EXHIBIT A

Max Price Personal Statement and Attached Exhibits

My name is Max Price and I am a Junior at Tufts University. I am a student, a musician, a writer,
and an aspiring policymaker. However, some parts of my identity are inalienable and
nonnegotiable: I am a proud Jew and an outspoken defender of the right of all peoples to self-
determination, as well as the Jewish right to live peacefully without fear of discrimination and
prejudice. I committed to attending Tufts in 2018, proud to take my place at an elite institution of
learning, most notable for its capacity for spirited and free debate on the great issues of our time.
However, I was disappointed to find that my Jewish identity made me unfit to participate in this
debate, at least in the eyes of some students and administrators. This is despite serving as a
community leader, President of Tufts Friends of Israel, an elected member of the student Judiciary,
and a tireless voice against anti-Semitism and bigotry in all of its forms. For these unforgiveable
crimes I have been targeted and marginalized, called a racist, a fascist, a Nazi, an enemy of
progress. I have been slandered in the student newspaper and most recently, threatened with
impeachment and removal from the student government. My innumerable complaints and
warnings to the administration were unheeded and most often ignored, despite 30+ documented
incidents of anti-Semitism over the last three years, including the posting of a swastika on the door
of a Jewish student. The anti-Semitism that Jewish students face at Tufts is not always so
immediately recognizable. It does not emanate from a secret cabal of white supremacists, nor an
alt-right student collective. Rather, it camouflages itself to assume the form of progressive
activism.

The specter of anti-Semitism, often under the guise of anti-Zionism, has haunted my Tufts
experience from the beginning. I arrived in the wake of the passage of the Boycott, Divest, and
Sanctions resolution and amidst the formation of a new blood libel: the Deadly Exchange. This
conspiracy theory posits that the Israeli government, along with its Jewish American proponents,
are responsible for institutional racism and police brutality in the United States. When asked in
March 2020 by journalists for my personal opinion on this matter in my capacity as the President
of Tufts’ only Zionist student organization, I told the truth:

“It distracts from the real issues in our country and on our campus. The campaign rests on
mistruths—the trip did not include training and was not with a military force—and ignores
the fact that the seminar included Palestinian police, as well as Israeli police...the campaign
maligns Israel by linking it to longstanding issues of systemic racism and police brutality
in the United States, when in reality Israel is not accountable for the actions of TUPD or
any American police in the past or future.”

I was elected to the TCUJ in Spring 2020. Throughout the Deadly Exchange referendum process
this Fall, I took on the constitutional responsibility ascribed to me: eliminating biased, misleading,
or otherwise untruthful language from the proposed referendum text. As a member of the Judiciary,
I insisted upon honesty, balance, and transparency of intent throughout the referendum process.
From the beginning of the process, I was completely straightforward about my personal beliefs on
the subject and vowed to the other TCUJ members that I would not allow those beliefs to bias my
decision making.

The initial referendum language provided by SJP contained several demonstrably untrue premises.
First, the law enforcement exchange programs are not military-led trips. They do not feature
military training or any formal meetings with active military officials in Israel. This can be verified
by reading the trip itinerary that SJP provides. All past participants in these events, which feature
both Palestinian and Israeli civil police officials, describe it as an educational seminar (as does the
event’s host, the Anti-Defamation League, which has fought bigotry for over a century). Second,
SJP’s proposed referendum language asked Tufts University to apologize for “sending” the former
TUPD chief to this seminar and demanded that the university never do so again. However, the
ADL sponsored the trip and invited the officer, and Tufts said publicly that they have no future
plans to participate. Finally, the third clause of the referendum called for discrimination against a
protected class, insisting that TUPD amend its hiring practices to exclude military veterans or
others who have received military training.

When I pointed out these fact-based concerns with the proposed referendum language, the other
members of the TCUJ agreed with me. TCUJ then attempted to negotiate in good faith with SJP
to reach the shared goal of generating a fair, unbiased referendum that would challenge police
militarization on Tufts’ campus. On at least two occasions, the TCUJ sent specific proposed
revisions to SJP in order to address the inaccuracies in their proposed text. SJP rejected the
revisions (Exhibits 1-4).

I was shocked when fellow members of the student government asked me to recuse myself from
constitutionally required deliberations on the language. In several emails, SJP members called me
inherently “biased” and demanded that I be muted or barred from attending digital Judiciary
meetings (Exhibits 5-11). I was told that I had an unavoidable conflict of interest by members of
the Senate Executive board and student leaders in the Committee on Student Life and pressured,
without regard to constitutional process, to dismiss myself from the proceedings. I refused. My
Jewish identity is not an “conflict of interest.” The only conflict I have is with misinformation,
manipulation, bullying, and the scourge of anti-Semitism.

Student members of SJP have repeatedly and persistently harassed me in an attempt to silence my
voice. First, they tried to force me to recuse myself and put pressure on the TCUJ and the leadership
of TCU Senate and CSL to mandate my recusal. That did not work, so now SJP has filed a
complaint seeking my impeachment and removal from student government. They are targeting me
based on protected characteristics, my Judaism and my Zionism which is inherent in my expression
of Judaism. They have made eminently clear their perspective that no person with my beliefs can
be allowed to participate in student government. That is why they are attempting to strip me of my
rights as a Tufts student and as an American.
On November 15, in response to emails from SJP members, the TCUJ held an emergency meeting
to determine whether I should have to recuse myself from the TCUJ discussions of the referendum
language. At this meeting, my quotes from the March and April 2020 articles SJP had cited were
read out loud and the TCUJ members were asked to consider whether these statements rendered
me biased. In addition to considering my past statements, the TCUJ members discussed my
conduct and the contributions that I had made during the referendum review process. In the end,
all five members of the TCUJ agreed that my identity and perspective had not biased the
referendum proceedings in any way. They agreed that I had provided valuable and necessary
insight throughout, that my comments had been fact-based, and that my background knowledge of
the issue at hand was of a net benefit. The TCUJ voted unanimously to recommend that I did not
need to recuse myself. The other members of the TCUJ, with myself abstaining, also voted to send
an email to SJP that (i) disputed the claims that the critiques of the referendum had been anything
but fact-based, (ii) explained I had exhibited no bias throughout the process, and (iii) discussed the
TCUJ’s role in the referendum review process (Exhibit 4).

After the TCUJ members agreed that I did not have to recuse myself, SJP (refusing to accept that
as an elected member of the TCUJ, I had a right and responsibility to participate in the process in
full) submitted a second complaint to CSL and TCU Senate leadership (Exhibit 12). In response,
the TCU Senate President set up a meeting for the next day, November 16, to discuss the
allegations. I was led to believe that the purpose of the meeting was to decide conclusively whether
the SJP allegations had any merit and whether any further action would be initiated against me.
Present at the meeting were myself, TCU Senate President , TCU Vice President
, TCU Treasurer , TCU Parliamentarian , TCU
Diversity Officer , TCUJ Chair , TCUJ Vice Chair ,
CSL co-chair , CSL member , and Director of Campus Life
, an administrator.

In my opening statement, I explained that Zionism is a crucial part of my Jewish identity, due to
the shared Jewish history and heritage that is implicit in Zionism, but that identity has never
impaired my ability to serve on TCUJ. In fact, I noted that my experience with the Israeli-
Palestinian conflict had enhanced my capacity to evaluate the referendum question. Additionally,
I shared my perspective that I personally see police demilitarization and criminal justice reform as
key priorities. The other student government leaders grilled me for over an hour about whether my
personal beliefs and Jewish and Zionist identities impact my ability to serve on the TCUJ on this
issue. I was explicitly asked if being co-president of Tufts Friends of Israel—the sole Zionist
student club on campus—rendered me too biased to participate in this process. The undercurrent
of nearly every question was whether my Zionist beliefs, which are a central expression of my
Jewish identity, disqualified me from serving on student government.
At no point were any of my substantive statements or actions during the TCUJ review process
cited or specifically called into question. , the TCUJ Chair, spoke in my defense,
asserting the official TCUJ position that I had not shown any bias throughout the process. At the
conclusion of the meeting, all present participants agreed that there was no need for me to recuse
myself, and no further steps were taken by TCU Senate, CSL, TCUJ, TCU Elections Committee
(ECOM), Office for Campus Life (OCL), or any other body on this subject.

SJP, however, would not give up. They continued to pressure to force me to
recuse myself (Exhibits 13,14). The final meeting of the TCUJ to discuss and vote on the wording
of the referendum was scheduled to take place on November 18, 2020 at 7:00 PM. Shortly before
this meeting was scheduled to start, I was informed by (via a group text to the
TCUJ members) that I would have to remain on mute during the entire meeting (which was being
held via Zoom) (Exhibit 15). We were also informed that SJP members would be joining the
meeting and would be bringing a guest speaker, Eran Efrati, to educate the TCUJ members on the
Deadly Exchange campaign. SJP presented Mr. Efrati as an “expert.” However, Mr. Efrati is
known to have expressed anti-Semitic sentiments including comparing the Israeli government to
the Nazis. That Mr. Efrati, who was central to the generation of the Deadly Exchange conspiracy
theory, was considered an academic source while I was considered too biased to participate
demonstrates the cognitive dissonance present in SJP’s complaint.

When I joined the TCUJ Zoom meeting at approximately 7:00 PM, immediately
announced that I would have to mute myself once SJP joined the session. Though I had the
technical capability to unmute myself, warned that he was running the meeting
and would re-mute me if I attempted to speak. I challenged this decision as unjust and unwarranted,
especially in light of the TCUJ’s conclusion only days earlier that I had been an unbiased and
valuable member of the committee. responded that the only way he was able to
get SJP to agree to attend the meeting in order to reach an agreement on final referendum language
was if I was silenced.

When I expressed concern about the bias of both the referendum’s language and SJP’s outside
expert and noted that as a member of the TCUJ I have a right to speak, insisted
that I would have to remain muted during the meeting, but he suggested that I track down a third-
party proxy to present my position. I had 15 minutes before the SJP members and Mr. Efrati were
scheduled to join the call. I scrambled during the next few minutes to find a speaker who would
be able to respond to what I feared would be misleading statements made by Mr. Efrati. I was able
to find a pro-Israel activist on Twitter, Mr. Joshua Washington of the Institute for Black Solidarity
with Israel. Mr. Washington, despite not knowing me and having no preparation time to talk to me
about the issue, agreed to join the Zoom meeting to respond to any biased statements of SJP and
Mr. Efrati. During the meeting, Mr. Efrati was permitted to speak without interruption. However,
as soon as Mr. Washington began speaking, he was repeatedly interrupted by the members of SJP
ewho demanded that he be prohibited from participating. This demand was made despite SJP
inviting their own, deeply biased speaker to the meeting. Ultimately, Mr. Washington was barely
able to speak for a full minute for the entirety of the meeting.

I attempted to provide some perspective to SJP’s heavily biased presentation by texting fact-checks
to the other TCUJ members in our group chat. Another member asked me to better explain my
positions after SJP and Mr. Washington left the Zoom meeting, before the vote. Unfortunately, I
never had that opportunity because suddenly and unexpectedly called for the vote
at 7:58 PM, demanding that the TCUJ members vote via Facebook messenger and conclude the
process. In a highly unusual if not unprecedented move, SJP—the sponsor of the referendum—
was allowed to stay on the call and observe the voting (Exhibit 16). The referendum language that
passed with a vote of two ayes, 1 nay, and 2 abstentions was:

Do you support Tufts University administration 1) apologizing for sending the

By silencing me, SJP and the TCUJ Chair robbed me of my rights under the TCU Constitution.
The TCU Bill of Rights expressly provides that “[a]ll members of the TCU shall be entitled to . . .
[a]ctively participate in the TCU government by voting on campus-wide issues, . . . [and]
participating during meetings of the government or Senate . . . .” Nowhere in the TCU Constitution
is it suggested that a member of TCUJ is empowered to silence a specific member of the TCUJ
during a meeting for a vote on an issue. The responsibilities of the Chair of the TCUJ are clearly
enumerated; none can be construed as empowering the Chair to take such action as SJP demanded
or as Mr. Dahlerbruch took on November 18.

With respect to SJP’s claims that I was somehow in collusion with Mr. Washington’s actions
(recording the TCUJ meeting and posting it online), there is documented proof that I was furious
with Mr. Washington and messaged him demanding that he take down the video immediately
(Exhibits 18-20). As for the allegation that Mr. Washington’s attendance was not allowed under
Tufts guidelines, there is no formal process for which I am aware. I was following the instructions
of the TCUJ Chair, and Mr. Washington’s attendance to the TCUJ meeting was of the same form
as Mr. Efrati’s.
During the course of the Deadly Exchange referendum campaign, SJP ran roughshod over the
Tufts Constitution in more ways than just silencing me during the TCUJ meeting. SJP students
violated several clauses of the TCU Constitution, the Judiciary Bylaws, and the Elections
Commission (ECOM) Bylaws in their haste to get the Deadly Exchange language on the ballot.
They violated the order for referendum proceedings set out in the Constitution. SJP began
collecting petition signatures before it had received approval of its proposed language. The
Constitution requires the Judiciary to first approve referendum language as unbiased and factually
accurate. Then the Committee on Student Life must rule on the referendum language’s legality
and compliance with University guidelines. SJP began collecting petition signatures before the
Judiciary Committee and the Committee on Student Life had completed their review. By asking
the student body to sign on to referendum language that had not yet been vetted and approved, SJP
increased the pressure on the TCUJ and CSL to accept the problematic language it had submitted.
In addition, despite having no constitutional role in the process, the TCU Senate repeatedly
pressured the Judiciary to rush through the referendum without due process, threatening to recall
elected representatives. The TCU President even showed up unannounced to a Judiciary meeting,
violating separation of powers, to express her hope that the referendum language would pass
through quickly. The Election Commission failed to inform the Judiciary of plans to rapidly hold
an election, which put unexpected pressure on the Judiciary to quickly approve a biased
referendum text. ECOM also failed to hold a constitutionally-required public forum on the
referendum two days before the vote. These are just a few of the rules that were broken.

Astonishingly, after SJP succeeded in silencing me, getting its language on the ballot, and passing
the referendum initiative, SJP was still not done harassing me. The TCUJ, and the leadership of
the TCU Senate and CSL all agreed that I had conducted myself appropriately and without bias
throughout the process and that my contributions to the TCUJ review had been helpful. Despite
this, SJP filed a formal complaint with the TCU Senate seeking to have me removed from my
position on the TCUJ. Although the complaint claims to be against all members of the TCUJ, I am
the only member of the TCUJ who is singled out by name, and I am the only one targeted for
impeachment.

SJP appears determined to remove me from the TCUJ in advance of the Boycott, Divestment and
Sanctions campaign they have announced they intend to launch this Spring. They wish to cleanse
the TCUJ of individuals who support Israel, particularly students like me, for whom belief in a
Jewish homeland is integral to my identity as a Jew. To the members of SJP who filed this
complaint, I am not a legitimate member of the student government. I am simply an obstacle to
their agenda due to inherent facets of my identity. This is an intolerable attack on my First
Amendment rights.

SJP and the TCU Senate have also denied me due process rights as set out in the Tufts Student
Conduct Resolution Procedure (SCRP). According to the SCRP, complaints like the one that SJP
 Option 2: Start with CSL. If you take the referendum to CSL first you can then bring it to the J to work on wording. This is
the preferred process for the TCU Constitution and may speed up the CSL process which can make a Wednesday
meeting more convenient in the coming weeks.

Either way, feel free to send updated wording. While meetings in person should include the whole Judiciary, we can try to
start working through the process virtually to speed everything up.

Thank you,

TCU Judiciary

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 1. We removed the mention of the Israeli Defense Force as that component was not a part of the itinerary for the year
that the TUPD officer in question was in attendance. We do not believe this inclusion was factually accurate and
therefore we believe it is unfair. Additionally, the Israeli military is officially named “Israel Defense Forces”.
2. We replaced the description of the seminar with one that is more accurate and fairly portrays the content of the
seminar as per the ADL website. The wording provided was based on a description of a significantly different
seminar and it was therefore unfair.
3. We removed the phrase military-led once again with the belief of it being unfair. Upon further review of the sources
provided, we do not believe that the seminar itself was military-led but we do believe it was a law enforcement
seminar. Based on the itineraries provided, calling it military-led is unfair.

Despite our recommended changes, we do believe that our suggested wording is a fair approach and description of what
occurred. This still gets your point and intention across to allow for people to vote for the same thing but in a more fair
manner.

In the case that you submit a revised and more accurate wording, we can vote. Additionally, we plan on voting within 48
hours of an additional submission due to the time constraints of the upcoming election.

Thank you for your consideration,

TCU Judiciary

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