In a court memorandum on Wednesday defending the University’s emergency suspension of Saifullah Khan, Yale painted a picture of a troubled student who was falling behind on his work and intimidating students and administrators.

According to court documents, Yale College Dean Marvin Chun suspended Khan on Oct. 7 in response to allegations published in the News two days before that Khan had sexually assaulted and acted violently toward Jon Andrews, a former associate of Khan’s who is not affiliated with Yale. In March, Khan had been acquitted of four counts of sexual misconduct stemming from an Oct. 2015 encounter with another Yale College student. Three days after the most recent suspension, Khan filed a suit against Yale and Chun in New Haven Superior Court, requesting that the court allow him to resume classes immediately.

But in yesterday’s court filing, Yale’s lawyers opposed Khan’s order, contending that Khan would be unable to make up all of the coursework he has missed, both before and after his suspension. In the memorandum, Yale also argued that the court should not consider Khan’s request until the University-Wide Committee on Sexual Misconduct concludes its investigation into the 2015 complaint against Khan — which had not yet been adjudicated by the University — and until Khan undergoes a psychiatric examination.

“Given all that Yale knew about the plaintiff’s behavior and state of mind, there is no question that it exercised reasonable educational judgment in deciding to place him on emergency suspension,” Yale’s court filing reads.

Khan has argued that by suspending him, Yale had committed a breach of contract. In its defense, Yale’s lawyers cited the Yale College Undergraduate Regulations, which include a protocol for emergency suspensions. The court response also asserts that the University had a “legitimate concern” for the community’s safety given the restraining order Andrews had obtained against Khan and the ongoing investigation by the District of Columbia’s Metropolitan Police Department into Andrews’ allegations against Khan.

Chun declined to comment. Khan did not respond to request for comment.

“One word: bullshit,” said Khan’s attorney in the suit, Norm Pattis, when the News asked about Yale’s filing.

On Tuesday, the University-Wide Committee on Sexual Misconduct held a hearing regarding the 2015 complaint against Khan and is expected to reach a decision by the end of November, according to court documents.

Yale’s response also cites Khan’s academic performance and poor mental health as justifications for the emergency suspension. According to court documents, Khan was “seriously delinquent on a number of assignments and attended class irregularly” this semester. Four of his five professors reported concerns about Khan’s frequent absences and failure to submit assignments for their classes. The memo also states that Khan will have missed six weeks of the 12-week semester by the time court hearings conclude next week, and “no student could possibly complete six weeks of [Khan’s] five courses, as well as make up the assignments missed before the suspension” in the remaining two and a half weeks of the term.

But beyond his academic impasse, the University also noted its own concern for the wellbeing of members of the Yale community, several of whom reported threats by Khan.

On Oct. 5, Khan reportedly appeared in the Office of the Secretary and Vice President for Student Life, and told Deputy Secretary and Senior Director of Corporation Affairs Martha Schall that he had just come from Yale Health’s Mental Health & Counseling department, and that he had “attempted suicide in the past and was again having suicidal thoughts,” according to court documents. Khan then reportedly told Schall multiple times that the resumed university adjudication process had made him “belligerent,” which Schall perceived as a “veiled threat.” The memorandum states that Schall requested police protection for the office because of Khan’s behavior.

Schall did not respond to request for comment.

Yale’s memo also states that earlier this fall, Britton O’Daly ’20, the editor-in-chief of the News, requested that the Yale Police Department place patrols around the News building after Khan had “burst into the Yale Daily News office” and made “threatening comments” about an impending story about him. Another undergraduate student also filed a report with the New Haven Police Department after Khan “stormed into the Yale Daily News building” and told Yale Daily News staffers that he had mental issues, adding that “‘if something happens to my brother … I will not rest.’”

Yale’s lawyers argued that the emergency suspension was also warranted to protect Khan from himself. On Sept. 12, Khan reportedly told Trumbull Dean Surjit Chandhoke he was distressed about the fact that a News reporter had told him about Andrews’ accusations against him, and this new development was “pushing him over the edge.” Khan also told his dean that suicidal thoughts and feelings of isolation had caused him to miss assignments and classes, prompting Chandhoke to arrange for Khan to see a therapist at Yale Mental Health & Counseling. Two weeks later, Chandhoke concluded after a phone call with Khan that he was “deteriorating emotionally.”

Still, Khan sent an email to administrators on Oct. 5 emphasizing that he had “at no point” considered harming himself nor anyone else.

Khan, a cognitive science major, was enrolled in five courses before his suspension. At the time, Khan had missed deadlines for nine of 11 papers in four of these classes, according to court documents. Professor Joshua Knobe, who teaches “Perspectives on Human Nature,” reported that Khan had partially completed one paper and failed to submit three other papers, which had all been due by Oct. 5. When a teaching fellow for the course saw Khan after a lecture, Khan reportedly told her that he was “going through some difficulties.” As of Wednesday, Khan had missed the first of two major papers, the midterm exam and six of eight discussion sections in the course.

Louisa Lombard, who teaches “Law as Culture,” reported in Yale’s memorandum that Khan had not turned in any of the three papers for her course and had also failed to attend any of the weekly discussion sections prior to his suspension. Khan had also failed to turn in two of three papers in his senior seminar course and one paper in “The Criminal Mind.” Arielle Baskin-Sommers, who teaches “The Criminal Mind,” declined to comment. Khan’s other professors did not respond to request for comment.

Khan’s first court hearing is scheduled for Friday.

Alice Park | alice.park@yale.edu .