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Open Letter On The Anti-Palestinian And Islamophobic Environment At Emory University

Above photo: Emory University. Wayne Hsieh/Flickr.

NOTE: Activism in support of Palestinian liberation is alive at universities despite repression and retaliation, as evidenced by the letter below to Emory University. Additionally, faculty at the University of Michigan recently voted to boycott all companies invested in the Israeli war in Gaza.

Students at Emory University have been targeted by racist, anti-Palestinian, xenophobic, and Islamophobic harassment and attacks for their support for Palestinian human rights.

Instead of helping, Emory has committed discriminatory acts of its own.

Editor’s Note: The following letter was sent to Emory University President Gregory L. Fenves on January 24, 2024, by a coalition of community and civil rights organizations, writing on behalf of Palestinian, Arab, and Muslim students and students perceived to be Palestinian or Muslim at Emory University.

January 24, 2024

RE: Anti-Palestinian and Islamophobic Environment at Emory University

Dear President Fenves:

We are a coalition of community and civil rights organizations, writing on behalf of Palestinian, Arab, and Muslim students and students perceived to be Palestinian or Muslim at Emory University (“the University”) who have been targeted by racist, anti-Palestinian, xenophobic, and Islamophobic harassment and doxing attacks for their support for Palestinian human rights. We write to express our concern about the University’s failure to protect its students from these bigoted doxing and harassment campaigns and the lack of official, public support shown to Palestinian, Arab, and Muslim students. The University’s largely one-sided public statements since the incidents of October 7, 2023, have, in fact, invited active harm, harassment, and intimidation of students on Emory’s campus. The University’s actions to date raise serious concerns that it is violating Title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin by institutions that receive federal assistance, including tolerating a hostile environment of which it has notice. We call on the University to protect its students from these attacks and affirm their right to advocate for Palestine.

Discrimination, Harassment, And Intimidation Faced By Palestinian, Arab, And Muslim Students, And Their Allies1

Students who support Palestine on campus are being severely and routinely intimidated and harassed by faculty, other students, alumni, and even parents and news media. This includes members of Emory Students for Justice in Palestine (ESJP), a group which advocates for the freedom and equality of Palestinians. ESJP is a diverse group, but its membership is made up of a number of Arab and/or Muslim students.

  1. Hateful speech and harassment by Emory students, parents, and outsiders against Emory’s Palestinian, Arab, and Muslim Students
  • Since October 9, ESJP has received several hateful comments, tags, and direct messages from non-Emory affiliates on their social media platforms. They have been called Hamas supporters, fake Muslims, and have been sent graphic photos, such as photos that were purported to be of an Israeli woman who had been sexually assaulted and a burned Israeli child – both of which have been proven to be fake. This has been reported to Emory via the University’s bias reporting process.
  • On October 12, [redacted], a current Emory student, liked a tweet by [redacted] equating all Students for Justice in Palestine chapters with Hamas. In another incident (date unknown), [redacted] liked a tweet by [redacted], a journalist who has peddled Islamophobic rhetoric and spread debunked messaging about what happened on October 7, denying the occurrence of the genocide and displacement of Palestinians in 1948.
  • On October 16, a Muslim student was walking to the shuttles when she overheard a girl behind her loudly telling her other friend that her cousins kept making crazy jokes and said, “They keep saying we need to kill all the Palestinians.” Both friends then started laughing, though the girl later clarified that is not what she personally was going for. This has been reported to Emory via the University’s bias reporting process.
  • On October 25, following the Stop Cop City protest at Emory, [redacted] , a current student at Emory and [redacted], posted on X (formerly Twitter) and described students affiliated with ESJP as “militant students calling for genocide of Jews from the river to the sea,” – referencing a call that is meant to be for complete freedom and equality for Palestinians.2 In fact, called every student who attended the protest a “militant.” She also called on Emory University to disband ESJP. Her activity on X has relied on Islamophobic tropes. This has been reported to Emory via the University’s bias reporting process.
  • On October 25, at the Stop Cop City protest at Emory, [redacted], [redacted], and several other students recorded the protesters. Video footage of the protesters was then posted on the Israel War Room Instagram account, an online group that has been known to dox and harass those who speak out for Palestine and that has collaborated with Emory Eagles for Israel on at least one social media post. The video sent to Israel War Room showed protesters and included an inflammatory heading: “Pro-Hamas students want to wipe Israel off the map” and a caption that stated “‘free Palestine from the river to the sea” would look like: ‘Jews will be slaughtered until there are none left.’” [redacted], who is Muslim and Arab and who spoke at the protest simply to state the number of Palestinian children killed in Gaza as of October 7, 2023, was shown in the video that labeled protesters as Hamas supporters. This has been reported to Emory via the University’s bias reporting process.
  • After the October 25 Stop Cop City Walk Out, ESJP students have received extreme hate online for an event that was not even sponsored by ESJP. These hateful posts came from [redacted], Stop Antisemitism (Instagram Page), and Israel War Room (Instagram Page), in addition to [redacted] ([redacted]), who called protesters “pro-murder, pro-rape, pro-torture, pro-abduction.” This has been reported to Emory via the University’s bias reporting process.
  • In October 2023 (exact date unknown), [redacted], [redacted] mother, commented on [redacted]’s LinkedIn post and said they must call on the mayor of Atlanta to arrest Emory students who showed their support for Palestine. She also falsely accused these students of antisemitism and stated that all such students’ names must be publicly exposed. This has been reported to Emory via the University’s bias reporting process.
  • On October 23, an Arab student stepped into the elevator of Clairmont Tower, a building they are a Resident Advisor (“RA”) for. The RA was with their roommate when another person in the elevator looked at the RA’s headband and hoodie that read “Arab Cultural Association.” The person looked at his friend, nudging him to stare at the RA. The person then stated, “There is a lot of hate in America,” took a deep breath, and then stated again, “There is a lot of hate in America…towards Jewish people.” The person then clenched his fist and whispered “oh my god,” as the RA left the elevator. Because the RA lived and worked in the building, they knew that the person who made the racist statement did not reside in the building. The RA’s face, name, and contact information are all over Clairmont Tower as they are a student employee in the building. This has been reported to Emory via the University’s bias reporting process.
  • On October 26, a student posted a physical threat posed as a question on an anonymous social media platform, known as Fizz. The post said, “Will I get in trouble if I fist fight anyone with a pro palestine [sic] sign on campus.” This has been reported to Emory via the University’s bias reporting process.
  • On October 26, Emory alumnus [redacted] called the University’s career center and asked for a list of students who attended the Stop Cop City protest on October 25. The student worker replied that they did not have the information he was requesting and directed him to call the dean’s office instead. This was an explicit attempt by [redacted] to further dox and harm pro-Palestine students who expressed their views on campus and to encroach on students’ privacy and safety. This has been reported to Emory via the University’s bias reporting process.
  • On October 31, an Arab student of Iraqi descent was attending the farmer’s market to get lunch. She ran into an old acquaintance from freshman year, who said hello and then asked, “Are you a terrorist?” She felt uncomfortable and asked him to repeat what he said. He said, “Are you a terrorist? I think all brown people are terrorists.” He then said “Everything I say is not sarcastic. I’m not joking.” He apologized and said it was a joke, but by then the student had already been made extremely uncomfortable and felt attacked. This has been reported to Emory via the University’s bias reporting process.
  • On November 5 and November 12, Palestinian, Arab, and Muslim students put up flyers and did chalkings at different locations on the University campus, in accordance with the University’s open expression policy. The flyers noted the number of Palestinians killed by Israeli forces since October 7. Over the next week, the flyers were ripped out or put in the trash. The chalkings likewise listed the number of Palestinians killed since October 7 and called the ongoing Israeli onslaught against Gaza a genocide. The first time the students engaged in these chalkings, pro-Israel students surrounded them and tried to interfere with the chalkings in violation of the University’s open expression policy. One of the pro-Israel students, [redacted], pretended to (or perhaps in fact did) call campus police on the Palestinian, Arab, and Muslim students, accusing them of mobbing her, when she, in fact, had approached them first. The second time the students engaged in these chalkings, other students followed them around campus, and filmed them, simply for engaging in protected expression in support of Palestinian rights.
  • On November 11, at a bake sale organized by Arab and Muslim students to fundraise for the Palestinian Children’s Relief Fund (PCRF), a humanitarian organization that provides medical assistance to Palestinian children, an Emory parent verbally accosted a Muslim student, accusing them of supporting Hamas. When the student asked on-site Emory staff from the open expression office and the director for student involvement to intervene on the student’s behalf and stop the parent from engaging with the student, Emory staff informed the student they could not stop the verbal harassment because of Emory’s open expression policy. This is in contrast to the response Emory had when a visibly Jewish student was verbally accosted the same day.
  • On November 11, a Jewish student who was passing by the same bake sale was allegedly verbally accosted by someone who yelled “Free Palestine, b***h” at the Jewish student. Pro- Israel social media accounts immediately and incorrectly blamed ESJP and its affiliated students for this verbal assault. Campus police are now investigating this incident.
  1. Blatant Discrimination by the Emory College Instagram Account
  • The Emory College Instagram account (@emorycollege), the official Instagram page run by Emory College of Arts & Sciences, has a clear policy to share all student-organized events and student club information on its page, and they shared this policy with ESJP. The Emory College Instagram account even wrote, “If you are connected with SJP, please let us know if there is a planned event for Palestinians who were killed, or if there is a joint event.” On October 10, 2023, when ESJP first released a mourning statement and statement of action on their Instagram, the Emory College Instagram account reposted ESJP’s statement on their Instagram story. However, within a few hours of reposting the ESJP mourning statement, the Emory College Instagram account deleted that post from their Instagram page. In contrast, the Emory College Instagram account reposted other groups’ statements and kept them up for a full 24 hours. Furthermore, when ESJP requested the Emory College Instagram account to repost a Vigil for Palestine flyer, they failed to do so. They read ESJP’s message and did not respond. However, when Israeli clubs hosted a vigil on campus, the Emory College Instagram account did share that information on its page. This demonstrates a clear bias against Palestinian students and students associated with Palestinians, in violation of Title VI and Emory College of Arts & Sciences’ own policy to publish information about all student club events and activities on its Instagram page. This has been reported to Emory via the University’s bias reporting process.
  1. Harassment/Intimidation and the University’s Failure to Protect Students
  • On October 9, an Emory University alumnus from Goizueta Business School, (“[redacted]”), made a public post on his LinkedIn platform, calling ESJP a “terror-related” organization, and asking the University to expel students affiliated with ESJP. [redacted]’s accusation that ESJP, an organization that advocates for Palestinian human rights and that is made up of a number of Arab and Muslim members, is associated with terrorism perpetuates dangerous, racist tropes of Palestinians, Arab, and Muslims as violent. In the same post, he doxed one Emory faculty member and at least four students affiliated with ESJP, listing their full names and tagging them in his post. Others reposted and commented favorably on [redacted]’s post. It was also liked by several Emory students, alumni, and faculty, none of whom have faced any consequences for supporting clearly anti-Palestinian and Islamophobic expression, in violation of the University’s values and policies surrounding open expression. Since October 7, 2023, [redacted] has openly called on the University to disband Emory Students for Justice in Palestine and for foreign students participating in pro-Palestine protests to be deported from the United States. Undergraduate students from Emory and their parents commented on [redacted]’s LinkedIn posts and supported his calling for ESJP students’ expulsion and the disbandment of ESJP. They also supported his claims that ESJP is a militant group made up of militant students. ESJP students were approached by professors, staff, and students in regard to [redacted]’s posting. One student explained that her LinkedIn account received hundreds of views a day due to [redacted]’s actions. [redacted]’s actions have been reported to Emory via the University’s bias reporting process.
  • On October 12, ESJP students met with Dean Andrea Hershatter (“Dean Hershatter”), one of the deans of Emory’s business school, to enlist her help in the issue ESJP students were facing with [redacted]’s social media posts. According to students who attended the meeting, Dean Hershatter started the meeting by saying that when students say “Free Palestine,” they are associating themselves with terrorism, directly and dangerously implying that advocating for Palestinian freedom and equality is a “terrorist” act for which students may be criminally liable. Dean Hershatter told the students, who themselves had been the targets of Islamophobic and/or xenophobic harassment, that they should be more understanding of [redacted], a man falsely and dangerously maligning them with racist, anti-Palestinian tropes. This has been reported to Emory via the University’s bias reporting process.
  • Despite the fervent attacks by [redacted] against current Emory students, [redacted] has been on the Emory campus at least twice, once on October 23, 2023, at the invitation of Dean Hershatter (after the impacted students informed her of [redacted]’s threats), and once to attend a student rally in support of Israel (again, after the impacted students informed Dean Hershatter of [redacted]’s threats). ESJP students had reported [redacted]’s threats to campus police and had asked campus police to inform them if [redacted] was ever on campus. Campus police failed to do so. Given [redacted]’s open hostility toward Palestinian, Arab, and Muslim students, and their allies, [redacted]’s presence on campus puts the impacted students’ physical and mental safety on campus in jeopardy. This has been reported to Emory via the University’s bias reporting process.

Students have submitted official reports to Emory through the school’s bias incident report form about the majority of these incidents. Nonetheless, to date, Emory has failed to act on reports of anti-Palestinian, Islamophobic, or otherwise racist harassment and discrimination, and Emory has instead cultivated an environment in which these acts can thrive.

Biased Statement By Emory Administrators And Faculty

In the face of this widespread racist and hostile environment, Emory has failed to support its Palestinian, Arab, and Muslim students not only via its investigation processes but also in its public statements. Since October 7, 2023, several administrators and faculty have issued public and/or University/department-wide statements solely in support of the students, faculty, and staff impacted by attacks in Israel, without mentioning the deadly violence and displacement suffered by Palestinians in Gaza and the West Bank as a result of the actions of the Israeli government, soldiers, and illegal settlers, and the impact of this violence on Palestinian students, faculty and staff on campus. When asked by students across the Emory campus to issue more balanced statements, Emory University administrators have either ignored them or informed them that the issue is too complicated for the University to issue such balanced statements.

We are aware of at least four such problematic and biased statements by Emory administrators or faculty.

  • On October 10, Dean Barbara Krauthamer, of the Emory College of Arts and Sciences, released a statement to the Emory College community. In her statement, Dean Krauthamer mentioned only the “deadly attacks in Israel” and their impact on Emory community members that have family and friends in the region, without mentioning Gaza, the mounting violence against Palestinians by the Israeli government, and its impact on the Palestinian, Arab, and Muslim communities at Emory. This has been reported to Emory via the University’s bias reporting process.
  • On October 11, President Gregory L. Fenves (“President Fenves”) released an email statement to the University, its affiliates, students, and parents of students. In his statement, President Fenves shared his “profound pain” at the attacks on Israel. However, he failed to acknowledge the violence the Israeli government, military, and illegal settlers have carried out against Palestinians in Gaza and the West Bank for decades, and the immense loss of life in Palestine since October 7. His lack of acknowledgment of Israeli violence on Palestinian lives and its impact on the University’s Palestinian, Arab, and Muslim communities has not only left these communities feeling isolated and ostracized, but it has also fostered an environment of increased anti-Palestinian rhetoric and Islamophobia on the University campus. This has been reported to Emory via the University’s bias reporting process.
  • On October 11, Doctor Steven W. L’Hernault (“Dr. L’Hernault”), Chair of the Emory Department of Biology, released a statement to students and faculty within his department. Dr. L’Hernault’s statement, like other statements released by Emory administrators, was one- sided, only acknowledging the attacks in Israel on October 7, and failing to mention or acknowledge the violence endured by Palestinians in Gaza and the West Bank for decades and since October 7. Moreover, in his statement, Dr. L’Hernault repeated some of the false claims President Biden made on national TV, claims which both the United Nations and the White House itself have deemed unfounded. This has been reported to Emory via the University’s bias reporting process.
  • On October 25, President Fenves sent another email to the University, its affiliates, students, parents of students, and even Emory alumni, about the Emory Stop Cop City protest, which had taken place earlier that day. He claimed that “antisemitic phrases and slogans were repeatedly used by speakers and chanted by the crowd.” He also said that the “antisemitism targeting Jewish members of our community” was “divisive and reprehensible.” President Fenves to date has failed to publicly specify which phrases or slogans he believed to be antisemitic, which left a lot to the imagination of those who were reading the email and opened up groups who sponsored the event and anyone who attended or spoke at the event to harassment and attacks. His statement again failed to condemn the rising anti-Palestinian environment and Islamophobia on Emory’s campus, in effect giving a green light to anti- Palestinian individuals and groups and Islamophobes to continue harassing the University’s Palestinian, Arab, and Muslim communities.

Only more recently, on November 21, did President Fenves release an email statement to the Emory community that mentioned the impact on Palestinians. His email expressed sympathy for the “emotional toll of the tragic war in Israel and Gaza,” mourned “the lives lost, both Palestinian and Israeli,” and condemned the “instances on our campuses where individuals have been targeted for their identities and backgrounds.” While Emory finally acknowledged the suffering and deaths of Palestinians, this statement came more than six weeks since October 7 and since the escalation of anti-Palestinian, anti-Arab, Islamophobic, anti-Black, and other forms of racist harassment on Emory’s campus. Emory has allowed and fostered an environment in which these racist sentiments could continue and grow for more than three months, with no acknowledgment of the emotional, mental, and physical toll on its Palestinian, Arab, Black, and Muslim students, and other students of color. Emory’s statement also fails to identify Israel as the perpetrator of the violence and murders of Palestinians in Gaza, whereas it has no issue identifying Hamas as a perpetrator of violence. The University’s acknowledgment of Israel as a perpetrator of violence is crucial to demonstrating that students have a right to advocate for Palestinian rights and condemn the violent and criminal acts of Israel.

As a cumulative effect of such statements, Palestinian, Arab, Black, and Muslim students, and other students of color have felt alienated and alone on a campus where they have no support from the administration and nowhere to turn to put a stop to these severe acts of anti-Palestinian racism, Islamophobia, anti-Black racism, and other forms of discrimination. If Emory condemns the targeting of individuals on campus for their identities and backgrounds, then it must act now to protect its Palestinian, Arab, Black, and Muslim students and other students of color. Students are waiting for Emory to stand behind its words.

Impact Of Bias And Harassment On Emory’s Palestinian, Arab, And Muslim Students

Because of the anti-Palestinian and Islamophobic hostile environment on campus, students who are Palestinian, Arab, Muslim, perceived to be Palestinian, or associated with Palestinians have been afraid to leave their rooms, go to class, focus on their coursework, and fully participate in campus life. Palestinian students have especially suffered as a result of this open hostility and fear. Many are experiencing trauma and are afraid of seeking help from the University because of the fear that their names and information will be released to external parties, or that identifying as Palestinians who believe in their own equality and right to life could lead to criminal consequences.

Rather than protecting its students, Emory University’s actions have encouraged and legitimized harassment and intimidation of its students who are Palestinian (or perceived to be Palestinian), Arab, Muslim, or those who advocate for Palestinian rights. Students are speaking out in support of Palestinian rights in a political climate where Israel has declared its genocidal intentions against Palestinians, over 23,000 of whom have been killed in Gaza since October 7, including nearly 10,000 children. It is Emory’s responsibility to ensure that students have the right to speak up for Palestinian human rights and that in doing so, they are safe from anti-Palestinian, anti-Arab, and Islamophobic harassment and bigotry.

Emory’s Actions Violate Title VI Of The Civil Rights Act Of 1964

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin by institutions that receive federal financial assistance.3 A university recipient of federal funding may be found to have violated Title VI in one of two ways: if it commits a discriminatory act of its own, or if it permits a hostile environment, i.e. when harassment by a third party or student is “so severe, pervasive, and objectively offensive that it effectively bars the victim’s access to an educational opportunity or benefit.”4

A university-recipient that has actual or constructive knowledge of a hostile environment must take prompt and effective steps that are reasonably calculated to end the harassment, eliminate the hostile environment, prevent its recurrence, and remedy its effects, by ensuring that students are not restricted from participation in or benefiting from their educational opportunities as a result of a hostile environment.5 A university that responds with deliberate indifference, or fails to take appropriate responsive action to a known hostile environment, violates Title VI and risks losing federal financial assistance.6

Targeted and pervasive harassment of Palestinians and Palestinian groups on campus on the basis of national origin or perceived national origin is actionable under Title VI where such harassment impedes the educational opportunities of the targeted students. Discrimination against Muslims and Muslim groups or those perceived to be Muslim on campus is likewise actionable under Title VI. As a university obligated to provide an educational environment welcoming to all regardless of race, color, or national origin, Emory cannot justify its failure to address the hostile anti-Palestinian and Islamophobic environment students have been subjected to on campus and by its own administration.

The discrimination, harassment, stereotyping, disparate treatment, and racial profiling described above are not isolated instances, but rather they are the product of deep-rooted, dehumanizing bigotry against Palestinians and their allies in an attempt to suppress speech supporting Palestinian rights on college campuses, which the University not only did nothing to address, but further contributed to by committing discriminatory acts of its own.

Conclusion

We urge Emory University to immediately:

  1. Publish a statement reaffirming its students’ right to openly advocate for Palestinian rights, and condemning online doxing.
  1. Condemn the anti-Palestinian, anti-Black, and other forms of racism and Islamophobia that its students are facing,
  1. Apologize to the students who have been impacted for creating an environment on campus that has encouraged further harassment and threats against students, particularly against Palestinian, Arab, Black, and Muslim students and students of color,
  1. Provide resources for impacted students that are accessible to them and responsive to their needs, including but not limited to, ensuring that career services have the knowledge and tools to help students navigate the unique hurdles they face entering the workforce as targets of smear campaigns; providing digital security resources to assist students in organizing safely; and, ensuring access to culturally competent mental health support,
  1. Implement educational initiatives and workshops aimed at fostering a culture of inclusivity, tolerance, and respect for Palestinian students and their allies,
  1. Conduct a thorough review of the incidents of harassment documented in this letter and other related reports Emory has received to ensure that the rights of students are protected, and that incidents of discrimination and harassment are addressed appropriately, and
  1. Ensure that reports of student discrimination and harassment are taken seriously and addressed promptly.

We respectfully request an immediate response to these concerns.

Sincerely,

Council on American Islamic Relations – Georgia
Palestine Legal
Asian American Advocacy Fund
Asian Americans Advancing Justice
Democratic Socialists of America – Atlanta Chapter
Georgia Muslim Action Committee
George Muslim Voter Project
Jewish Voice for Peace – Atlanta Chapter
Muslim Student Association – Kennesaw State University
Project South

CC:
Ravi V. Bellamkonda, Provost and Executive Vice President for Academic Affairs
Carol E. Henderson, Vice Provost for Diversity and Inclusion
Enku Gelaye, Senior Vice President and Dean of Campus Life

Notes

1 Documentation on file with Council on American-Islamic Relations (CAIR) – Georgia and Palestine Legal.

2 Understanding this Palestinian call for freedom as a call for Jewish death is based on racist and anti-Muslim stereotypes of Palestinians as intrinsically violent and hateful towards Jews. See Noah Zatz, Palestinian Freedom, Antisemitism Accusations and Civil Rights Law, THE LAW AND POLITICAL ECONOMY PROJECT (Nov. 20, 2023), https://lpeproject.org/blog/palestinian-freedom-antisemitism-accusations-and-civil-rights-law/; see also Maha Nasser, “From the river to the sea” – a Palestinian historian explores the meaning and intent of scrutinized slogan, THE CONVERSATION (Nov. 16, 2023), https://theconversation.com/from-the-river-to-the-sea-a-palestinian-historian- explores-the-meaning-and-intent-of-scrutinized-slogan-217491; Yousef Munayyer, What Does “From the River to the Sea” Really Mean?, JEWISH CURRENTS (Jun 11, 2021), https://jewishcurrents.org/what-does-from-the-river-to- the-sea-really-mean.

3 42 U.S.C. §2000d (1964).

4 See Davis ex rel. LaShonda v. Monroe Cty. Bd. Of Educ., 526 U.S. 629, 633 (1999). Although Davis is a Title IX case, the same legal standards are applied to Title VI enforcement. See, e.g., Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246, 258 (2009) (“Congress modeled Title IX after Title VI of the Civil Rights Act of 1964, and passed Title IX with the explicit understanding that it would be interpreted as Title VI was.”).

5 See, e.g., Letter from Melanie Velez, Reg’l Dir., Dep’t of Educ. Office for Civil Rights Region IV to Kathryn LeRoy, Superintendent of Polk County Pub. Schs. at 3 (Mar. 23, 2016) (RE: Case No. 04-14- 1664), https://www2.ed.gov/about/offices/list/ocr/docs/investigations/more/04141664-a.pdf.

6 42 U.S.C. § 2000d‐1 (1964).

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