Article two asks whether I "delivered a copy of  ***'s November 6, 1998 complaint to" various media. The qualified answer is yes, I delivered a redacted copy of a letter of complaint, the name of the alleged author and the section of the English class having been removed to secure the complaining person' s identity. Since that identity remains unknown, no privacy rights that I am aware of have been, or could be, violated.
 
     3.      Article three inquires as to whether I "will comply with the College's policy against the use of profane, obscene, or vulgar language in the classroom, which is not germane to course content." In the first place, all the language I use in the classroom is germane to course content because everything I say is relevant to the literature I teach, whether I am explicating the text in the analytical mode, or recreating the text by dramatically representing the characters or by emoting the themes identified therein. (Even the complaint letter asseverates: "these comments stemmed from the English stories we were reading for class.") Secondly, since I also teach language itself--the histories of words, their derivations, denotations, and connotations--any English terms are subject to scrutiny, including vernacular formulations.  Finally, I devote class time responding to queries from students, some of which pertain to etymologies or usage of words. Therefore, I am unaware of having deviated from any "germaneness" stipulation of the College's speech policy. Since the College allegedly installed its policy to prevent the generation of so-called "hostile environments," I further affirm and attest that I create no such environments. One complaint out of 300 students in all of 1998 clearly demonstrates the accuracy of my claim. As College counsel wrote in 1992: "There is simply no way to 'shield' the sensitive student from life and reality in the classroom."

4.     The first "finding" of the College, which serves as the basis for its suspension of me, is a direct quote from a student named Brian Tyler who appeared before an "investigatory" panel on December 18, 1998. Mr. Tyler, who came forth as a friendly (to me) witness, was referring to my advice to my students on the first day of class that I deal with "adult" themes found in literature and that I employ the full range of the English language, language that could  contain "adult" expressions which some people might find offensive. I never make it a practice "to swear in the classroom," though the words cited might well occur as quoted  material, as items in themselves fit for further linguistic/etymological analysis, or as terms I might utilize in the process of explicating the text, or of dramatically representing a character or emoting a theme found therein.

5.      The second article pertains to a classroom discussion of cognates to a Greek word for love: philia. After discussing the sense of such words as philosophy,  Philadelphia, and pedophilia, the discussion, at the instance of a student, dealt with necrophilia. The expatiation included, as such devolutions often will, a historical  illustration. I cited the case some fifteen years ago where an Indian village (a posh neighborhood in Detroit) gardener murdered his girlfriend, buried her body on the estate grounds, then dug it up two weeks later and had sex with it--because he was certain "she" must have gotten lonely. After a few students gasped or groaned, I attempted to lighten things up a bit by sharing a Sam Kinison skit about a corpse having pleasant thoughts over having fought the good fight, having earned his not so unpleasant rest, only to then be subjected to anal rape by the mortician  Following Mr. Kinison's own typical diction, I utilized the construction "butt fucking," not imagining that anyone in the class would construe such an utterance as an essay to dehumanize or degrade him or her, it not having been specifically directed to an individual or minority grouping. My impression was that the majority of the students appreciated such a moment of comic relief," as indeed the four who appeared at the hearing on December 18 so testified. And comedic elements, it has always seemed to me, are highly valuable increments to the pedagogic presentation. Students who laugh, who find mirth as well as pathos admixed with information, become more involved, more committed, learners.

6. The third article charges me with having included  the term "blow job" while discussing President Clinton's relationship with Monica Lewinsky. This topic was broached by a student who observed that, at the back of the classroom (F204--normally reserved for foreign language instruction), a framed cartoon of some French politician with his pants down and phallus exposed is prominently displayed. Apparently, this student said, Americans are not the only ones with compromised leadership. To the best of my recollection, the tenor of this class's mood ranged from the sarcastic/ironic to one of feigned (?) boredom, the nation then being in the ninth month of that bizarre ordeal. Again, employment of "blow job," with its conflation of the seamy and buffoonish, seemed precisely resonant with the French cartoon and an American Presidency under ribald scrutiny. To have insisted on the Latin term "fellatio" would have tended toward the inapropos, if not the absurd--particularly in a room filled with adults whose average age is twenty-six.

 
     7.      The fourth article charges that I "remarked two or three times that 'tits on a nun are as useful as balls on a priest.''' Actually, I said an approximation of this only once, to wit: "The not unusual simile heard among many Roman Catholics: 'as useless as tits on a nun,' is not counterbalanced by an equivalent simile with regard to men of the cloth, such 'as useless as balls on a priest, ' because of the prevalent (chauvinist) notion that women are to be evaluated only on the basis of their sexual attractiveness or reproductive function." I made this observation with reference to Joyce Carol Oates' erotically and romantically thwarted nun in the story "In the Region of Ice."  The specific passage that triggers this analysis flows thus: "This city was not her city; this world was not her world. She felt no pride in knowing this, it was a fact. The little convent was not like an island in the center of this noisy world, but rather a kind of hole or crevice the world did not bother with, something of no interest." "Hole or crevice, of course, constitutes yonic imagery, and author Oates conjures it to remind the reader of Sister Irene1s conflicted sense of her value as a woman as well as her value as a human being. I went on to point out that, in fact, one might occasionally hear a Roman Catholic exclaim about a priest:
"All man and all priest!" A man does not forfeit his social estimation merely because he eschews sexuality. The irony in all this is that the student who complained against me stopped
listening to what I was saying. The image "useless as tits on a nun," which I neither invented nor endorsed, stimulated a squeamishness in her that cancelled the rest of the lesson, a lesson altogether opposed to the dehumanization of womankind.
 
8.     As for the concluding paragraph of the "Disciplinary Suspension" memorandum, I must reiterate that all of my in-class utterances are "germane to course content as measured by professional standards," and that none of the language I utilize is calculated to insult, to embarrass, to patronize, or to harass any student. In fact, where the literature warrants such treatment, my inclusion of the vernacular in any emotive evocations of theme or character fosters an environment where a typical student can feel safe to discover and discuss the richness that great literature affords as well as the self-discovery that art induces.
 
9.     That attorney Mark Cousens, the attorney for the union has indicated he does not represent my interest and that he only represents the union's interest. He has also accused me of creating a hostile environment in my classroom. Furthermore, he and the union refused to process my grievances or support my rights under the collective bargaining agreement.

 
10.      I firmly believe that the cause of my current problem with Macomb Community College are the contortive efforts of both the institution and Attorney Mark Cousens to destroy my teaching career.
 
11.      I believe my right to free speech and association continues to be violated and I am concerned that I will be damaged irreparably if the current disciplinary process continues as scheduled for March 11, 1999, without the Court intervening to maintain status quo pending resolution of these issues in a fair setting.
 

12. If the defendants are not temporarily restrained in this matter I will be irreparably harmed in the following further particulars:
 
          A.      My removal from all teaching duties causes a breakdown of my professional relationship with my students on a daily basis.
          B.      The insistence of defendant Cousens to represent me, against my will, materially hampers my right to adequately defend myself in the administrative process.
          C.       The "gag order" continuously interferes with my right to free speech and my ability to freely disseminate my defense in any public forum.
          D.       The prohibition of my right to meet with students or be present on college property prevents me from pursuing my defense.
          E         The continuation of the indefinite suspension hinders my career, simply because a professor who cannot teach has no professional function.
F. All of the actions of the defendants, from which I ask immediate relief, amount to a stigma, escalating with time, which brand me in public and in the media as a purveyor of smut to students of the college.
 
FURTHER DEPONENT SAYETH NOT.
 
(signed)
PROFESSOR JOHN C. BONNELL
Subscribed and sworn to before
me this 10th day of March, 1999