Content warning: This story addresses allegations of sexual abuse and may be difficult to read and emotionally upsetting.

A fourth woman has filed suit against Butler University for alleged sexual misconduct by an athletic trainer while she played on the school’s women’s soccer team. She joins three other women’s soccer players who said they were sexually assaulted by the trainer and filed suit against the school last month.

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The woman, identified in the complaint as Jane Doe 4, said that Michael Howell, an athletic trainer with the university from 2012 to 2022, sexually assaulted her during treatments, including rubbing his erect penis on her hand, touching her breasts, labia and groin and pressing his groin against her buttocks.

According to the complaint, Howell’s sexual misconduct began when Jane Doe 4 was a sophomore in 2019 and continued until her senior year. Jane Doe 4 became so uncomfortable with the treatments that she would wear two sports bras and/or underwear beneath her spandex “to feel more protected.” Howell would massage her groin even though she did not have a groin injury and she noted his breathing became heavier when he’d massage that area. She said she felt “afraid, anxious and paralyzed” during these treatments.

Jane Doe 4 also said in her complaint that Howell gave players treatment in his and their personal hotel rooms during a tournament in Rhode Island in the spring of 2021 and that Howell required “some women’s soccer players to take ice baths in his hotel bathroom,” and gave the impression that “this was non-negotiable.”

Three lawsuits were filed against the school in U.S. district court in Indianapolis last month by players who alleged similar conduct by Howell. According to multiple complaints, the players say Howell rubbed his erect penis on them and touched them in their vaginal and breast areas during massages and treatments. All four women are suing the school, athletic director Ralph Reiff and Howell for negligence, battery, assault and intentional infliction of emotional distress.

The lawsuits detail a culture in which Howell was close with one of the team’s coaches, wielded influence over athletes’ treatment and playing time, and exposed players’ intimate body parts during massages so often that athletes coined this routine occurrence “the breeze.”

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An attorney for the four women, Monica Beck of the Fierberg National Law Group, told The Athletic that her clients and student-athletes on Butler’s women’s soccer team reported their abuse claims and “subsequently proved their allegations in an extensive investigation and Title IX hearings.”

According to the initial lawsuit, a months-long Title IX investigation was performed into the allegations. A panel of outside attorneys tasked with presiding over a five-day hearing on the allegations against Howell determined that Jane Doe 1 “was slowly and steadily isolated, stalked and manipulated” in an “unconscionably abusive environment,” and that Howell “sexually assaulted, sexually harassed and stalked Ms. Doe,” and had “sexually assaulted and harassed other young women on the soccer team,” citing a “widespread pattern of inappropriate conduct.”

According to the lawsuits, Butler and Reiff “ignored” NCAA warnings about potential staff-on-student-athlete abuse and the need for policies and training to prevent any such abuse from happening. Additionally, the initial three complaints claim that the university and Reiff breached their duties by “permitting Howell to provide treatment to female athletes … in his private hotel room without staff or a third person present,” failing to protect student-athletes with appropriate protocols and policies, failing to prevent him from approaching female student-athletes after his alleged misconduct was reported and failing to prevent him from “destroying and deleting photographs, videos and others evidence from his university-issued cell phone.”

Butler University said in a statement in response to questions about the initial trio of lawsuits that it “promptly notified law enforcement, removed Howell from campus and suspended him from his job duties, pending further investigation” after it learned of Howell’s alleged misconduct in late September 2021.

“After a thorough investigation and hearing, the trainer was found responsible for violating university policies, and he was then terminated in summer 2022,” the university said. “Butler looks forward to the opportunity to show the high integrity and responsiveness of the coaches and senior personnel. Because the complaints do not name the plaintiffs and they have not waived federal student privacy protections, Butler is limited from further comment outside of the legal process.”

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Of the four lawsuits filed, two of the complainants are current members of the Butler women’s soccer team. Two of the complainants, including Jane Doe 4, are former members of the team. The women are identified as Jane Does to protect their anonymity. Attorneys for Butler University, Reiff and Howell have objected to the use of pseudonyms, according to court documents.

In those documents, attorneys for the co-defendants argue that the pseudonyms have been misused, with the plaintiffs “deploying pseudonymous allegations in the media as character attacks on named individuals.” Those documents also say that plaintiffs were not minors at the time of the alleged sexual assaults and that they have not established that they “have tried to keep their grievances or identities confidential.” Additionally, the documents note that one of the first three plaintiffs is no longer a student-athlete at the school, and that “less drastic means remain available” such as sealing or redacting filings.

Plaintiffs have argued for the right to use pseudonyms because of the sensitive and intimate nature of the allegations and the desire to protect against additional emotional and mental injury.

Attorneys for Butler, Reiff and Howell have not yet responded in court to the allegations contained within the complaints. Requests for extensions to respond were filed earlier this month in response to the first three complaints.

Howell, who was placed on leave in October 2021 (the school said he was terminated in summer 2022), did not respond to requests for comment when The Athletic contacted him in July. He worked with the men’s baseball, men’s and women’s golf, men’s tennis and cheerleading teams while with Butler from 2012 to 2021.

An attorney for Howell said his client “flatly denies the claims in these lawsuits” in response to a request for comment.

“We have no further comment about the claims because we intend to litigate the case in court, not in the media,” the attorney said.

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Rachael Denhollander, the first woman who came forward against former USA Gymnastics and MSU physician Larry Nassar, who sexually abused hundreds of young women, joins Beck and Doug Fierberg as counsel on behalf of the complainants.

(Photo: Education Images / Universal Images Group via Getty Images)