The Stanford “Model” Student and her Silicon Valley Mentor

[I have no problem using the Anglo-Saxon, and Shakespearean term “fucked”, but I softened it only to make search engines happier.]

Shakespeare's Fuck

One of the more prominent and most salacious performances of campus-related sexual assault has recently emerged from the Title IX shadows into the courtroom and the court of public opinion, and it contains many of the elements common to false and malicious allegations, compounded by issues of power-imbalance, family interventions, therapeutic conditioning and pecuniary interests, and made more complex by a campus hearing process influenced and reversed by victim advocacy protest, media attention and the unrelenting pressure of ever-more stringent government mandates.

Opening the Curtain on a Post-Modern Tragedy

Opening Curtain

A “dream” Silicon Valley relationship ends in collapse, and what had been described only in glowingly loving terms gradually morphs into a story of unremitting sexual and emotional abuse, serial rape, psychological kidnapping, and sex slavery.

Introducing the characters and the plot:

Ellie Clougherty

Ellie Clougherty

Ellie Clougherty was raised in Vienna, Virginia, a suburb of Washington, DC, and graduated from one of the nation’s most competitive high schools, the Thomas Jefferson High School for Science and Technology, with a straight-A average. She was also involved in music, was captain of the varsity lacrosse team, and was president of the National Honor Society. From approximately age 13 to 20, she worked for Ford Models as a print model.

Her father is an anesthesiologist in private practice and her mother is a systems engineer who worked for IBM before joining their national marketing division, and later started her own media-focused software company, which she sold in 2000 and joined the acquiring corporation.


Ellie, who once considered becoming a nun, by age 15 became interested in neuroscience. Her protective mother Anne, who managed Ellie’s modeling career, took great care to shield her lithe blonde daughter from unwanted attention from men. When Clougherty was 10, her family says, a man accosted her in a restaurant on her way to the bathroom. As a teenager trying out for modeling jobs, Ellie said, “There were always just a lot of men, complete strangers, on the subways and in the streets, blocking me off or following me, touching my breasts, grabbing my arm. I’d have to walk through them.”

Carrying this history of real or imagined sexual trauma and fear of men, Ellie Clougherty arrived at Stanford University in 2009, , where she became interested in technology entrepreneurship after a freshman year class on internet start-ups. At the tech events she frequented, where she was one of few women, she says that men pursued her and she often felt overwhelmed and intimidated.

Ellie was thrilled to be part of the Stanford community and enjoyed student life at Stanford immensely. However, she began experiencing negative unwanted male attention, including stalking and verbal assaults. Ellie and her mother reported two particularly threatening incidents to Stanford authorities (nota bene: it is always Ellie-and-her-mother making these decisions).

Ellie reports having felt anxious and unsafe because of these incidents and, in the fall of 2010, after she learned that she had been placed in the same residential hall as one of the male students she had reported for harassment, her anxiety triggered an eating disorder, which required her to take several months off of school to receive treatment. “I wanted to be invisible,” she said, with her early experiences and her Catholic guilt troubling her relationship with men and with her own body image.

Ellie withdrew from her classes and went home for therapy, including eight days of inpatient treatment. In the spring of 2010, she took a trip with her mother to New York, where a photographer they had met through her modeling work introduced her to a friend of his from the tech world: Joe Lonsdale. Ellie met Joe at a bar in January 2011 and returned to Stanford to resume her studies in the spring quarter of 2011.

Joe Lonsdale

Joe Lonsdale

Joe Lonsdale, a 2003 Stanford graduate, made a fortune by helping to start Palantir Technologies in 2004, a major data-mining company, and was among the “top entrepreneurs and venture capitalists” of Silicon Valley. In 2009, Lonsdale founded Addepar, offering private wealth management technology, and was a founding partner in 2011 of Formation 8, a technology venture capital fund.

In elementary school, Joe memorized hundreds of sequences of chess moves played by 19th-century masters on his way to becoming a scholastic chess champion. He learned to code in junior high school and spent most of his time in front of the computer.

At Stanford, he earned a degree in Computer Science, studied financial markets and macro-economics, and was a member of Phi Kappa Psi (the same fraternity targeted at U-Va by the discredited 2014 Rolling Stone gang rape story).

As a Stanford student, Joe edited the conservative Stanford Review, where he encountered Peter Thiel, its co-founder. When Lonsdale graduated with a degree in computer science, he went to work for Thiel, both at PayPal and at Clarium Capital, a macro hedge fund. Helping the company fight hackers, Lonsdale learned about weaknesses in the government’s surveillance systems and saw a business opportunity. With early funding from the CIA, Lonsdale helped Thiel and others start Palantir, which developed powerful data-mining software for surveillance and won contracts with hundreds of law-enforcement agencies, including the National Security Agency and the Defense Department. In 2009, Lonsdale went on to other ventures but retained a stake in Palantir, whose value would climb to more than $9 billion.

Joe Lonsdale has also hosted a 2014 fundraiser for Senator Rand Paul and has joined his finance team for a possible 2016 presidential bid. Joe’s mentor and business partner, Peter Thiel, was second only to the Koch brothers in donations to former Congressman Ron Paul’s 2012 presidential campaign.

In October 2011, Joe and Ellie connected again In Palo Alto and then more formally when Joe engaged in a volunteer mentoring program at Stanford and made himself available to Ellie, in a school program called Technology Entrepreneurship, Engineering 145.

A couple of weeks into their dating relationship, in March 2011, Joe invited Ellie to join him in Rome, where she says she lost her virginity. Ellie was a 21-year-old college junior and Joe was a 29-year-old Silicon Valley entrepreneur and already profoundly wealthy, showering her with luxury, gifts and contacts among the elite (including Mitt Romney).

Joe Lonsdale and Ellie Clougherty in Rome, March 2012

Joe Lonsdale and Ellie Clougherty in Rome, March 2012

Late at night on February 7, 2012, Ellie texted her mother: “Joe really really really seriously likes me.” In emails, Ellie told Joe that she found him attractive. “Kiss kiss kiss, you are super handsome,” she wrote in June, and later, “You are a sexy man” and “It was so nice sleeping with you.”

In August 2012, Joe took Ellie on a 10-day trip to raise money for Formation 8 in Hong Kong, Beijing and Seoul. After struggling through some relationship problems, Ellie acknowledged her own emotional and psychological issues, writing “Sometimes I think it would have been so much better had you met me a year from now, when I’m fully healed.”

At the end of September 2012, Joe rented out the Hearst Castle on the California coast for a lavish 30th birthday party with hundreds of guests and Elllie as the gowned hostess. But over the autumn and winter, their relationship frayed.

In December 2012, Joe wrote Ellie a long email. “We are dealing with serious relationship dysfunction,” he began, and laid out a list of examples in bullet points. The first read: “Sometimes I feel it’s very clear you are eager to engage sexually, but other times you will talk about me taking advantage of you and forcing myself on you as if there is this dirty old man / young innocent student dynamic, and I should feel badly about it. We will do something and then just a bit later you’ll talk as if ‘how can I stop you from making me do that?’ and yet earlier I honestly thought you wanted to.”

Break-Up, Downward Spiral & Outside Influences

Joe spent that Christmas with Ellie at her family’s home, but they fought about a number of things, including that he had not brought her a present. When he got home, Joe broke up with her over email.

In a mid-February 2013 phone call, Ellie told her mother that she was having a hard time making it to class, was not eating and was spending hours in her dorm room alone. Her mother flew out to take her home, and brought her a book called Why Does He Do That?: Inside the Minds of Angry and Controlling Men.

The next morning, after a night spent reading the book, Ellie typed furiously on her laptop: “If I said no, he would slowly convince me / make it look like he was going to die if I didn’t climb on top of him. He would freak out when I mentioned I wanted to slow things down, even if it meant having sex only once each time I would see him. One time I cried hysterically because it freaked me out and he wouldn’t listen to me but he would then immediately start crying way harder than me saying he felt like a creepy old man and didn’t want to feel that way. I felt compelled to comfort him even though I was the one who felt violated.”

It appeared that the book on domestic violence offered Ellie an entirely new perspective on her relationship. Ellie decided she wanted to “escape”, and met Joe in a Palo Alto park in late February 2013, and they broke up while her mother and her loyal friend Jane waited for her in a nearby wine bar.

On March 1, 2013, Ellie went to Stanford’s counseling center to tell them that Lonsdale had forced her to have sex when she didn’t want to and also revealed the incident when a man accosted her in the restaurant bathroom when she was 10. The university psychologist noted in a report that she “seems to have symptoms of post-traumatic stress disorder from current and past trauma”. Ellie went home to Virginia and spent days crying and rocking in a corner of her family’s living room. She undertook therapy twice a week with a clinical psychologist who treated her eating disorder by prolonged-exposure therapy, a treatment developed for combat-related stress disorders, in which a therapist prompts a patient to describe deeply traumatic events, and to listen to the tape recordings repeatedly to desensitize the patient.

On the tapes, the therapist reflected back Ellie’s account, saying that she had experienced “multiple traumas over a prolonged period of time that did repeated damage.” In one session, he told Ellie, repeating her words, that Joe “held you captive and you were essentially brainwashed over a year”.

On the tapes, Ellie described particular sexual acts that she didn’t want to take part in and how Joe cajoled, begged and insisted until she gave in. She also said that “It was rape in a sadomasochist way nine times a day.” In a later session, the therapist mirrored what she told him: “You didn’t have personal agency, you didn’t have personal choice, all of those things had been robbed from you.”

Ellie was further reevaluating her sexual relationship with Joe and becoming convinced that it was a non-consensual one based on manipulation and force.

Initially, Ellie told the therapist (as she had said to her friends) that she had sex for the first time with Joe in Rome. Weeks into therapy, however, Ellie said that Joe had earlier taken her to his house, yanked her into a bedroom, thrown her down on a bed and raped her (according to the lawsuit she filed in 2015, though she was then a virgin, he “began to penetrate her with his flaccid penis”).

In the course of the therapy, Ellie came to reject the term “relationship” or even “abusive relationship” to characterize her year with Lonsdale, and came to call it a “psychological kidnapping” – a term she came up with after watching a video about domestic abuse on the Internet – and she now says she was raped every time she and Lonsdale had sex.

Ellie finished her coursework for Stanford on-line when she was at home, and during that time she decided she wanted Stanford to take action for what she then viewed as sexual harassment and abuse.

Filing Title IX Complaint, Campus Protests, & Reversal of Finding

Clougherty & Stanford

In May 2013, Ellie and her parents went back to Stanford to ask the university to investigate Joe’s conduct. Ellie submitted to Stanford a written account of her sexual-assault and harassment allegations, including selected texts and emails. The university appears to have initially investigated only whether Lonsdale broke the rules against consensual relationships between mentors and mentees, which the university treats as “inherently unequal,” like relationships between teachers and students.

An outside legal investigator hired by the university interviewed Lonsdale without a lawyer. He said that he didn’t know about the rule against consensual relationships between mentors and mentees, which is posted on the university’s website but was not included in the mentor handbook for E145.

In June 2013, Stanford found that, even though the relationship was consensual, Lonsdale had violated this rule and said he could not mentor undergraduates for 10 years. Lonsdale was unhappy with the decision, but to Ellie and her mother, the penalty seemed negligible, and they were confused about why Stanford hadn’t looked into her sexual-assault allegations.

In November 2013, Ellie and her mother attended a conference on gender-based violence at Harvard and heard a talk given by a Harvard lecturer and lawyer, who said ‘You have these rights in Title IX’, and Ellie’s mother Anne convinced the speaker to represent Ellie in negotiations with Stanford and Lonsdale over her allegations of sexual harassment and assault.

In December 2013, Stanford, Clougherty, Lonsdale and their lawyers met for a daylong mediation. Before the meeting Clougherty texted her friend Jane: “Totally joe take down scheme!” Clougherty settled with the university for an undisclosed amount. A few days later, Clougherty received a settlement proposal from Lonsdale, which contained a blanket nondisclosure provision that Clougherty did not want to sign and the deal fell through. Lonsdale vehemently denies making a settlement offer.

Shortly after that, Stanford opened a new investigation into Clougherty’s sexual-harassment and assault allegations. Stanford had learned that Lonsdale had dated another student after he and Clougherty broke up, but she told the investigator that her relationship with Lonsdale was consensual and not abusive.

Lonsdale submitted a statement in writing, in which he said that he and Clougherty were in love and she never said no to sex or even expressed ambivalence in the moment. Lonsdale said the problem wasn’t Clougherty’s lack of consent. It was that she sometimes felt bad after the fact. “There was a lot of stuff around the Catholic guilt,” he said, “about how she didn’t like being addicted to the body.”

Following public demonstrations over another prominent case of sexual assault, the university reached a new decision, finding that Lonsdale had engaged in sexual misconduct and harassment during his relationship with Clougherty and banned him from campus “for any purpose”. After 10 years, he could apply to return, and Stanford “strongly encouraged” him to seek counseling for sexual misconduct and relationship violence.

Lonsdale says that he believes Stanford’s treatment of him was influenced by student activism and the protests over another case. Lonsdale’s lawyers asked the university in November 2014 to reopen the case, and submitted to Stanford hundreds of pages of his email correspondence with Clougherty and her mother that they hadn’t previously provided, along with an eight-page sworn statement from Ellie’s friend and chief supporter Jane.

In the months after Jane helped Ellie break up with Joe, she says that she watched with increasing unease as Ellie’s accusations rose from emotional abuse to rape. “In March 2014, she texted me that she considered herself a ‘sex slave’ during her relationship with Joe,” Jane wrote in her statement. “This is far, far beyond anything that she ever said about the relationship when it was happening or for a long time afterward. It also made no sense in light of her clear enthusiasm about the relationship.”

Jane said about Ellie and her mother, “They asked me to lie, and I said no.” “She hung up on me after five years of helping her through all her life issues and crises… All of that, only to be put to the side when I won’t do what they want me to do.”

Jane, who works in tech, got in touch with Lonsdale late in the summer of 2014. “I thought, He needs to know what I know,” she said. In her sworn statement, Jane wrote, “If I sensed, even remotely, that the relationship was in any way abusive, I would have talked to Ellie’s mom about it.”

Ellie Clougherty is currently a student at the University of Virginia, enrolled in a master’s program in data science and living with her brother, also a student, in a Charlottesville apartment their mother found them. After Rolling Stone published its story in November 2014 of a lurid fraternity gang rape at that campus, Ellie and Anne arranged a meeting with the university president, Teresa Sullivan. On the day before Thanksgiving, they spent a couple of hours sitting in front of a fire at Sullivan’s home, drinking hot chocolate and talking about the effects of trauma (how many students are granted such privileged access to a university president?). Ellie gave President Sullivan a beaded bracelet she had made and was thrilled when Sullivan mentioned the gift in a major speech on campus the following week, calling Clougherty the survivor of a “brutal assault inflicted on her at another university” (one of many rush-to-judgement statements made by Sullivan that were not factually supported).

Competing Lawsuits

In January of 2015, Ellie Clougherty and her mother filed a sexual assault and harassment lawsuit in federal court in San Francisco against Joe Lonsdale. Lonsdale filed a counterclaim for defamation.

Clougherty’s lawsuit claims that Lonsdale raped Clougherty several times while serving as her mentor and later hired her as an intern for Formation 8 in May 2012 in order to remain close to her. He allegedly continued to force himself upon Clougherty over the following months, and his interspersed moments of loving behavior caused Clougherty to become “powerfully attached” to Lonsdale, which explains all the loving email correspondence.

The suit charges Lonsdale with sexual battery, sexual assault, domestic violence, gender violence, sexual harassment, intentional infliction of emotional distress and negligent infliction of emotional distress. The civil lawsuit also includes a charge of negligent retention and supervision against Formation 8.

Londsdale Goes Public

On January 28, 2015, Joe Lonsdale sent an email to his friends and associates, saying “I’m writing because a personal matter that I’ve been dealing with is becoming public, and I want you to hear the facts directly from me.”

For some time now, I have been defending myself against a vengeful, personal attack by a disturbed former girlfriend. This is a woman that I dated for a year and whom many of you knew. Shortly after I ended the relationship in 2013, my ex-girlfriend began a malicious campaign of lies. Upset that I was not willing to continue the relationship, she contacted business associates, friends, and others advancing a repugnant and increasingly bizarre narrative of “abuse” hoping to hurt me and damage my career. To quote the words she sent in a text to her close friend, this is a “Joe take down scheme”.

Because she told me throughout our relationship that she had been a victim of abuse before we met and had suffered from mental health issues, I tried to be as sensitive as possible, even as she made it clear that she was intent on defaming and damaging me…

Last night, she took her attacks public by filing a lurid and salacious lawsuit alleging abuse and assault. Let me be completely clear: there is not a single allegation of abuse, assault or neglect contained in her lawsuit that is true… There are only hundreds of loving emails and handwritten love letters from her during and even immediately after the relationship. More than six weeks after first breaking up with her, for example, my ex-girlfriend emailed me, “Joe, you are capable of treating me better than any man in the world. You have proven this to me before, which is why I fell in love with you….I crave for you to come closer.”

There are also statements from third parties, including a very close friend of hers who has voluntarily come forward to state in an affidavit that she is lying – and that she tried to enlist the friend to lie about me. In her affidavit, this close friend of my ex-girlfriend states that “at no time” during the relationship did she ever say that I had been verbally or physically aggressive to her or that any part of our relationship was non-consensual.

Tomorrow I will file a defamation lawsuit in Federal court, and I will counter these vindictive attacks at every turn. I will not be bullied by lies and threats, and I now have the ability to fight these lies in the light of day. I am fully prepared to confront her fabrications with facts and evidence.

In early 2013, I ended a year-long relationship with a 22-year old woman named Ellie Clougherty. I would not name her, but she has identified herself in the lawsuit that she filed… We were a very public and committed couple. And like any couple in a long-term, loving, committed relationship, we attended important family and social events together, went on vacations together, and planned our future together.

Our first meeting came at her initiative, about a year before we became a couple. While a Stanford undergraduate, she and her mother sought me out through a mutual friend, and we first met in New York in the Spring of 2011. After this first encounter, we kept in contact over the ensuing months.

While we had been seeing each other socially even before the class started, and started dating during class, it was not until after the class ended and we were on a trip to Rome that we began an intimate relationship (an experience my ex-girlfriend later described to me in an email as “a beautiful moment together”). She was 21, and I was 29.

She accompanied me to every major event in my life, and on numerous vacations and trips. She was my date at my 30th birthday party and my father’s wedding, and we traveled together to Italy (a trip she recalled fondly for the “love” she felt for me on it)…

Throughout the course of our relationship, she regularly expressed her love and affection for me – which I reciprocated. There are hundreds of emails from her telling me how much she loved me, how happy she was, and how excited she was about our future… These and other effusively loving emails exist from throughout the entirety of our relationship, including some from immediately after we broke up.

By the Summer of 2012, our relationship had developed to a new phase. Our discussions and emails turned to talk about future plans – kids, and the impact of our careers on family. She told friends that she might not need to work because of her plans to marry me…

…In retrospect, I understand that I was naïve about some warning signs – especially those concerning her unstable behavior and related mental health issues, many of which were revealed for the first time over six months into our relationship…in August 2012. I truly wanted to think that the positive aspects of our relationship would outweigh what she told me were past issues in her life and that we could work through anything together.

…Her mother was always involved in our relationship – urging a mutual friend to introduce us originally, accompanying us on one of our first dates, encouraging me to spend more time with her daughter and making decisions for her… one time thanking me for the positive impact our sexual relationship had on her daughter. Her mother also continued to insert herself more and more in planning our future together, including my deliberations over a home purchase in Palo Alto… In another harbinger of things to come, her mother attempted to leverage our relationship for personal, financial gain. She asked me for contacts with investors, and asked me to invest her money. Toward the end of 2012, with her daughter’s graduation in sight, she also repeatedly pressured me to secure a high-paying job for her daughter.

As she continued to behave more erratically toward the end of the year, my unease about the relationship began to grow, and I lost confidence that we could work through our fundamental problems. Just before the end of December at a vacation at their family house, it became obvious to me that it needed to end. After that trip, I broke it off, and yet, over the course of the next two months, both she and her mother persuaded me through emails to try to preserve the relationship. Her mother emailed me a two-page letter imploring me to get back together with her daughter. She also mentioned that I should continue to help her daughter find a job and buy her more thoughtful gifts.

Just days after these entreaties, in late February of 2013 when I made it clear the relationship was over for good, the tone of my then-ex-girlfriend and her mother changed dramatically. When I began dating other women casually, my ex-girlfriend and her mother became disturbingly angry and vindictive. In one of our final break-up conversations, my ex-girlfriend suggested to me, for the first time, that I had been “emotionally abusive” toward her, and told me that she had visited a campus counseling center to discuss it. This was the first time she had ever mentioned or even hinted about any alleged “abuse” in our relationship.

I brushed this off at first, as she often invoked the term “abusive” when discussing her ex-boyfriends (on several occasions, she had told me various ex-boyfriends or male friends had “abused” or “stalked” her). By that summer, however, I heard through friends that she was openly accusing me of being “abusive,” creating completely made-up and hurtful stories that she began to spread among my friends, associates, and business partners…

She also reported her fabrications of abuse to Stanford. When Stanford first contacted me in May of 2013, I was informed only that it was investigating whether I had violated school policy about consensual relationships between students and staff, and I’d heard none of the sexual harassment claims. Because I was confident in my standing as a volunteer and not university staff – and confident in my innocence – I readily agreed to be interviewed without ever contacting a lawyer. I had done nothing wrong and had nothing to hide. What I didn’t know until many months later was that she had been fabricating new stories about our relationship – lies designed to leverage the political climate on campus around sexual assault that would pressure Stanford to take action.

In late 2013, I learned for the first time that Ms. Clougherty’s new fictional story was not one of emotional conflict, but some undefined “sexual abuse”.

As I have since learned, Stanford’s initial response to her complaint was muted, finding that it was a consensual relationship, but claiming I had an obligation to disclose it to the University. I thought that was the end of it, as I’m sure Stanford did as well. However, Ms. Clougherty and her mother were clearly not satisfied. They retained lawyers and threatened Stanford with negative publicity concerning its handling of her complaint.

As most of you know, Stanford has been in the spotlight in connection with its prior mishandling of on-campus sexual assault claims. Her team of lawyers exploited this political climate to their benefit. Under this pressure from my ex-girlfriend and her lawyers, Stanford initiated a second investigation, dispensing from the outset with any pretense of fairness.

It’s not an overstatement to say that what followed was a Kafka-esque nightmare. Stanford’s investigation guidelines are such that the University could not tell me any of the specific allegations against me, and I never had a chance to review or comment on anything submitted by Ms. Clougherty to support her manufactured and constantly-shifting claims. Key evidence, including email correspondence between us, that directly exculpated me and proved Ms. Clougherty was lying was not considered, nor were previous claims that she had made against other men in the past. The University never spoke to key witnesses with direct, personal knowledge, whose testimony would further prove she was lying.

Out of the blue, I received a terse, written notice that Stanford had banned me from campus for 10 years. Again, I was never told what the specific allegations were against me. All I was told was that Ms. Clougherty claimed that there was some subset of sexual encounters between us that were “abusive”.

Despite being told that as a non-student I had no right to appeal the ban, last October I provided Stanford with volumes of evidence – literally hundreds of emails – proving that my ex-girlfriend and I shared a loving, communicative and respectful relationship and her allegations of “abuse” were suspiciously never uttered until after her and her mother’s attempts to resurrect the relationship failed.

The evidence shared with Stanford includes a lengthy statement from one of Ms. Clougherty’s closest friends, stating not only that she believes her friend to be lying but also that Ms. Clougherty and her mother asked the friend to perjure herself and lie to Stanford to help get me banned from campus.

This friend contacted me on her own accord – neither I nor anyone representing me approached her – and later provided her definitive statement. “I do not believe, based on Ellie’s excitement and happiness when discussing their relationship – including the first time they were intimate – that Ellie was in any way forced to have sex,” she says in her statement. And when Ms. Clougherty and her mother attempted to get her to testify to alleged abuse, “I told her I thought the accusations were false and I was not willing to lie.” She also states, “I feel bad about testifying that my long-time friend is not being truthful. But I don’t think that Joe should be accused of something he did not do to help her cope with her guilt about having sex with him or to punish him for ending the relationship.”

I hope Stanford considers this evidence and ultimately does the right thing.

Regardless, the latitude Ms. Clougherty has received from Stanford to make unsubstantiated false allegations will not carry over to the courts. And while I do not relish the headlines and stories her lies will create, I am relieved to finally be able to confront them with the full force of evidence and third-party testimony, including other ex-girlfriends who will attest to my respect for women and that I would never abuse anyone.

I have tried to protect my friends and loved ones from being impacted by this sad episode. But as Ms. Clougherty and her mother have taken their campaign of false and disturbing accusations to the courts, it’s important to me that you know the truth.


Plaintiff Elise Marie Clougherty (“Ms. Clougherty” or “Plaintiff”) alleges as follows:

  1. This action arises out of a sexually, emotionally, and physically abusive relationship between Stanford University mentor Mr. Joseph Lonsdale (“Mr. Lonsdale” or “Defendant”), a successful and well-known Silicon Valley entrepreneur-turned-venture capitalist, and Ms. Clougherty, which lasted from February 2012 to February 2013. At the time of the events described in this Complaint, Ms. Clougherty was an undergraduate student at Stanford University (“Stanford” or the “University”) and nearly ten years Mr. Lonsdale’s junior. During the period in question, Mr. Lonsdale continuously and systematically subjected Ms. Clougherty to repeated and incessant sexual assaults and abuse, employing psychological manipulation and coercion in order to confuse, isolate, and otherwise disorient Ms. Clougherty from appreciating the true danger of her situation
  1. In January 2012, Mr. Lonsdale used his participation in a technology entrepreneurship mentor program at Stanford to hand-pick Ms. Clougherty to be his mentee. Over the course of the next year, Mr. Lonsdale took advantage of his position of power and Ms. Clougherty’s youth and trusting personality to draw her into a highly deviant, abusive, and controlling relationship during which he perpetrated hundreds of non-consensual, and often violent, sexual acts upon her.
  1. During the summer of 2012, Mr. Lonsdale hired Ms. Clougherty to be an intern at his technology venture capital firm, Formation8 GP, LLC and Formation8 Partners, LLC (collectively, “Formation 8”). Mr. Lonsdale’s position of authority over Ms. Clougherty enabled him to extend his control over her and to continue subjecting her to repeated, non-consensual sexual acts.
  1. In or around February 2013, Ms. Clougherty’s family began to suspect that something was terribly wrong with her relationship with Mr. Lonsdale. They intervened and helped her leave Mr. Lonsdale. Over the next couple of months, they discovered the true extent of the deviant and violent abuse she had endured as his supposed girlfriend over the previous year.
  1. In February 2013, Ms. Clougherty and her family reported Mr. Lonsdale’s actions to Stanford University. Stanford retained an outside investigator to investigate her allegations. At the conclusion of the investigation, the outside investigator found that Mr. Lonsdale had engaged in conduct meeting the definitions of sexual harassment and sexual misconduct under Stanford’s Title IX policy, and that it was “more likely than not that [Ms. Clougherty] expressed to [Mr. Lonsdale] that she did not want to engage in the sexual conduct in question, but that [Mr. Lonsdale did not comply with [her] request.” As a result of the investigation, Stanford banned Mr. Lonsdale from Stanford’s campus for a minimum of ten years.

In the “Statement of Facts” within the Clougherty lawsuit document, were these salacious assertions:

From very early on, Mr. Lonsdale repeatedly told Ms. Clougherty that it was women’s nature to enjoy being raped, especially if they are raped by a man with greater means.

Throughout the [London-Rome] trip, Mr. Lonsdale deprived her of both food and sleep by scheduling late night and early morning activities, delaying meals, not ordering her enough food, and other such tactics.

To control Ms. Clougherty, Mr. Lonsdale employed many forms of psychological manipulation and control on her, including but not limited to “positive intermittent reinforcement,” “gaslighting,” isolation, sleep deprivation, food deprivation, anger, embarrassment, and guilt.

[Gaslighting is a form of mental abuse in which information is twisted/spun, selectively omitted to favor the abuser, or false information is presented with the intent of making victims doubt their own memory, perception and sanity.]

Throughout this period, Mr. Lonsdale repeatedly commented to Ms. Clougherty that women needed to be raped to learn to be loyal and that they really enjoyed being raped more than they let on.

During intercourse, he would regularly shake Ms. Clougherty violently and would not stop, despite her protests, until she promised she would always “listen to her master”. In addition to shaking her violently during sexual assaults, he also began strangling her, slapping her, scratching her, yanking her by the hair so hard that he would lift her torso off the bed, and slamming her body against the walls and bedboards.

Mr. Lonsdale typically forced Ms. Clougherty to have sex several times a day – on some occasions, as many as ten or more times a day. When Ms. Clougherty was on her period, Mr. Lonsdale’s attacks were especially frequent. He often would not let her buy tampons and seemed to relish getting her blood everywhere – on her clothing, bed sheets, hotel furniture, car and bus seats, and elsewhere.

On several occasions he admitted that he was abusing her, but claimed that he had a sickness, that he could not control himself, and that he needed her help to change. After months of seemingly kind and loving behavior from Mr. Lonsdale interspersed with the abuse, Ms. Clougherty felt powerfully attached to Mr. Lonsdale and believed that if she was more supportive and treated him with kindness, he would stop hurting her. She wrote him numerous emails and love letters to let him know how much she cared about him in the hope that it would end the abuse.

[This was the attempted rationalization for the many dozens of loving emails sent by Ellie to Joe.]

In a 10-page letter sent by email from Ellie to Joe on August 23, 2012, after an argument following their trip to the Far East (introduced as evidence in Lonsdale’s counter-suit):

In high school and in my modeling career, being a perfectionist was rewarded and it was a skill I nearly “perfectly perfected” in my late teens. Unfortunately, that same perfectionism that I received accolades for led to the demise of my health and became so extreme that I started seeing imperfections that honestly didn’t exist. I began having cognitive distortions about my body and diet to the point that I unconsciously trained myself to *believe* I was eating, when in reality, I wasn’t. From my mother’s perspective, she thought I was lying to her about my health, but in reality, I was physically incapable of speaking the truth, because cognitively, I was blind to it. . .

This perfectionism is sometimes reflected in how I treat you because the closer and closer I let you in, the more and more I begin to treat you the same way I treat myself … My illness is reminiscent of Rome: strong, powerful, and abusive towards women.

When it comes to moral issues, relationships, and coming to terms with my own humanity, however, perfectionism is disastrous and sinful. Because I spent so many years abusing my emotions to feel “disgust” whenever I didn’t want to do something (eat candy, sleep with boys, etc.), any small trigger to my system would set off a huge chain reaction of emotion that is acceptable to a certain degree, but beyond that threshold, begins to topple reason and temporarily distort cognition… This Mr. Lonsdale is what I call the perfect tornado. Cute, perhaps, but treacherous.

…I tangentially discovered I had PANDAS (Pediatric Autoimmune Neuropsychiatric Disorders Associated with Streptococcal infections) … it began to damage my basal ganglia which play a huge role in the perception of physical needs (hunger, warmth, etc.), motor control, and cognitive / emotional processes which apparently includes the emotions of love and attraction (fantastic!). … but it also leads to those moments when I send you “ultimatums” because the emotional strain takes such a heavy toll, I just want to get rid of the pain completely. Or when it took me so long to find a healthy sexual rhythm. These behaviors are taxing, but this isn’t how I want to act, and these actions will change for the better as my brain heals….

I consciously overlaid a feeling of disgust to prevent myself from eating… I did this because I wanted to succeed in the modeling world so tremendously badly. I had lots of ambition and lots of drive. This pattern got so out of control that eventually… I lost my sense of hunger; I lost my ability to smell; I stopped being able to read… and no one had any idea. In a lot of ways, I was slowly dying. This was where I was exactly two months before we first met.

Here’s what happened two weeks before: I was taken away from my parents and locked up in a nearby mental health hospital, against my will. There were lots of cameras and lots of locked doors… I didn’t know what was happening to me, but I was immediately asked to remove my clothes for a strip search… I wasn’t allowed to keep my belongings. Nor could I call my parents… The first day there I wasn’t allowed to eat or drink anything because I wasn’t “on schedule” and the nurses were just going along with orders.

…By the second day, the doctors began to convince me I was incapable of surviving in the outside world and that my parents were a corrupting influence. I started to believe them… and I started to lose myself…

But then I became aware. I also became really close to God. I never felt closer to God actually…

I had to play every possible card I could to get out of there. I answered all their questions exactly as they wanted them to hear. I was complacent and thankful, praising them for their wisdom of the disorder and for wanting to help me. Some of the other girls…didn’t have the same strength to play the system as I did.

It was like I had an invisible power… From that moment on, I’ve never felt more vindicated in who I was or what I stood for; I became thoroughly confident in the power of awareness and sanctity of intelligence. It was a tremendous gift.

…I don’t expose myself to certain kinds of music, art, and television that eventually conditions me to accept a certain behavior is “good”. It’s my responsibility to protect myself from harmful influences and “cut off whatever leads me to sin”.

I see you as one of my paths, and I would only hope you see me as yours, but if not, you deserve to take a step along the right path … I definitely think you’d be an amazing spiritual leader by nature of who you are as a person and that’s beyond enough for me … I accept you thoroughly and don’t wish you were anything different from who you are now, or that you behave differently if that isn’t true to who you are.

…I’ve always said that I want to be with someone who makes me a better person… You’re the first person I’ve met who gives me something to fight for and who pushes me to be way better…

Sometimes I think it would have been so much better had you met me a year from now, when I’m fully healed and healthy enough to be in a relationship…

Statement from Kristen Dumont, Partner, Goodwin Procter; co-counsel for Mr. Lonsdale, 1-28-2015:

“This lawsuit is a vile collection of lies and a transparent attempt to destroy the reputation and good name of Joe Lonsdale. To borrow the words Ms. Clougherty used in a text to a friend, this is a ‘take down scheme’. The overwhelming and unequivocal evidence – which includes hundreds of emails from Ms. Clougherty herself and testimony from her close friend – will exonerate Mr. Lonsdale. For nearly two years, Mr. Lonsdale has been eagerly waiting to tell the truth and to fight these defamatory and outlandish allegations. Sunlight is always the best disinfectant and we welcome this fight and our day in court, where facts trump fiction.”


Defendant and Counterclaimant Joseph Lonsdale, by and through his undersigned attorneys, files these Counterclaims against Plaintiff and Counter-Defendant Elise Clougherty, and in support thereof, alleges as follows:

  1. Joseph Lonsdale (“Mr. Lonsdale”) brings this action to stop a vicious and vengeful campaign by his ex-girlfriend, Plaintiff Elise Clougherty (“Ms. Clougherty”), to destroy his reputation with false and outrageous accusations. Since Mr. Lonsdale ended their relationship nearly two years ago, Ms. Clougherty has repeated her fabricated accusations to numerous people at Stanford, to Mr. Lonsdale’s friends and social acquaintances, and to his business colleagues, causing serious damage to Mr. Lonsdale’s reputation. Worse yet, through her inflammatory lies, Ms. Clougherty is seeking to capitalize on the serious and highly-politicized issue of sexual assault against women on college campuses, and by doing so undermines and discredits legitimate claims of sexual assault.
  1. This shameful lawsuit is just the next chapter in a long-running campaign that Ms. Clougherty herself admitted is a “Joe take down scheme” in a text message that she sent to a former close friend. Alarmed and shocked by Ms. Clougherty’s attacks on Mr. Lonsdale, that close friend has since come forward out of conscience to share Ms. Clougherty’s admission with Mr. Lonsdale and reveal the truth.
  1. Mr. Lonsdale is an entrepreneur and businessman in the San Francisco and Silicon Valley area who has founded several well-known and successful companies. Until February 2013, Mr. Lonsdale was involved in a consensual romantic relationship with Ms. Clougherty that lasted approximately one year.
  1. Mr. Lonsdale and Ms. Clougherty first met in New York in a bar, approximately one year before they would interact at any Stanford class. Ms. Clougherty traveled to New York to meet Mr. Lonsdale after a mutual friend said he would introduce her to Mr. Lonsdale. Despite the fact that Mr. Lonsdale was in a relationship with another person at that time, Ms. Clougherty persistently flirted with him (and he with her) and stayed in frequent contact with him after that, meeting him several times during the next year. After learning that Mr. Lonsdale regularly volunteered as an alumni resource in an entrepreneurship class at Stanford, Ms. Clougherty registered for that class for Stanford’s Winter Quarter of 2012, almost a year after they’d first met.
  1. By February 2012, Ms. Clougherty and Mr. Lonsdale began to date and she became Mr. Lonsdale’s girlfriend. They began a romantic relationship that lasted almost one year during which they regularly engaged in consensual sex, and Mr. Lonsdale and Ms. Clougherty developed a deep affection for one another. The two spent extensive time with one other, took multiple vacations together, got to know each other’s families, and generally behaved like any two people in a serious personal relationship. Indeed, Ms. Clougherty’s mother, Anne Clougherty, frequented social events with them and got to know Mr. Lonsdale especially well, often corresponding with him independently of Ms. Clougherty.
  1. As Mr. Lonsdale grew to love Ms. Clougherty, he also began to learn about her past relationships with men, including that she claimed to have suffered sexual abuse numerous times before meeting him, starting when she was working as a teenage print model and including several men on the Stanford campus.
  1. A turning point in the relationship occurred around the time that the two of them went on a trip to Asia in August 2012. Around that time, Ms. Clougherty started to openly display signs of severe mental health issues. After Ms. Clougherty became furious with Mr. Lonsdale on a trip to Asia and verbally lashed out at him, she wrote a long letter to apologize and explain her extreme behavior. In that letter, Mr. Lonsdale learned that Ms. Clougherty had been involuntarily committed to a mental health facility just before they met. She said, “I was taken away from my parents and locked up in a nearby mental health hospital, against my will. There were lots of cameras and lots of locked doors …” Ms. Clougherty described being abused and psychologically manipulated by the medical staff there, including by isolation and deprivation of food and water (much as she would later accuse Mr. Lonsdale of isolating her and depriving her of food in the Complaint): “Nor could I call my parents. They gave me a phone card but every time I tried to use it, it ‘wouldn’t work’. The first day there I wasn’t allowed to eat or drink anything because I wasn’t ‘on schedule’ and the nurses were just going along with orders …”
  1. In her description of her commitment to a mental health hospital, Ms. Clougherty said that she had also previously suffered “an autoimmune reaction that fought so viciously, it began to damage my basal ganglia which play a huge role in the perception of physical needs (hunger, warmth, etc.), motor control, and cognitive / emotional processes …” She explained: “My perception of time was warped (what?); I started seeing myriads of color on white tile floors; that weird purple dot that you get too became almost permanent; open spaces with people scared me, almost like they would scare a little chipmunk; I was so cold I couldn’t leave my apartment because I thought it would look weird going to the library with a comforter wrapped around me…”
  1. Ms. Clougherty also went on to specifically describe how she suffered “cognitive distortions” at times that convinced her that things were happening that did not ever happen: “I began having cognitive distortions about my body and diet to the point that I unconsciously trained myself to *believe* I was eating, when in reality, I wasn’t.” She went on to explain “[f]rom my mother’s perspective, she thought I was lying to her about my health, but in reality, I was physically incapable of speaking the truth, because cognitively, I was blind to it…”
  1. As time went by, Ms. Clougherty began acting more and more erratically. During the final few months of their relationship, Ms. Clougherty frequently blew up in anger at Mr. Lonsdale without warning and often sent him long, rambling emails about their relationship. Increasingly disturbed by the situation, Mr. Lonsdale decided to end the romantic relationship in late 2012. After that, both Ms. Clougherty and her mother Anne Clougherty persistently attempted to convince him to change his mind and take back Ms. Clougherty.
  1. Mr. Lonsdale and Ms. Clougherty briefly rekindled their relationship, but Mr. Lonsdale again ended the relationship in February 2013. As it became clear that the romantic relationship was completely over, Ms. Clougherty’s behavior changed dramatically and she began making a string of stunningly false, and constantly changing, accusations – first saying that Mr. Lonsdale had “emotionally” abused her and eventually claiming that he had sexually assaulted her over the course of their relationship.
  1. Ms. Clougherty has made such statements to numerous people at Stanford, Mr. Lonsdale’s personal friends and acquaintances, business contacts, and her own acquaintances, including her mother. This smear campaign has caused significant harm to Mr. Lonsdale’s reputation and has significantly disrupted his personal life and business ventures.
  1. For the first time, with the filing of the Complaint in this action, Mr. Lonsdale has learned the full extent of the appalling web of lies that Ms. Clougherty has spun – including the reprehensible and unfathomable allegations that he repeatedly raped her and told her that women “enjoyed” being raped and the he suffered a “sickness”. But Ms. Clougherty’s allegation that Mr. Lonsdale committed literally “hundreds” of “non-consensual” acts upon her is entirely contradicted by her well-documented, eager participation in their loving relationship. Realizing that those facts expose her story for the fabrication that it is, Ms. Clougherty has concocted an elaborate and radically implausible theory that she so eagerly participated in the relationship only because Mr. Lonsdale employed “many forms of psychological manipulation and control on her, including but not limited to ‘positive intermittent reinforcement,’ ‘gaslighting,’ isolation, sleep deprivation, food deprivation, anger, embarrassment, and guilt”.
  1. The hard evidence, including Ms. Clougherty’s own admissions in hundreds of emails to Mr. Lonsdale, exposes her “mind control” theory for the outright lie it is. As just a few telling examples of those lies:
  • She describes their first “sexual encounter” at Mr. Lonsdale’s home in Los Altos as an abusive scene with Mr. Lonsdale “aggressively” attempting to touch her and her “pushing” him away and non-consensually “penetrating” her. But Ms. Clougherty’s own email to Mr. Lonsdale after she returned home that very night tells the real story about how she felt about their first kiss that evening at his house as she wrote: “I love getting to know you! More deets about rome soon :)”
  • She says that during their sexual encounter on a trip to Rome in March 2012, Mr. Lonsdale was “abruptly … penetrat[ing]” and “grabb[ing]” her multiples times despite her “pull[ing] away,” leading to her locking herself in the bathroom and crying for several hours. But Ms. Clougherty would write Mr. Lonsdale days after Rome to exchange flirtatious email regarding the trip to Rome, prompted by seeing a photo of them together at the Coliseum. And in July, she wrote another email and admitted that she “told [a mutual friend] in Rome, the love I feel for you is deep”. And months later she would fondly write another email to describe their sexual encounter in Rome as the “day we shared such a beautiful moment together! If you know what I mean…”
  1. Whether her lies about Mr. Lonsdale are more of the “cognitive distortions” Ms. Clougherty has suffered in the past that leave her “incapable of speaking the truth” or are deliberate and vengeful makes no difference. Either way, they are egregious falsehoods that are aimed at destroying Mr. Lonsdale’s reputation. Based on the foregoing, and as alleged in more detail below, Mr. Lonsdale now seeks to set the record straight and end Ms. Clougherty’s outrageous attacks on him. Accordingly, he asserts the following claims against Ms. Clougherty for defamation, intentional infliction of emotional distress, negligent infliction of emotional distress, and invasion of privacy and seeks damages and injunctive relief to prohibit further harm to him.

Sworn Deposition from Ellie Clougherty’s close friend Jane (excerpts):

Before she met Joe, Ellie had already told me that several of her ex-boyfriends were “abusive” to her.

During 2010-2011, Ellie was getting over a relationship… she frequently said that this ex-boyfriend was “crazy” and emotionally abusive to her.

During the Winter Quarter, Ellie had a relationship with another boyfriend. She told me that […] was also “abusive” and on more than one occasion, left her in what she described as “dangerous situations”. She frequently described […] as “psycho”…

Either while she was still dating […] or very shortly after her relationship with […] ended (I am not certain of the timeline), Ellie told me she had begun dating Joe and said they were going to Rome together.

Ellie was thrilled about the trip to Rome. Immediately after she returned, she shared all the details about her trip with Joe. It sounded very romantic and she was very excited about it. She certainly described the trip as a very positive experience.

Ellie told me that she lost her virginity in Rome when she had sex with Joe. Ellie never suggested that the sex in Rome was non-consensual during those conversations. To the contrary, she told the story in a very positive and excited way… She clearly sounded like she wanted to have additional sexual experiences with Joe when we talked.

With minor exceptions consistent with the occasional ups and downs of a long-term relationship, Ellie was extremely happy for most of the time she dated Joe. She was always very excited to spend time with him, and especially to take vacations with him. She would rave about how great it was to spend time with Joe on vacation, and during the relationship often reflected back positively on the trip to Rome where she lost her virginity. She also frequently talked about how she thought he was a “good” and moral person.

At first, I objected to Ellie and Joe dating because I felt he was too old for her. I talked to Ellie’s mother, Anne, about those concerns. Anne told me that my concerns were unfounded and that Joe offered the type of “stability” Ellie needed. Anne and Ellie frequently talked about the financial benefits of Ellie’s relationship with Joe.

During 2012-2013, Ellie started spending almost all of her free time with Joe and I saw her less frequently. When I did see her, she would still always talk about how wonderful things were when she spent time with Joe and would regularly say that she was deeply in love with him. She had actively helped shop for a new house for Joe with the clear goal of moving in with him. She also frequently spoke about her goals of marrying Joe and having children with him.

Ellie told me that Joe broke up with her during Christmas break of2012. I wasn’t surprised this had happened because Ellie was very capricious and could be a difficult girlfriend. I had also assumed that Joe would tire of Anne’s involvement with the relationship. At that time, I tried to encourage Ellie to move on, but neither she nor her mother wanted that. Anne was particularly insistent that Joe and Ellie should get back together. Joe and Ellie did start dating again off and on for a couple of months after that. I told Anne that I thought this situation was unhealthy, but Anne said Ellie could make her own decisions.

After the initial break-up in December, Ellie started to act in a very “bipolar” way about the relationship, alternating between bouts of frustration with the relationship (she did not feel that Joe made her enough of a priority in his life) and euphoria about it. After she would become upset with him, she he would frequently offer him ways to could “appease” her, which often involved something he could do to further her career.

I was there the night Joe and Ellie finally broke up permanently in February of 2013. I spent the night in a wine bar with Anne while Joe and Ellie met elsewhere. At the end of the night, Joe drove up with Ellie in the car and parked outside the restaurant where we could see them. They talked in the car in front of the wine bar for some time and then Ellie came inside the wine bar. Ellie seemed happy. I didn’t see anything abnormal about their interaction in the car, nor did Ellie seem upset in any way. Ellie told us everything about her conversation with Joe. She never said he was violent or in any way physically or verbally aggressive.

In fact, at no time during their relationship did Ellie ever say that Joe had been verbally or physically aggressive to her or had tried to make her have non-consensual sex. I was very close with Ellie’s mother. If I sensed, even remotely, that the relationship was in any way abusive, I would have talked to Ellie’s mom about it and tried to help Ellie get out of the relationship.

During their relationship, Ellie often spoke about their sex life positively, even immediately after her therapy sessions. She told me she did feel guilty about the fact that she was having pre-marital sex, which was inconsistent with her Catholic beliefs. She said she wasn’t sure if it was morally right to have sex and she was very jealous of other women in Joe’s life and questioned whether Joe was monogamous. To my knowledge, she never actually discovered any evidence that Joe was not monogamous with her.

After their relationship ended, Ellie often said that she regretted having sex with Joe, but also sometimes still talked about sex positively, saying that it can be “stress relief’ and “addicting”.

She often said she did not want to have sex again until marriage after her relationship with Joe. I believe she was very guilty about violating her Catholic beliefs and having pre-marital sex. I believe that she is coping with her choice to have sex by claiming that Joe raped her so that she can avoid culpability for her decisions.

Over time, Ellie’s story about what happened with Joe seemed to keep changing. The claims of “emotional” abuse gradually morphed into allegations of “rape” and “criminal” activity. At first, she commented that her sex life with Joe was “kinky”. She kept embellishing her claims until she was saying that it was actually “rape”.

Ellie appeared to lack any interest in actually settling with Joe and would frequently say that she wanted to punish him. On December 11, 2013, she sent me text messages about the mediation:

  • In a lobby with 4 lawyers and parents!
  • Totally joe take down scheme!

Ellie’s story about her relationship with Joe kept getting more and more extreme as time went on. In March 2014, she texted me that she considered herself a “sex slave” during her relationship with Joe. This is far, far beyond anything that she ever said about the relationship when it was happening or for a long time afterwards. It also made no sense in light of her clear enthusiasm about the relationship, her constantly going to Joe’s house (often times canceling plans with me to be with him), traveling the world with him, and thinking so highly of him during their relationship.

In March 2014, Anne contacted me and said Stanford was re-opening the investigation… She asked me…to talk to the Stanford investigators and tell them that I noticed a “marked change” in Ellie when she was dating Joe and that she became “sad”. That would not have been true… It was only at the end when they were breaking up that she acted sad about their relationship. Her descriptions of Joe as “abusive” and a “rapist” only came after spending what seemed like hundreds of hours with therapists after leaving school and breaking up with Joe.

I did not want to help them with their investigation because I felt things had gone way too far. I did not and do not believe Ellie’s claim that Joe raped her or was in any way abusive. I believe that Ellie felt guilty about having sex afterwards and regrets it because she and Joe did not eventually get married. I do not believe, based on Ellie’s excitement and happiness when discussing their relationship – including the first time they were intimate – that Ellie was in any way forced to have sex.

Although we spent some time together during Ellie’s relationship with Joe, Joe and I were never friends. I was actually very apprehensive of Joe during their relationship because I believed Ellie was using Joe for his status and money and for help with her career and I didn’t think that led to a healthy relationship. Nonetheless, it is my firm belief that Joe Lonsdale did not rape or otherwise sexually abuse Ellie Clougherty.

It is my opinion that Ellie is a confused and unstable person and she is greatly influenced by her mother. It seemed like Anne spent more time at Stanford than Ellie and that she has been the driving force behind Ellie’s accusations against Joe to Stanford. I don’t believe that Ellie can be trusted to tell the truth about what happened in her relationship with Joe Lonsdale.

I feel bad about testifying that my long-time friend is not being truthful. But I don’t think that Joe should be accused of something he did not do to help her cope with her guilt about having sex with him or to punish him for ending the relationship. I think both sides of the story deserve to be told.

I declare under penalty of perjury under the laws of California and the United States of America that the foregoing is true and correct. Executed this 29th day of October, 2014, at San Francisco, California.


The Take-Away

In a sort of post-modern Greek Tragedy that engaged in an unfortunate coupling with Theater of the Absurd, both protagonists become their own antagonists such that the Fates will likely deal with each of them harshly (though the filthy rich generally rise exultant over the merely very rich in the end).

It would seem that the emotionally-fragile Ellie and the self-assured Joe are both victims in this escapade – not of each other but of Anne Clougherty, Ellie’s controlling and gold-digging mother, who not only accompanied the child model on every professional gig and managed (pushed?) her modeling career and almost certainly engineered Ellie’s pathological perfectionism and consequent self-loathing, but inserted herself into most of the significant decisions in the Ellie-Joe relationship, such as shopping fortheir new (marital?) home and cajoling Joe to reopen the tryst after the Christmas breakup, and then leading the charge to the Title IX tribunal and the negotiating table and courtroom for a generous monetary settlement (one can only wonder whether their refusal to sign a non-disclosure agreement was due to a tell-all book and movie prospect).

While I feel sympathy for the obviously troubled Ellie, who seems to have been a pawn of her domineering mother, and also feel some sympathy for the jet-set man who might be taken down a notch by his first truly bad career decision (falling for Ellie) – if anyone should be indicted for questionable motives it would be Anne Clougherty for a lifetime of manipulation of her daughter’s choices and seeking her own pecuniary gain through Ellie’s connections. Joe Lonsdale, if he is guilty of anything in this tale, it’s not for crossing professional boundaries (he was involved with Ellie long before their mentor relationship), but for making a good chunk of his fortune by aiding and abetting the NSA and CIA to better vacuum data from Americans (this from an ostensible libertarian). It’s perhaps some form of instant karma that Joe’s private life has now been vacuumed up by the media for public consumption.

But what the sordid tale offers to the rest of us is a peep-hole glimpse onto the stage where lust, love, and opportunism get mixed up with a radical social and political agenda which seeks to control bedroom behavior, and angelize the women and demonize the men who explore the boundaries of acceptable sexual liaisons.



On November 2, 2015, Clougherty’s and Lonsdale’s respective lawsuits were settled on terms they agreed not to disclose. The same day, Stanford University reversed its 2013 finding of sexual misconduct and harassment against Lonsdale, lifting the 10-year campus ban it had imposed on him. Lonsdale agreed not to challenge the separate determination that he broke the rule against consensual relationships between mentors and students.

Marcia Pope, the lawyer Stanford brought in as an outside investigator for the Title IX hearing, and who made the finding of sexual misconduct and harassment against Lonsdale (engaged in conduct meeting the definitions of sexual harassment and sexual misconduct under Stanford’s Title IX policy, and that it was more likely than not that Ms. Clougherty expressed to Mr. Lonsdale that she did not want to engage in the sexual conduct in question but that Mr. Lonsdale did not comply with her request) reversed herself after reading the emails from Clougherty to Lonsdale, which he had tried – but was not allowed – to present in his defense.

“As a result of new evidence that came to light during litigation between Mr. Lonsdale and Ms. Clougherty,” university spokeswoman Lisa Lapin wrote in an email, “the investigator in a Stanford University Title IX matter involving both parties has determined that Mr. Lonsdale did not violate Stanford’s Title IX policy.” (Sexual-Assault Case against Joe Lonsdale Dropped)

Those emails were disclosed in a Feb. 11, 2015 New York Times article, The Stanford Undergraduate and the Mentor, by Emily Bazelon (who subsequently published a followup article, The Lessons of Stanford’s Sex-Assault-Case Reversal on November 4, 2015, and more completely in Lonsdale’s lawsuit documents.


by Robert Riversong: may be reproduced only with attribution for non-commercial purposes and a link to this page.

See also:

When Progressive Social Change Becomes Regressive Ideology: From Women’s Liberation to Cultural Misandry – ReHonoring Masculinity & Achieving Gender Justice

Misandric Feminism vs. Progressive Gender Equality (excerpt of above)

Male Victims of Sexual Violence (also an excerpt of the first essay)

Yellow Journalism and the Meme of “Rape Culture” – Rolling Stone and U-VA Gang Rape

Dear President Sullivan – letter from 17 attorneys involved with campus sexual assault claims throughout America, detailing specific reasons why they “are concerned that the University’s Proposed Student Sexual Misconduct Policy is both vastly over inclusive in attempting to define prohibited conduct and ill equipped to guarantee a procedure for resolving allegations that is fair and impartial”.

It’s Time for a U-VA Apology – Op-Ed from a 25-year U-VA professor and his U-VA junior son

Journalistic Fabulism and Ideological Agendas – the Sabrina Rubin Erdely Story

New Puritanism – New Paternalism – The “Rape Culture” Narrative Demeans Women, Demonizes Men, and Turns Universities into Witch Hunt Tribunals

Dear Senators – letter from 20 attorneys critical of the Campus Accountability and Safety Act (S. 2692)

Sexual Assault and Justice: Can we reconcile the belated attention to rape on campus with due process? by Nancy Gertner, feminist lawyer, retired federal judge and Harvard Law professor

The Pendulum Reverses – Again – The Betrayal of Liberty on America’s Campuses & Men Strike Back against Title IX Tribunals

HELP for DOE Regulatory Excess – A Senate Task Force Report Recommends Scaling Back the Mountain of Regulations Strangling Higher Education Institutions

Men are Twice-Raped – Domestically and Globally, Men and Boys are Victims of Sexual Violence at rates Equal to those of Women, and are Assumed to be Villains whenever a Woman Accuses

Two Sexual Assault Studies Contradict Stereotypes

All Sex is Rape – All Men are Rapists : Patriarchy = Rape Culture

A Model of Campus Gender-Based Harassment – The Columbia University “Mattress” Story

A Case Study in “Politically-Correct” Reactionary Response – The Duke Lacrosse Team Stripper Rape Hoax

When the Megaphone becomes the Gavel – Two legal experts on sex discrimination law and procedure argue that the current Title IX mandates for America’s colleges and universities are legally unsupportable and both practically and ethically indefensible.

Insurance Industry Revelations and Prescriptions about Campus Sexual Assault

The Feminist Movement has Cannibalized Its Own Core Values and Become Its Own Worst Enemy

The Rape Culture Meme – It’s to authentic human culture what genetically modified corn is to maize.


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