was their law professor at George Mason University School of
1
Law. During the same time frame, Ms. Dorsey and Ms. Landry made similar statements on social
media about their experiences with \Vright.
1Cl. Wright was and is a \Vell-kno\\'n figure in antitrust law and in the broader legal
profession. ln 20 l 5, \\/right served as a Commissioner of the FTC. a position to \vhich be was
appointed by President Barack Obama. From 2004 until August of 2023, Wright \Vas employed
as a la\\ professor at GMU. See Compl. 5-11: Joshua D. Wright, Wikipedia,
https://en.wikipedia.orgl,viki/Joshua_D._ Wright (last visited Sept. 19, 2023, 11 :53 a.m. ).
11. Shortly after the Law360 article ,11aspublished, Wright sued Ms. Dorsey and Ms.
Landrv for S108.000,000.00, asserting claims for defamation. tortious interference. statutory
conspiracy. and common law conspiracy.
12. In his ComplainL \Vright fails to allege any specific false or defamatory statement
made by either Ms. Dorsey or Ms. Landry. Wright tellingly concedes the factual bases of Ms.
Dorsey's and Ms. Landry's respective accounts, admit1.ing, among other things. that he began
sexual relationships ,vith Ms. Dorsey and Ms. Landry while they were la\1-istudents and his
1
George Mason University School of Law is nmv known as the Antonin Scalia Law School and
is ref erred to herein as "G MU."
research assistants and that he rnvarded Ms. Dorsey and Ms. Lanclrv with professional
opportunities during the duration of these relationships.
13. In any event, \Vright canno1 seriously dispute 1he contents of the Lav,360 article
and the social media posts because Ms. Dorsey·s and Ms. Land1f s statements are (i) true. or (ii)
opinions regarding each of their feelings about and experiences with, Wright.
14. Although denigrated by \Vright in bis Complaint. the "Me Too MO\ emenf· renrnins
a topic of ongoing public interest at a local and national level. ln the Complaint Wrigh1 concedes
that discourse related to the "]Vle Too MovemenC is of national interest and importance. Sec
Compl. il 77. \/hight further alleges that the Lav,360 article. as \Ve]] as Ms. Dorsey's and .\1s.
Landry·s statements on social media, \Vere of inlerest to the public. See id at 61-62.
COt:NTI
Violation of Anti-SLAPP Statute, Va. Code§ 8.01-223.2
15. Tl1e foregoing paragraphs are incorpora1ed as if Cullyrestated herein.
16. The Virginia Anti-SLAPP statute prO\ ides. ·'A person shall be immune from tort
liability if the tort claim is based solely on statements (i) regarding matters of public concern that
\Vould be protected under the First Amendment lO the Constitution of the United States made by
that person that are communicated to a third party ... :' Va. Code§· 8.0l-223.2(A). This immunity
is broad and has only one excep1ion for statements that ·'the cleclarant kne\v or should haw known
were false or were made with reckless disregard for whether they were false." Va. Code§ 8.01-
223.2(B).
17. To deter SL.APP lawsuits, the Virginia Code furtl1er proYides. ·'Any person who
has a suit against him dismissed ... or otherwise JXe\ ails in a legal action, pursuant lo the immunity
provided by this section may be aYvarded reasonable attornev fees and costs.'· Va. Code § 8.01-
223.2(C).
4
18. ·'The First Amendment to the Federal Constitution and article 1. section 12 of the
Constitution of Virginia protect the right of the people to leach. preach. write. or speak any such
opinion. however ill-founded, \vithout inhibition b~ actions for libel and slander. [E]rrnr ofopinion
may be tolerated where reason is left free to combat it. 1lciwever pernicious an opinion may sce!m].
we depend for its correction not on the conscience of judges and juries blll on the competition of
other ideas:' Thw7Je v. Sounders. 285 Va. 476. 481 (201 ?.) (cleaned up) (quoting Chcm's 1·.
.Johnson. 230 Va. 112. 119 ( 1985 )J. A statement involves a matter of public concern ·'when it
involves an issl1e of sociaL politicaL or other interest to a com1mmity.'· Snyder v. Phelps. 580 F.3d
::106,220 (4th Cir. 2009), afrd 562 U.S. 443 (2011) (citing Kirby V. City o/Elizaberh City. C.
388 F.3d 440, 446 (4th Cir. 2004)).
19. Ms. Dorsey's and Ms. Landry"s statemcnls 10 Law360 and on Tv,it1er iffvolve
matters of public concern that are protected by the First Amendment and the Constitution of
Virginia. Until his resignation. Vhigh1 was a well-kml\-\11 lcl\Vprofessor at one of Virginia· s largest
pl1blic !av, schools. He JXeYiously held public office a.s an FTC Commissioner. a presidentially-
appointed position. Wrigl1t's conclucL judgment, and treatment of his students and subordinates
are therefore properly matters of the public's concern. Tlrns, as \Vright's own allegations shmv.
Ms. Dorsey's and 1v1s.Landry's statements contributed 10 a topic of ongoing public discourse,
namely, the pervasive problem of superiors abusing positions of power to pursue sexual
relationships with their slibordinatcs.
20. Ms. Dorsey's and Ms. Landry's statements are true and/or are statements of Ms.
Dorsey's and Ms. Landry's personal opinion. As a result, J\-1s.Dorsey and Ms. Landry have not
made any statements \Vith actual or constructive kno\11"ledge or reckless disregard of any
statement's falsity.
5
21. Because Ms. Dorsey's and Ms. Landry" s sta1ements are statements regarding
matters of public concern that arc protected under the First Amendment to the Constitution of the
United States. Ms. Dorsey and Ms. Landry are entitled to the immunitY afforded by Virginia's
Anti-SLAPP s1atute.
n By bringing his meritless SLAPP action, Wright has violated Va. Code ~ 8.01-
.2. and pursuant to Va. Code~ 8.01-223.2(C). Ms. Dorsey and Ms. Landn are entitled to full
recm en of the amounts expended defending this action, and in any event not less than
$500.000.00.
\VHEREFORK Ms. Dorsey and Ms. Landry respectfully request thm the Court (i) enter
judgment against \Vright and in favor of Ms. Dorsey and Ms. Landry in the amount of Ms.
Dorsey·s and Ms. Landry's reasonable attorneys' fees, costs, and post-judgment interest st the
maximum legal rnte. and (ii) grant such ,,ther and further relief as this Court deems reasonable and
just.
Da1ed: September 10, 2023
Roya Vasseghi (VSB No. 85

Kellie Budd (VSB No. 72084) /\llison P. SB No. 96400)
VASSEGHI BUDD PLLC HIRSCHLER FLEISCHER. PC
9663-A Main Street 1676 International Drive. Suite 1350
Fairfax, VA 22031 Ty sons. VA 22102
(703) 215-9358 Tel. (703) 584-2172 Tel.
(703) 563-7401 Fax (703) 584-8901 Fax
roya@vasseghibuddlaw.com sharris@hirschlerla\v.com
kellie@vasseghibuddlaw.com aklena((l]hirschlerlaw.corn
Atror11eysfor Defendant E~yse Dorsey Atrorneysfor Defendant Angela Landry
6
I cert if\ that on September 19. 2023. a true and correct copy of the foregoing Counterclc1im
hand-delivered upon the follmving:
Jason C. Circaves, Esq.

Lindsay R. f\1cKasson. Esq.
Benjamin F. North, Esq.
JJinnall Law Group, PLLC
717 King Street Suite 200
Alexandria. VA 22314
Email: jascm1rTbinnall.com
lindsa\'/d binnall .co1:i}
ben Zlbinnall.com
Counsel
J 769.2 048734.0000 l

Wright v. Dorsey - Responses

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Wright v. Dorsey - Responses

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VIRGIN I A:

JOSHUA WRIGHT, zcn..~r:o

vs. Civil Action No.2023-12232

Defendants and Counterclaim Plaintiffs :

ANGELA LANDRY'S ANSv\TER

subordinates of the ability to trulv consent.

understand she is anything but a heartbroken, scorned former lover, as he writes:

I\\ as emotionally manipulati\'e, clecepti\'c. and not capable of honest emotional

l\e clone e\crytliing J'n: told you I \Yould do.

cotmsel-- as an extortionate '·multi-million dollar demand.''

Landry does not know how many.

8. Ms. Landry lacks information sufficient to admit or deny.

am other public service.

13. Ms. Landry lacks information sufficient to admit or deny.

14. Ms. Landry lacks information sufficient to admit or deny.

15. Ms. Landry lacks information sufficient to admit or deny.

17. Ms. Landry lacks information sufficient to admit or deny.

18. Ms. Landry lacks information sufficient to admit or deny.

\\'right and Ms. Dorsey published together.

20. Ms. Landn lacks information sufficient to admit or elem.

21. Ms. Landry lacks information sufficient to admit or deny.

11 Ms. Landry lacks information sufficient to admit or deny.

a relationship with Ms. Edwards in the late 202 l timefrarne.

25. Ms. Landry lacks information sufficient to admit or cleiw.

Ms. Landn lacks information sufficient to admit or deny.

27. Ms. Landn lacks informalion sufficient to admit or deny.

28. Ms. Landry lacks information sufficient to admit or deny.

29. Ms. Landr, lacks information sufficient to admit or deny.

30. Ms. Landry lacks information sufficient to admit or

31. Ms. Landry lacks information sufiicient to admit or deny.

32. Ms. Landry lacks information sufficient to admit or deny.

Ms. Landry. just as he did \Vith Ms. Dorsey.

durirn2 their c01werscllions. and eventuallv sayirn.>thirnzs clurin12_

work for her first lm:vfirm. the relationship fizzled out.

professor, but also her superior at her upcoming job.

Ms. Landry expressly requests a reply pursuant to Rule 3: 11.

Bv the time of the December

above. Ms. Landry expressly requests a reply pursuant to Rule 3: 11.

itself and all other characterizations and allegations are denied.

characterizations and allegations are denied.

l want you to know l arn genuinely frir hO\\ T tn°atecl you. J \\ as

longer n,essage, reads:

Jd. (Emphasis added.)

Wright then offers to ban: a conversation with Ms. Lmclry:

reflects a follow up from their conversation. in which Ms. l ,andry states:

J'\'e done eYerything I\·e told you I \\ oulcl. do.

He srnt mt· a (bullshit) ,qxilogy email.

Ms. Eclwards responded:

I pulled out the moot COUJ t thing after he did this.

Ms. Landry replied:

Ms. Edwards replied:

I also don't ,vant it to end up fucking my deg-ree over

pursuan1 10 Rule 3: 11.

Wright" s predatory conduct.

client relationship, ,vhich Wright fails to specifically identify.

54. Denied. A1w statements that Ms. Landrv made to

experience ,1,,ith\Vrigbl v/as entirely trne.

\Vright' s reference lo and reliance on pri\ikged setllement comnrnnications and negotiations.

the same da\ that she created her "J\vitler account.