With Del Mar doing nothing, the campaign against Mr. Benitez and Ms. Lopez took a shocking and horrific turn.

28. Mr. Benitez did not remain silent in the face of this outrageous conduct. On July 22, 2003, an attorney hired by Mr. Benitez to respond to the Wood, Bodkin & Wolter allegations sent a letter to Rivera pointing out that Matula was invading the privacy of Mr. Benitez and committing numerous violations of the rules of Del Mar. The letter stated: “The investigation by Dean Matula is retaliatory in nature and her hiring a private law firm to conduct such an investigation was a violation of Mr. Benitez’s and Melody Lopez’s confidentiality and privacy rights under Del Mar College Policies.” Del Mar was thus on notice of what Matula was doing and why it was a problem. However, Del Mar took no action, and instead wholly failed to supervise Matula or stop her vendetta.

29. Mr. Benitez filed a grievance against Matula on July 28, 2003, based on the stalking, harassment, and retaliation. Del Mar took no action on that grievance, once again demonstrating deliberate indifference to the policy violations and civil rights abuses being committed by the members of its administration.

30. With Del Mar doing nothing, the campaign against Mr. Benitez and Ms. Lopez took a shocking and horrific turn.