Summary: Jane Doe 3 has filed a lawsuit alleging sexual assault and misconduct by Michael Howell, an athletic trainer at Butler University, against her and other members of the women's soccer team. The plaintiff asserts that Howell exploited his position of authority to manipulate, isolate, groom, and sexually assault multiple young women in various locations, including the university's training room, offices, buses, and his private hotel rooms during away games. The lawsuit also implicates Ralph Reiff, Howell's direct supervisor and Butler's Senior Associate Athletic Director for Student-Athlete Health, Performance and Well-Being, for negligence. The plaintiff alleges that Reiff neglected to investigate the circumstances, train the coaches, implement safety policies, or protect the female athletes from Howell's abuse. The plaintiff further alleges that Howell sexually assaulted her during a massage session for her lower back pain on September 11, 2021. She also claims that Howell had been secretly photographing and recording female student-athletes on his university-issued phone. The lawsuit accuses Butler University of alerting Howell to the investigation before contacting law enforcement or seizing his work-issued phone, thereby potentially enabling him to destroy or transfer inappropriate photographs and videos of the athletes. The university is also accused of ignoring warnings from the NCAA about the need for policies to prevent staff-on-athlete sexual abuse and of having no written policies or procedures regarding proper athletic trainer conduct, setting boundaries with athletes, or working with athletes of the opposite sex. The plaintiff seeks to recover damages, compel Butler University to implement safety protocols, assess whether former student-athletes were also abused by Howell, prevent Howell from maintaining licensure, and hold the defendants accountable for their alleged negligence. The case is filed under 28 U.S.C. § 1332(a) as the matter in controversy exceeds $75,000 and is between citizens of different states. The venue is deemed appropriate under 28 U.S.C. § 1391(b) as all defendants reside in the judicial district where the lawsuit is filed.