Legal Documents

 

Decisions on Motions for Partial Summary Judgment
Princo (1Mb, pdf)
Fiduciary Duty (1.82Mb, pdf)
Sole Beneficiary (675kb, pdf)
Admitted Missing (730kb, pdf)
Statute of Limitations (1Mb, pdf)
Article 11C (797kb, pdf)

Articles of Incorporation
The Articles of Incorporation of the Robertson Foundation spell out the specific mission of the private charitable Foundation.
Full document (306kb, pdf)
Zip version (245kb, zip)

 

Original Complaint
The original complaint, filed July 17, 2002 charges the University-Designated Trustees of the Robertson Foundation – and through them Princeton University – with ignoring the donors’ intent by failing to honor the Robertson Foundation’s mission, by using Robertson Foundation funds without the Family-Designated Trustees’ consent, and by trying to transfer management of Robertson Foundation investments to the Princeton Investment Co.
Full document (174kb, pdf)
Zip version (160kb, zip)

 

Verified First Amended Complaint

The amended complaint, filed November 12, 2004, charges the University-Designated Trustees of the Robertson Foundation – and through them Princeton University – with wrongfully spending more than $100 million of the Robertson Foundation’s money on programs, projects, salaries and bonuses, buildings, equipment and “overhead” costs that have little or nothing to do with the Robertson Foundation mission, engaging in an elaborate cover-up scheme to hide the improper spending, and misusing other donors’ gifts.

Full document (506kb, pdf)

Zip version (240kb, zip)

 

 

McGuire Report
The McGuire Report, a detailed financial analysis of Princeton University’s misspending of Robertson Foundation funds released in January 2006, doubled the amount of potential misspending to more than $200 million. The report was prepared by plaintiffs’ expert witness Michael McGuire, head of PricewaterhouseCoopers National Education Advisory Service.
Section 1 (310kb, pdf)
Zip version (290kb, zip)
Section 2 (380kb, pdf)
Zip version (360kb, zip)

 

Summary Judgment - Admitted Overcharges
In this motion, Plaintiffs argue that summary judgment should be granted on those overcharges imposed on the Foundation by Princeton which Princeton has admitted and corrected. Plaintiffs also argue that Defendants’ defense that various overcredits and undercharges provided to the Foundation should act as a set off to any overcharges imposed should be barred because Princeton waived any right to reclaim these undercharges.
Plaintiff's Partial Summary Judgment Motion (187kb, pdf)
Zip version (160kb, zip)

Defendants Brief in Opposition of Plaintiff's Partial Summary Judgment Motion (184kb, pdf)
Zip version (174kb, zip)
Plaintiff's Reply Brief in Support of Summary Judgment Motion (197kb, pdf)

Zip version (120kb, zip)

Summary Judgment - Fiduciary Duty
In this motion, Plaintiffs argue that all the defendants, including Princeton University, have a fiduciary duty to the Robertson Foundation to use its assets only to advance its mission; that Princeton’s spending of Foundation assets is not protected by the business judgment rule and that the burden of proving the entire fairness of all transactions challenged by the Plaintiffs is on the Defendants.
    Plaintiff's Partial Summary Judgment Motion - Section 1 (490kb, pdf)
    Zip version (470kb, zip)
    Plaintiff's Partial Summary Judgment Motion - Section 2 (175kb, pdf)
    Zip version (103kb, zip)
Defendants Brief in Oppostion to Plaintiff's Summary Judgment
    Section 1 (489kb, pdf)
    Zip version (420kb, zip)
    Section 2 (120kb, pdf)
    Zip version (110kb, zip)
Plaintiff's Reply Brief in support of Partial Summary Judgment (189kb, pdf)
Zip version (170kb, zip)