Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 1 of 30 EXHIBIT B Working, el al. v. Lake Oswego School District Case No. 3:16-cv-00581-SB Pending in the U.S. District Court for the District of Oregon, Portland Division Settlement Agreement I. Definitions. A. A!!reement Duration. The Agreement Duration is July 17, 2017 until the end of the 2019/2020 school year, unless the Court's jurisdiction over the Plaintiffs' lawsuit is extended as described in sectionVI.I? Jf the Cou1t's j urisdiction is extended past t he 2019/2020 school year, the Agreement Duration will be July 17, 2017 until the Court's j urisdiction ends. ~ q /-zs(rt ../,/¢.. 'l}i\11'.:} 46 '1/.1.s;? )' 73f:' i/ZS/f .7 B. ifquicy Consultant. The Equity Consultant is the person mutually selected by the parties as described in sectionVI. C. lf6 1'/ir/•7 C. Mediator. The Mediator is Debora L. Osgood. The Mediator previously served as the National Enfo rcem ent Director with the U.S. Department of Education's Office for Civil Rights, and before that held Office Director and Chief Attorney positions in OCR's regional office in Chicago. D. Title IX. Title IX includes the statute, 20 U.S .C. §1681 et seq., Title IX regula tion, 34 C.F.R. § 106.41 (c)(l ), et seq., OCR po licies and guidance, the Title TX lnvestigator's Manual, and controlling Title IX judicial case law. II. ~ ~{2·{~°t Recitals. The parties to the Agreement are the Plaintiffs, or their parent representatives, and the Defendant or its representative, in a civil lawsuit, captioned as Working et al. v. Lake Oswego School · District. This laws uit was filed in the U.S. District Court for the District of Oregon, Portland Division, and was assigned the case number 3: I 6-cv-00581-SB. The Plaintiffs arc fomalc students at the Lake Oswego High School. In their lawsu it, the Plaintiffs seek to enforce their rights under Title IX of the Education Amendments of 1972. Plaintiffs' lawsuit challenges various aspects of Lake Oswego High School's athletics program under Title IX, and related regulations and administrative directives. The Plaintiffs' lawsuit seeks (00507025.DOCX 2) 1 J(F 1/ZS'/17 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 2 of 30 injunctive relief. The Defendant in this lawsuit is the Lake Oswego School Distri ct, wh ich will generally be referred to from here on as "the District." Following a successful medi ation, the parties have agreed to settle the Pl ai ntiffs' lawsuit under the terms described below. III. Effective Accommodation of Interests a nd Abilities. The District wi II prov ide participation opportuniti es for female and male students at Lake Oswego High School that effective ly accommodate the ath letic interests and abilities of both sexes, consistent with the requirements of Title IX. The District has committed to providing additional athletic participation opportunities to fema le students that are substantially proportionate to thei r enrollment in Lake Oswego High School by the end of the 20 18/20 19 school year. If the District does not reach substantial proportionali ty by the end of the 20 18/20 19 school year, then it will assess current interests and abilities of fema le students at Lake Oswego High School and take steps to add additiona l participation opportunities as appropriate to meet their interests and abilities, as described in sections 111.B and 111.C below. The District will continue to assess current interests and abilities of female students at Lake Oswego High School and take steps to add additional participation opportunities as appropriate to meet their interests and abiliti es until the Di strict is able to demonstrate that athletic participati on opportunities availabl e to female students at Lake Oswego Hi gh Schoo l are substantially proportionate to their enro llment. A. Actions to Ach ieve Substantial Propo11ionality. 1. The District commits to reaching prong one compliance (substantial proportionality) by the end of the 20 18/2019 school year at Lake Oswego High School. The District anticipates that it wi ll reach substantial proportionality at Lake Oswego High School by the end of the 2017/2018 school year. The Di strict commits to having a disparity in participation rates by the end of the 20 17/2018 school year of no more than 4 percent. 11. To help ensure that it reaches the goal of substantial proportionality, the District shall elevate both girls' water polo and girls' lacrosse at Lake Oswego High Schoo l to the status of an interscholastic sport beginning the 20 17/20 18 schoo l year. 111. The District will also institute a "no cut" policy for gi rls' volleybal l and girls' soccer at Lake Oswego High School beginning the 2017/20 18 school year. The Di strict may, however, cut fe male athletes who it determines, at its discretion, cannot safely play a sport because of a lack of experience, athletic ability, or any other reason. For any such decision to cut a fema le student from the sport of vo lleyball or soccer, the District must record the reason. {00507025.DOCX 2) 2 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 3 of 30 1v. The District understands that Title IX does not requ ire that it cut teams or reduce opportunities for students who are participating in interscholastic athletics in order to comply with the provisions of Title IX relating to the effective accommodation of the interests and abilities of female students. The District agrees that it wi ll not meet its obligations under th is Agreement to effectively accommodate the interests and abilit ies of female students at Lake Oswego High Schoo l to compete in interscholastic ath letics by summarily eli minating or reducin g the boys' sports or teams. v. Effective immediately, ifthere is a suffici ent number of hi gh school fema le students with sufficient interest and, if applicable, ab ility to support the addition of a team or mu ltiple teams (e.g., varsity, junior varsity, sophomore), the District will offer additional leve ls of sport provided that these new leve ls have sufficient competition with in the school's norma l competitive region and geographic area. The District will offer a JV softball team un less a sufficient number of fema le students do not try out for softball. v1. Effective immediately, the District wil l take steps to recru it fema le athl etes for any participation oppo1tunities added, such as those added based on the interests of Lake Oswego High School girls in athletics as revea led in the spring 2017 Lake Oswego High School survey and focus groups, unless the Di strict is in compliance with prong I. The Equity Consu ltant wil l be responsib le for assessing whether Lake Oswego High Schoo l has achieved substantial proportionality fo llowing the 20 18/20 19 schoo l year. B. Assessing Interests and Abi lities. If prong one is not reached by the end of the 20 18/20 19 school year, then the District wi II assess current interests and abi lities at Lake Oswego High Schoo l as described in this section. The Di strict has conducted an assessment of the students at Lake Oswego High Schoo l and the middle school which feed s into it to determine the existence and/or scope of any unmet athletic interests of female students, and has supp lemented the results of the survey with focus groups. To determ ine whether there is unmet interest and abil ity among fema le students in participating in interscholastic ath letics at Lake Oswego High School the District wil l take the fo llowing actions: • The Di strict will adm inister a simi lar survey as it recently completed, and will conduct supplemental focus groups as necessary, every other schoo l year; • The Di strict will maintain records show ing enrollment numbers broken out by sex, and records showing the numbers of students participating in athletics, broken out by sex and by sport; {00507025.DOCX 2) 3 Case 3:16-cv-00581-SB • • • • • • Document 48-2 Filed 10/03/17 Page 4 of 30 The Di strict wi ll mainta in and rev iew data concerning female students' rates of participation in interscholastic sports at Lake Oswego High School, and any non-m andatory or elective physica l education classes offered at Lake Oswego High School; The District will review any requests (whether oral, written, formal or informal) made beginning the 20 17/20 18 school year to schoo l board members, District administrators, coaches, or staff by or on behalf of fema le students at Lake Oswego Hi gh School to add a particular sport, squad, or level of sport, or to elevate an existing club sport to interscho lastic sport status; The Distri ct will identify all viabl e girl s' teams that have been eliminated at Lake Oswego Hi gh School in the past ten school years; Each school year, beginning with the 20 17/20 18 schoo l year, the District will review the number of female students who were cut from each team at the Lake Oswego High School, including in prior years, and the reasons they were cut, to assess whether any of those students had or have the abi lity to compete in that sport and whether sufficient numbers of students were cut to sustain another level in that spo1t (e.g., junior varsity); The Di strict will identi fy the sports, squads, and levels of sports for female students that are not currently offered at Lake Oswego High School, but are offered either by schools that compete within the league or leagues in which Lake Oswego High School competes, or by schoo ls that are withi n Lake Oswego High Schoo l's normal competitive region and geographi c area; and The Di strict will assess girl s' interest in youth and commun ity sports in the Lake Oswego area, including, but not limited to, new and emerging spo1ts. C. Actions to Increase Ath letic Opportunities. If prong one is not reached by the end of the 2018/20 19 school year, then the District wiII take steps to add add itional participation opportunities as appropriate to meet interests and abilities as described in this section. If, through the above-described assessment, Lake Oswego Hi gh School identifies a sport in which there is sufficient but unmet interest and, as applicable, ability of fe male students to participate at the interscholastic leve l at Lake Oswego High Schoo l, then the school will add ath letics opportunities as described below. For purposes of this provision, "sufficient interest" is defined as the minimum number of athletes needed to support a team. For "sufficient ability," it is sufficient that interested students and admitted students have the potential to sustain an interscho lastic team; students will not be required to demonstrate they have sufficient ability in a new sport or team if students participating in ex isting sports or teams are not required to demonstrate through try-outs or some other process that they possess suffici ent abil ity to participate in the specifi c sport or at the particular level of competition (varsity, junior varsity, etc.) in which they have expressed interest. {00507025.DOCX 2) 4 Case 3:16-cv-00581-SB 1. Document 48-2 Filed 10/03/17 Page 5 of 30 Sports Currently Offered. The District will determi ne, for sports that are currently offered as interscho lastic sports at Lake Oswego High Schoo l, whether there is a suffic ient number of fema le students with the interest and, as appl icable, abili ty to support the creation of add itional levels of competition or multip le sq uads at the same level of competition, and suffi cient competition within the school's normal competiti ve region, to support additional levels of competition or mu ltipl e squads at the same level of competition in those sports. If so, the schoo l wi ll add additional levels of competition or squads at the same or a lower level of competition at the school in those sports beginning the next competitive season. Lake Oswego High School does not have to maintain any additional levels of competition or squads if the minimum number of athletes needed to suppo1t the additional team level or squad do not materialize in a reasonable time. In order to increase the competitive participation opportuniti es for female students, the District will cons ider expanding the squad sizes for interscholastic sports currentl y offered at Lake Oswego High School, consistent with the nature of each sport, so as to ensure a sufficient amount of practi ce and pl aying time for each player, and the level of interest in each sport. The District wi ll increase the size of each squad where determined to be appropriate. If necessary, the District will provide sufficient coaching staff to suppo1t the addition of new athletes to any given squad and take any other steps necessary to ensure that the new athletes on each expanded squad are provided meaningful opportunities to paiticipate in interscholastic athletics. ii. Response to Developing Interests and Abilities. For any sport that is not currently offered at Lake Oswego High Schoo l where there is a sufficient number of female students who have suffi cient interest and, if appli cab le, ability in that sport, but where the District determines that there is not suffic ient competition within the school's normal competitive region, then the Di strict wi ll take ongoing steps to develop students' interests and abilities. These steps may include establi shing intramural or club sports, expl oring the feasibi lity of establ ishing competition in Lake Oswego High School's normal competitive region and geographic area, and elevating such sports to interscholastic status when competition becomes available. 111. Sports Not Currently Offered. The Distri ct wi ll determine whether there is a sufficient number of fe male students at Lake Oswego Hi gh School with suffic ient interest and, as applicable, ability to support the addition of a team or multiple teams in sports not currently offered by Lake Oswego High School as interscholastic sports, and whether there is sufficient competition within the schoo l' s normal competitive region and geographic area for those teams/sports. If so, the Di strict will add a team or multiple teams in those sports at the School. iv. Encouraging Participation. {00507025.DOCX 2) 5 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 6 of 30 The Di strict will take steps to encourage female students at Lake Oswego High School to participate in an interscholastic sport or sports, such as by hosting informational meetings regarding current and prospective athletic offerings. D. Add itional Commitments to Improve Athletic Opportun ities. Regardless of whether the Lake Oswego High Schoo l ach ieves substantial proportional ity, the District comm its to the following: The District wi ll develop a process or procedure for students or other interested parties, such as coaches or parents, to use in requesting the addition of new sporis or leve ls of sports at Lake Oswego High School. The procedure will be written . Notice of the procedure will be published in Lake Oswego High School 's Student Handbook and available on the Lake Oswego High Schoo l athletics web page. The individual responsible for responding to any requests, along with their contact information, will be identified by name. At the beginning of each school year, the District wi ll prov ide written notice to all coaches, physical education teachers, guidance counselors and the principal of Lake Oswego High Schoo l of all sports offered at the schoo l, spec ifying which sports are available to fema le and male students, what students shou ld do if they wish to participate in a sport, as well as all relevant deadlines. Thi s information wi ll also be posted on the athletics page of Lake Oswego High Schoo l's website. At the beginn ing of each school year, the District wi ll distribute a written description of all sports offerings at Lake Oswego High School to all students, what students should do if they wish to participate in a sport, and the relevant deadlines. The written description will include the phrase "students with no prior sports experience are welcome to try out for any and all sports." Th is information will also be posted on the athletics page of Lake Oswego High School's website. The District will maintain squad lists for the interscholastic sports offered at Lake Oswego High Schoo l, which shall reflect the participation numbers fo r each sport. These records wi II not be destroyed or otherwise altered fo r the Agreement Duration so that they can be submitted to the Equ ity Consu ltant and Plaintiffs' counsel as part of quarterly reporting cons istent with the terms of the Agreement. E. Support for Athletics Teams: To the extent that the District adds any sports or add itional levels of teams at Lake Oswego High School, the District shall provide those new teams or new levels, in a manner comparable to other interscholastic programs and teams, and with the eq uivalent level of funds to cover expenses including but not limited to the provision of coaches, equipment and supplies, and publicity and support services. The Di strict will also publicize any new sports or add itional levels of teams through written notices, verba l announcements and postings on the Lake Oswego High Schoo l's website. {00507025.DOCX 2) 6 Case 3:16-cv-00581-SB IV. Document 48-2 Filed 10/03/17 Page 7 of 30 Equal Treatment and Benefits. Subject to the Equity Consultant's approva l, the District will deve lop and implement a plan to ensure that it provides equal athletic opportunities at the hi gh schoo l for members of both sexes with respect to areas li sted below. In assess ing compli ance, the Di strict will compare the availability, quality and kinds of benefits, opportunities, and treatment affo rded to the Di strict's male and female athletes at the high schoo l. • • • • • • • the prov ision of practice and competition fac ilities and locker and team rooms, including softball; the provision of equipment and supplies; scheduling of games and practices times, including opportunities to compete in "prime time" and in pre- and post-season competition; coaching; travel; medica l and training facilities and services; and publicity. A. Locker Rooms. and Practice and Competition Faciliti es. i. Softball Field and Related Facilities. Currently the Lake Oswego Hi gh Schoo l so ftball team is assigned to practice and play on the socalled "lower turf fie ld," and to the so-called " hitting barn" next to the lower turf fi eld. The softball team shares this fi eld with the baseba ll team and other teams. Meanwhile, the softball team still has access to the so ftball fi eld at Lake Oswego Juni or High Schoo l, where it was previously assigned, and may use it whenever it chooses. The softball team also has access to a hitting fac ility installed in Lake Oswego Hi gh School's old gym. As described below, the Di strict will insta ll a turf fi eld on the softball field at Lake Oswego Junior Hi gh Schoo l, and other fac ilities, and the so ftba ll team will be assigned to the softball fi eld at Lake Oswego Juni or Hi gh School. IL Artificial Tur[Field. The Di stri ct will install an artificial turf fi eld on the softball fie ld at Lake Oswego Junior High School that will be in place by the start of the 201 7/2018 softball season. During the softball seaso n, the Lake Oswego High Schoo l so ftball program will have priority use of the softball field at Lake Oswego Junior Hi gh School; the community youth girls' softball program wi ll have secondary priority use of the fi eld. During the off-season, the Lake Oswego High Schoo l softball program and the community youth girls' softball program will have use of the fi eld in accordance with the Di strict' s intergovernmental agreement with the City of Lake Oswego, which requires the Di strict and the City to work collaborati vely to meet the needs and interests of athl etes, and whi ch affords the Di strict's hi gh schoo l spo11s tier one pri ority. {00507025.DOCX 2) 7 Case 3:16-cv-00581-SB 111. Document 48-2 Filed 10/03/17 Page 8 of 30 Hitting Facility and Other Softball Facilities. The Di strict will construct a hitting faci lity immediately outside the right field fence at the softbal l field at Lake Oswego Juni or High School that will be in place by the start of the 20 18/2019 softball season. The hitting faci lity afforded to the Lake Oswego High School softball program will be equivalent to the hi tting barn next to the lower turf field (at LOHS) and provided to the members of the baseball program. In addition, the softball hitting fac ility wi ll include an elevated press announcer's box and concessions stand area, and wi ll have a team room/locker room. By the start of the 2018/2019 softball season, or sooner if possible, the District will ensure that the softba ll field at the Lake Oswego Junior High Schoo l has the fo llowing amenities, which will prov ide benefits to the members of the softball program that are equivalent to the benefits that si milar amenities provide to the members of the baseball teams: PA system ; Ci nder block dugouts; Bu llpens (one for home and one for visitor with preference for location on first base side and on third base side); Lights; Electron ic sco reboard; Flag pole; Fou l po les; Hitting markers and space for sponsors on the outfield fence; Warning track; Markings, color, and painting appropriate and typical fo r a softba ll field ; Proper drainage; Bleachers on concrete slabs; Power outlets at the fie ld; Drinkin g fountain at the field . iv. Other Provisions For Soflball. By the start of the 20 17/20 18 softba lI season, the District wi ll ensure that the softba ll fie ld at Lake Oswego Junior High Schoo l is locked, and that the fie ld is maintained in a manner equivalent to the lower turf field. To reduce the amount of gear the softba ll players may have to transport from Lake Oswego High School, the District wi ll store di strict-owned gear for home practices and games at the softba ll field at Lake Oswego Junior High School beginni ng the 20 17/20 18 softba ll season, providing the necessary keys/access codes to the softba ll program. In addition, the District will ensure that the trainer for Lake Oswego High Schoo l is available and on call for home games and practices, and that the trainer can be reached by a communications device if needed. v. Locker Rooms, and Practice and Competition Facilities {00507025.DOCX 2) 8 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 9 of 30 Effective immediately, the District wi ll monitor the shared faciliti es at Lake Oswego Hi gh School, including the facilities shared by the softball and baseball teams, to ensure that boys' and girls' teams have appropriate and equitable access. The Di strict will designate the Athletic Director and Title IX Coordinator to be point persons for any concerns about the shared usage of faci lities. The District agrees to provide equal athletic opportuni ties to partici pa nts of both sexes in its interscholastic athletics program with respect to the provision of locker rooms, practice and competitive fac ilities, at Lake Oswego High School as required by Title IX. In thi s regard, the District will assess its compliance with the requirements of this program component through a faci li ties review o f Lake Oswego High School and share the results in a report to the Equity Consultant. The District wi ll then develop and implement a plan, to be implemented by or before the end of the 20 17/ 18 LOHS school year, subject to the Equ ity Consultant's approval, to resolve any identified compliance concerns to ensure the provision of equa l ath letic opportunity to participants of both sexes in its interscho lastic athletics program. The Di strict may retain the Equity Consu ltant to conduct the assessment and develop a plan. By January I, 20 18, the Di strict, will complete its comprehensi ve assessment of all locker rooms, team rooms, practice fi elds and fac ilities, and competition fie lds and facil ities assigned to the boys' and girls' athletic teams at Lake Oswego High School to ensure the equivalent provision of locker rooms, and practice and competiti on facilities. The assessment will be documented in a report with the appropriate supporting documentation. The report shall include, at a minimum, an evaluation of the fo llowing: the quality, availability, and use of the fac ilities provided for practice and competiti ve events for each athletic team at Lake Oswego High School; the quality, availabi lity, the use of the locker rooms and team rooms at the school; the maintenance of practice and competitive faciliti es; and the preparati on of facilities fo r practice and competitive events; and the number and percentage of male and fema le athletes that have access to each faci lity or amenity . Except as specified, the report wi ll be done in a manner directed by the Equ ity Consu ltant. The assessment of the above-listed factors shall include the following: a list of al l locker rooms, practice fie lds and faci li ties, and competitive fi elds and facilities, includ ing proximity of locker room s to the practice and competitive facil ities; quality of each faci lity (including, but not li mited to, any identified issues related to field drainage, field lighting, etc.); amenities for each locker room (showers, laundry service, ava ilable trainers, accommodations fo r visiting teams); use of locker rooms; amen ities for each practice and competitive field (concession facilities, public address systems, electronic scoreboards, seating at each field, mai ntenance of each fac ility, preparation of each practice and competiti ve field); the age of each facility, and whether it is on or off-campus; and whether certain teams or program s have exclus ive use of the fac ility, including a schedule showing when faci lities are used for practice and competiti on and how long the locker rooms are assigned fo r use by each athletic team Lake Oswego High School. If boys' and the girls' ath letic teams at Lake Oswego High School are not receiving comparable benefits and opportun ities with respect to locker rooms, practice fields and faci lities, and {00507025.DOCX 2) 9 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 10 of 30 competitive fie lds and facilities, then the District wi ll deve lop and implement a plan to ensure that female and male student ath letes are prov ided with equ ivalent benefits and services in this area at Lake Oswego High Schoo l. Once the District has implemented th is plan, the Di strict will include in its quarterly reporting its remedial effo rts. The Equ ity Consultant will then determine whether the District has remed ied any prev iously identified inequality. Quarterly reports wi ll identify any outstand ing issues with respect to the provision of fac ilities in Lake Oswego High School 's interscholastic athletics program. 8. Equipment and Supplies. The District agrees to equitably treat participants of both sexes in its interscholastic athletics program with respect to the prov ision of equipment and suppli es at Lake Oswego High School as required by Title IX. In this regard, the District wi ll develop a plan to ensure that it provides equal athletic opportunities at Lake Oswego High School for members of both sexes in the provision of equipment and supplies, to include uniforms and storage space for such equipment and supplies. The District will immedi ately commence implementation of the plan as applicab le beginning the 20 17/20 18 school year. The Equity Consultant wi ll review, and as necessary recommend changes. The District will assess whether the girls' interscholastic athletic teams at Lake Oswego High School are provided with uni forms, equipment, supp lies, and storage that are comparable in quality, relative amount, suitability, maintenance, and replacement, and avail ab ility to the equ ipment and suppli es provided to the boys' interscholastic athletic teams at the school. To that end, if it has not already done so, the District wil l complete a comprehensive inventory of all equ ipment and supp lies, which includes uniforms and any re lated storage spaces, assigned to the boys' and girl s' athletic teams at Lake Oswego High Schoo l to ensure the eq uitable provision of equ ipment and supplies. The inventory will be documented, updated annuall y, and in the next quarterly report. The report shall include, at a minimum, a detailed listing and evaluation of the eq uipment and supplies prov ided to each athl etic team; the relative qua lity or condition of the equipment and supp lies; the source of funding fo r the equipment and supplies; the date the equipment and supplies were acquired, if known; the date they are scheduled to be replaced, if applicable; and their current value and replacement cost, if known and applicable. The Di strict wi ll take all reasonable steps to ensure the equitable provision of equ ipment and supp lies to male and female athletes. If the Equity Consultant determ ines that the provision of equipment and supplies is not equ itable then the Equ ity Consultant will create a plan to remedy the inequa lity to be prov ided to all parties. The plan will include a description of specific actions needed to ensure the inequality is remed ied. C. Scheduling of Games and Practice Times. The District agrees to equ itably treat partic ipants of both sexes in its interscholastic athletics program with respect to scheduling of games and practice times, as well as tournament opportunities, at Lake Oswego High Schoo l as required by Title fX. In thi s regard, the District {00507025.DOCX 2) 10 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 11 of 30 will assess that the District's girls' interscholastic athletic teams at Lake Oswego High School are provided with comparable opportun ities as provided to the boys' interscholastic athletic teams at the same schoo l in the number of competitive events per sport, number and length of practice opportunities, time of day competiti ve events are scheduled, time of day practice opportunities are scheduled, and opportunities to engage in available pre-season and post~season competition. The practice and game schedules the District creates for Lake Oswego Hi gh School will be included in quarterly reporting in their most current or complete form at the time of the report. If the Equity Con sultant determines that the schedule is not equitable, then the District will then develop and implement a plan, subject to the Equity Consultant's approval, to ensure that the scheduling of game and practice times in the future is equitable. Reports submitted will include a compilation of the game and practice schedules from Lake Oswego High Schoo l dati ng back one year. D. Coaching. The Di strict agrees to equitably treat pa1ticipants of both sexes in its interscholastic ath letics program with respect to quality and quantity of coaching at Lake Oswego High School as requ ired by Title IX. In this regard , the District will provide equal ath letic opportunities to participants of both sexes in the interscholastic athletics program at Lake Oswego Hi gh Schoo l with respect to the opportunity to rece ive coaching and the assignment and compensati on of coaches, as required by Title IX. The Di strict will assess its comp liance with the requirements of thi s program component at Lake Oswego High School and share the results in quarterly reports. The assessment wi II spec ifically consider and address any actions taken or support provided by booster clubs, with particular emphasis on how such outside fundin g is used to prov ide stipends for part-time and vo lunteer coaches. The District will then deve lop and implement a plan to resolve any identified compliance concerns to ensure the provision of equal athletic opportunity to participants of both sexes in its interscholastic ath letics program. The District will complete a comprehensive assessment of the avai labil ity, experience, assignment, and compensation of coaches in its interscholastic athletics program at Lake Oswego High School to ensure that participants of both sexes are provided coachin g benefits that are equiva lent or equi valent in effect. The assessment will be documented in quarterly reports and shall include in fo rmati on about the Lake Oswego High School athletics program fo r the relevant school year. The assessment will also include plan s the District has to ensure that inequalities in the avail ability of coaching do not arise as the number of athletes participating in sports fluctu ates. Such reporting sha ll further include, at a minimum , an assessment of the fo llowing factors: the number of pa1ticipants for each team at Lake Oswego High Schoo l; a review of the number of full-time coaches, part-time coaches, ass istant, and volunteer coaches at the school assigned to each sport; and a review of the compensation of coaches, including their rate of compensation (per sport, per season), and the qualifications of each coach. E. Medical and Training Faci lities and Services. The District agrees to equitably treat participants of both sexes in its interscholastic athletics program at Lake Oswego Hi gh School wi th respect to quality and quantity of medical and (00507025 .DOCX 2) 11 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 12 of 30 training services as req uired by Title IX. In th is regard , the District wi ll assess its compliance with the requ irements of this program component at Lake Oswego High School and share the results in its quarterly reports. The assessment will specifica lly consider and address access to the weight room and training services, including whether the weight room provides female athletes with appropriate we ights and train ing equipm ent, as well as scheduled access, in a manner comparable to males. The District will then develop and imp lement a plan, subject to the Equity Consultant's approval, to resolve any identifi ed compliance concerns to ensure the provision of equal athletic opportuni ty to parti cipants of both sexes in its interscholastic athletics program. F. Trave l and Transportation. The District agrees to equitably treat partici pants of both sexes in its interscholastic athletics program at Lake Oswego High Schoo l with respect to the provi sio n of travel and transportati on benefi ts to male and female athletes as requ ired by Title IX. In this regard , the District will assess its compli ance with the requ irements of this program component at Lake Oswego High Schoo l and share the results in its qua11erly repo11s. The District will then develop and implement a plan to resolve any identi fi ed compliance concerns to ensure the provision of equal athletic opportunity to participants of both sexes in its interscholastic athletics program. G. Publicity The Di strict agrees to equitably treat participants of both sexes in its interscholastic athletics program at Lake Oswego High Schoo l with respect to publicity as requ ired by Title IX. In this regard, the District will assess its compliance with the requirements of th is program component at Lake Oswego High Schoo l and share the results in its quarterly reports. The assessment will specifi cally consider and address access to, contracts with, and work perfo rmed through Game Day media, the student newspaper, daily announcements (written/verbal), and dai ly/week ly Lake Oswego High Schoo l and/or the District bu ll etins. The Di strict will then develop and implement a plan to resolve any identifi ed compliance concerns to ensure the provision of equal athletic opportunity to participants of both sexes in its interscholastic athletics program. H. Funding and Fundraising. Subj ect to the Equ ity Consultant's approva l, the District will create and implement, if it has not already, a comprehensive policy to oversee booster club fundin g and any other private donations fl owing into the athletic program at Lake Oswego High Schoo l. The po licy will ensure that if booster clubs or other outs ide sources prov ide benefits and services to athletes of one sex that are greater than the benefits and services prov ided to the other sex at Lake Oswego High School, or if any fund ing results in such an inequality, then the District will take action to ensure that the benefi ts and services are equivalent for both sexes. The District wi ll remedy any such inequality even if it was not aware at the time it was given that a booster cl ub or other outs ide source provided a benefit, service, or fundin g. The bud get fo r each team (including fund ing from all sources) will be included in its quarterly reports. {00507025.DOCX 2) 12 Case 3:16-cv-00581-SB I. Document 48-2 Filed 10/03/17 Page 13 of 30 Eliminati on or Reduction of Program Components. The District understands that Title IX does not req uire that it eliminate or reduce any program component in order to comply with the provisions of Title IX which provide for equal treatment and benefits between the sexes in any offered interscho lastic athletics. The District agrees that it will not meet its obli gations under this Agreement to treat female students at Lake Oswego Hi gh Schoo l equa lly in any offered interscholast ic athletics by summaril y elim inating or reducing any program component offered to male athletes. V. Additional Requirements. A. Public Statement of Commitment. Within 30 days of this Agreemen t's execution, the District's Superintendent, and the Principal and Athletic Director of Lake Oswego High School, will issue a public statement of the Di strict's commitment to complying with Title IX and its implementing regul ations. The statement will specifica lly state that the District and Lake Oswego High School are committed to effectively accommodating the athletic interests and abilities of members of both sexes with respect to the opportunity to participate in the interscholastic athletics program at Lake Oswego High School and to providing equal opportunity for all students to receive the benefits and services in Lake Oswego High School's interscholastic program. The statement will also include an affirmation that the District supports the Lake Oswego High School softball program, and all female ath letes at Lake Oswego High School. B. Task Force on Gender Equ ity in Interscholastic Athletic Programs. Withi n 30 days of this Agreement 's execution, the District will establi sh a volu nteer task fo rce comprised of members of the community to provide in put on gender eq uity issues at Lake Oswego High Schoo l, including implementation concerns relating to the Agreement. The Di strict will also work collaboratively with the task force in planning, designing, and installing the artificial turf fi eld and related facil ities at the softball fie ld Lake Oswego Junior Hi gh School. The task force will include at least one of the Plaintiffs, Andrew Glascock, the Lake Oswego Hi gh School Title IX Coordinator, and the Lake Oswego Athl etic Director. This task fo rce wi ll remain in place during the Agreement Duration. C. Title 1X Coord inator. The Di strict wi ll designate a Title IX coordi nator to coordinate its effo11s to compl y with and carry out its responsibil ities under Title IX at Lake Oswego High Schoo l. The coordinator's responsibi lities will include investigating complai nts alleging noncompliance with Title IX in the area of interscholastic athletics at Lake Oswego High Schoo l. The Coordinator's name and contact in formation will be posted on the Lake Oswego Hi gh School web site. D. Title 1X Annua l Train ing. {00507025.DOCX 2} 13 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 14 of 30 The Di strict wi ll provide annual Title IX training for District employees and all Lake Oswego High School coaches involved in the interscholastic athl etics program. E. Non-Retaliation Policy. The District wi ll not retal iate against anyone fo r their participation in the lawsuit or for their advocacy on behalf of fema le athletes. The word "retaliation" here has the normal mean ing ascribed to it in the context of a retaliation claim brought under Title IX. VI. Monitoring and Enforcing the Settlement Agreement The Agreement requires the parties to comply with some of its terms both now and fo r a period in the future . The parties therefore agree to the fo llowing prov isions regarding how the parties' imp lementation o f the terms of the Agreement will be monitored and enforced. A. Reports. The District will provide quarterly reports to the Equity Consultant, and the Plaintiffs (through their counsel) on the District's implementation of the Agreement beginning October 15, 2017, followed by reports on January 15, April 15, and Jul y 15 and conti nuing fo r the Agreement Duration. The quarterly reports will be in the manner and form prescribed by the Equity Consu ltant, except where the manner and form of those reports are specified in the Agreement. The quarterly repotts will include enro llment numbers broken out by sex, and the numbers of students parti cipating in athletics, broken out by sex and by sport. The quarterl y reports also wi ll include the Di strict's assessment of the progress made at Lake Oswego High School in adding teams and team levels as required in thi s Agreement. The quarterl y reports will include the results of the survey and focus groups, including other steps to assess interest at Lake Oswego High Schoo l, including conducting an analysis of the competitiveness and feasibility of starting various teams in its geographic region. The quarterly reports will detail any effo rts it has made to create new opportunities for fe male students in response to the information it has collected, including whether it has added new sports, or levels of sports. The quarterly reports will detail the Distri ct's plan to create to create new opportuniti es for fema le students in response to th e info rmation it has col lected, including whether it has added new sports, or levels of sports. The quarterly reports will include any informat ion or data the District amasses to comply with the requirements of all sections of this Agreement. B. Monitoring and Implementing the Settlement Agreement. With approva l of both parties, the Di strict will retain a mutually-agreeab le Equity Consu ltant to oversee and monitor the implementati on of the Agreement for a period of at least three (3) years {00507025.DOCX 2) 14 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 15 of 30 from the execution of the Agreement. The Di strict wi ll prov ide the Equity Consultant with access to its fac ili ties and data and , with appropriate notice, personnel and students, for the purpose of assessing the District's compli ance with the Agreement. The patties agree to work in good faith with one another and with the Equ ity Consultant to resolve any differences regarding the implementation of the Agreement. If the Equity Consultant determines that the Di strict has fa iled to comp ly with the Agreement after notice to the District and an opportunity to take appropri ate action to address the noncompliance, then the Equity Consultant will in form the part ies in writing of the fa ilure to comply with the Agreement. The parties agree they will not seek cou1t intervention regarding the implementation of the Agreement unless and until the Equ ity Consu ltant and the Med iator has informed them in writing of the fa ilure to comp ly with the Agreement. C. Selection of Equity Consultant. The District will retain an Equity Consultant with expertise in Title !X's provisions as they apply to interscholastic athletics who, as described in the Agreement, will oversee and monitor the District's impl ementation of the terms of the Agreement which relate to Lake Oswego Hi gh Schoo l's athletics program. The Equity Consu ltant will serve fo r the Agreement Duration. The District will pay the Equity Consultant's cost. The patties shall exchange proposed names and qualifications fo r the Equi ty Cons ultant within 30 days of the execution of th is Agreement and shall then endeavor to agree upon a candidate. If the parties cannot mutually agree on an Equity Consultant, then one will be selected by the Med iator with cons ideration of the parties' input. The District and the Plaintiffs sha ll not have to accept an Equity Consultant it/they has/have previously rejected . D. Continuing Court Juri sd iction. The parties agree to request that the District Court reta in jurisdiction of the federal lawsuit, including jurisdiction to enforce the Agreement and, as necessary, to address any issues raised by the Court relating to the proposed Class, for a period of three (3) yea rs from the Agreement's execution. Plaintiffs agree that Defendant may seek to petition the court to end jurisdiction should al l obligations of the Agreement be met, including the full construction of the new so ftba ll complex. Plaintiffs may seek attorneys' fees and costs for preva iling in any such petition regarding termination of the Court's jurisdiction. Consistent with the process outlined in Section VJ. B above, Pl ainti ffs may petition the court to extend the term of the Agreement should Defendant not substantially comply with the Agreement. Within 5 business days of the sign ing of the Agreement, the parti es wi ll j ointly fil e this Agreement with the Un ited States Di strict Court for the Di strict of Oregon in the matter captioned as Working et al. v. Lake Oswego School District, case number 3: l 6-cv-0058 1-SB. The joi nt motion shall ask that the Court enter this Agreement as an order of the Court pursuant to Federal Ru le of Civi l Procedure 41 (a)(2), and cond itionally dismiss the complai nt in this action without prejud ice pursuant to Rule 4 1(a)(2), while retaining j uri sdiction to enforce the (00507025.DOCX 2} 15 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 16 of 30 Agreement. The parties will ask the Cou rt to place the case on the Court' s inactive docket subject to recall to the active docket should it be necessary for either party to move the Court for an order to enforce a term or term s of the Agreement. If the Court requ ires this Agreement to be changed before it wi ll enter it as an order of the Court and conditionally dismiss the Plaintiffs' complaint, then the parties agree that they will work together in good fa ith with the Mediator to make the necessary changes. If the Court requires this Agreement to be changed, the Agreement will remain in effect except any part of the Agreement that is changed. Any changes to the Agreement required by the Cou rt will become part of the Agreement and will be binding on the part ies. The parties also agree that they will work together in good fa ith, with the Medi ator if necessary, to resolve any other issues the Court may raise before it wi ll enter this Agreement as an order of the Court and cond iti onally dismiss the Plaintiffs' complaint. If the Court grants the parti es' motion for a cond itional dismissal, then a condi tional dism issal will be fo llowed by a final dismissal with prejudice either on performance of the terms of the Agreement, at the end of 20 19/2020 schoo l year, or as stipulated to by the parties un less the Plaintiffs successfully petition to extend the term of the Agreement. If the Plaintiffs successfully petition the Court to extend its jurisdiction over the terms of the Agreement as described in paragraph one of this section, such an extension shall be limited to those provisions of the Agreement that Plaintiffs successfully petitioned to have extended rather than the entire agreement. If the District has fulfilled all its obligations under the Agreement before the end of the 20 19/2020 schoo l year, then the District may move the Court fo r a fin al dismissal with prej udice. The Plaintiffs may oppose the Distri ct's petition to end the Court's jurisdiction. If the Plaintiffs prevai l in their opposition, then the Plaintiffs may petition the Court for the fees and costs they incurred in opposing the Di strict's petition to end the Court's jurisd icti on. If the Court finds the Di strict is not in compliance with this Agreement, but that noncompliance was beyond the reasonabl e control of the Di strict, the District sha ll not be in breach of this Agreement. However, if the noncompliance was beyond the reasonable control of the District, the parties agree that the Court may exercise its equitable powers to devise an appropriate remedy or modification of this Agreement to accomplish the same result as that intended by the portion of the Agreement with which noncompliance was fo und, provided the parties cannot reach Agreement on the remedy or mod ification. VII. Fees and Costs. A. Attorneys' Fees and Costs. Within 30 days of the date the Agreement is executed, the District will pay to the Plaintiffs' attorneys-Andrew Glascock and Lega l Aid at Work-the amount of $262,500, representi ng their fees and costs. {00507025 .DOCX 2) 16 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 17 of 30 B. Mediator's Costs. The District shall pay any and all costs for the Mediator for conducting and finalizing the mediation. C. Future Fees and Costs. Except as provided otherwise in this Agreement, the parties will bear their own fees and costs incurred during the Agreement Duration. VIII. Negotiation and Drafting. For the purposes of resolving any ambiguities that may later arise in interpreting this Agreement, neither party will be deemed to have drafted this Agreement so that neither party will be entitled lo have any terms of this Agreement construed in its favor by default. Likewise, the pa1ties aver that they were all represented by competent attorneys throughout the mediation process and the negotiation of this Agreement. Approved and agreed to on: For the Plaintiffs: Stf1 i~ ~, io 11 Date BRIONNA GEREB, By her next friend DREW GEREB Date LILLIAN HAR WOOD, By her next friends TYE HARWOOD and JAMIE HARWOOD Dale KELSEY DEOS, By her next fiends KELLY DEOS and LAURA DEOS Date (00507025.DOCX 2) 17 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 nr DilaDcl . . ..,. _, ...... cmllf h-dJt ~ ~ caad\ttlrfdj m - Page 18 of 30 av di¥ (nvfi111 iarj+++ c. ftmlR: f':m and Cmmi Uapc • jWViclaf utbiwbc iD . ~ dicpmawlil fJar"~Ollllll tkD.ufc.a ;...... ~ dnt ADt* uw1111 Dmriam Far- 6r pmpolD af tDJ!w.t& my amq•inea lfi:atl. llZBJ'~ailtr in•t 19M¥•irrs Aw•N'1'ilft mi6c% pmcy will u ..._, iildl:d m A(p=ammm diJm will kcndinf ID . . . . aDJ tama tJI lfaia Aa#CO"'iltlW amsnmd im • dk&al\l hr:••''"'' lfmo.-.,. amdia',_., 81...........,... ~ dlC' ~-= diat lky-=m llJ'cnmgenmr; :ttnmrc:p.~tk i!M cfiJ4m pi:ocaa md lfkr RqliP iW ..,.. CJI dJis Agtae iilffl1! Appioccdm..,-Dam Fardtl~· • , -~. ...:.i ' ;1;: -~. r ~k .· ..· ~. . .. ~~~ :! ~ J I Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Date Date KELSEY DEOS, By her next fiends KELLY DEOS and LAURA DEOS {()(1j()70:ZS.OOCX 2} 17 Page 19 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Page 20 of 30 B. Mediator's Costs. > The District shall pay any and all costs for the Mediator for conducting and finalizing the mediation. C. Futme Fees and Costs. Excepl as provided otherwise in this Agreement, the parties will bear their own fees and costs incurred during the Agreement Duration. VIII. Negotiation and Drafting. For the purposes ofresolving any ambiguities that may later arise in interpreting this Agreement, neither party will be deemed to have drafted this Agreement so that neither party will be entitled to have any terms of this Agreement construed in its favor by default. Likewise, the parties aver that they were all represented by competent attorneys throughout the mediation process and the negotiation of this Agreement. Approved and agreed to on: For the Plaintiffs: LAUREN WORKING Date BRIONNA GEREB, By her next friend DREW GEREB Date LILLIAN HARWOOD, By her next friend s TYE HARWOOD and JAMIE HARWOOD Date LSEY DEOS, By her next fiends KELLY DEOS and LAURA DEOS Date 0 -Z!P-17 {00507025.DOCX 2} 17 Case 3:16-cv-00581-SB Document 48-2 ~~ . Filed 10/03/17 Cf-zr-1:r- MORGANJOS, By her next friends DAVID JONES and SHELLY JONES Date ANNA TOMITA, By her next friends TODD TOMITA and MARNA TOMITA Date MARIN PENNEY, By her next friends DARIN PENNEY and MARIE PENNEY Date LAYNEY LOMBARDO, By her next friend HEIDI JONES Date VIVIAN RITTENOUR, By her next friends PETER RITTENOUR and DAM.ARI RITTENOUR Date KIANA WILLIAMS, BY her next friends ANDREW CHOO and LINDA LA TIO Date For the Defendant: Date DR. HEATHER BECK Superintendent Lake Oswego School District (00507025.00CX 2) 18 Page 21 of 30 Case 3:16-cv-00581-SB Document 48-2 MORGAN JONES, By her next friends DAVID JONES and·SHELLY JONES Date ~~f,~,{ 0. ~ ANNA TOMITif By her next friends TODD TOMITA and MARNA T01v1JTA MARIN PENNEY, By her next friends DARJN PENNEY and MARIE PENNEY Date LAYNEY LOMBARDO, By her next friend HEIDI JONES Date VIVIAN RTITENOUR, By her next friends PETER RITTENOUR and DAMAJU RITTENOUR Date KIANA WILLIAMS, Date BY her next friends ANDREW CHOO and LINDA LA ITO For the Defendant: Date DR. HEATHER BECK Superintendent Lake Oswego School District {0050702.5.DOCX 2.} 18 Filed 10/03/17 Page 22 of 30 Case 3:16-cv-00581-SB Document 48-2 MORGAN JONES J By her next friends DA VJD JON ES Filed 10/03/17 Page 23 of 30 Date and SI JELLY JONES ANNA TOMITA, By her next friends TODD TOMITA and MARNA TOMlT A MARJN PENNEY, By her next friends DARIN P NNEY - Date 9_,_:tS- /T- oate and MARIE PENNEY LAYNEY LOMBARDO, By her next friend HEIDI JONES VIVIAN RIITENOUR, By her next friends PETER RITIENOUR and DAMARl RIITENOUR KIANA WILLIAMS, BY her next friends ANDREW CHOO and LINDA LA ITO Date Date Date For the Defendant: THERBECK Date Case 3:16-cv-00581-SB \ll)RCi \'.\ l(J~I Document 48-2 s. Daw B: hl·r lll'Xl lm•11d-. D \ \ l () JO'- I anJ SI II .I I '\ JO'd S \ V\-\ ro,111 r\. 13) h~.-r lll'\I fricmJ.. I OD!> I 0\111 \ I>ate and \1 \RNr\ I 0\111 \ \!ARI'\ PF\: LY. B) hi.:rnc\t fricnJs D.\RI'\ Pl ·N\:1-Y an \ \!VI\~ Date Rll Pl :\'\FY Rl1 l"L~OUR. Date B) her next friends Pl: I l:R R11 11 NOL R and D.\\lr\RI RirI ENOUR Kl \N \\\II I l1\\1S. Date BY her nc\t friends /\\!DRI \\' C 1100 nnd I IND \ I \ no DR. I fl \ 1111 R Bl CK Supcrintcmknl I akc Om ego chool District Date Filed 10/03/17 Page 24 of 30 Case 3:16-cv-00581-SB Document 48-2 MORGAN JONES By her next frien~ DAVID JONES and SHELLY JONES Date ANNA TOMITA, By her next friends TODD TOMITA and MARNA TOMITA Date MARlN PENNEY, By her next friends DARIN PENNEY and MARIE PENNEY Date LAYNEY LOMBARDO, er next friend HEIDI JONES Date KIANA WILLIAMS, BY her next friends ANDREW CHOO and LINDA LATIO For the DefendanJ: DR. HEATHER BECK Superintendent Lake Oswego School District pJ5010Z5.DOCX 2} 18 Filed 10/03/17 Page 25 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 MORGAN JON ES, By her next friends DA YID JONES and SII ELLY JONES Date ANN/\ TOMIT /\, By her next friends TODD TOM IT/\ and MARNA TOMJT A Date MARIN PENNEY, By her next friends DARIN PENNEY and MAR IE PENNEY Date LAYNEY LOMBARDO, By her next friend HEIDI JON ES Dale VIV IAN RITTE OUR, By her next fri ends PETER RITTENOUR and DAMAR! RITTENOU R Date 9 cG.\l b~RrM· hl'ill Wv\\J h Date KIA A WILLIAMS , BY her next fri ends ANDREW CHOO and LINDA LATTO Cy I zu, , 1·+ c§--)oQF<~-./-k-") For the Defe11do11t: Date DR. llEATllER BECK Superintendent Lake Oswego School District (00507025.DOCX 2 1 18 Page 26 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Attorneys for the Plaintiffs COCK, STREET AND WAXLER, LLP ndrew Glascock THE LEGAL AID AT WORK Elizabeth Kristen Kim Turner Date Attorneys for the Defendant MERSEREAU SHANNON LLP Karen M. Vickers Blake H. Fry Date (00507025.DOCX 2) 19 Page 27 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Allorneysfor the Plaintiffs GLASCOCK, STREET AND WAXLER, LLP Andrew Glascock Date ~~ THELE~L AID AT WORK Date Elizabeth Kristen Kim Turner Attorneysfor the Defendant Date MERSEREAU SHANNON LLP Karen M. Vickers Blake H. Fry {00507025.DOCX 2) 19 Page 28 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 MORGAN JONES, By her next friends DAVID JONES and SHELLY JON-.ES Date ANNA TOMITA, By her next friends TODD TOMITA and MARNA TOMITA Date MARIN PENNEY, By her next friends DARIN PENNEY and MARIE PENNEY Date LAYNEY LOMBARDO, By her next friend HEIDI JONES Date VIVIAN RITTENOUR, By her next friends PETER RITTENOUR and DAMAR! RITTENOUR Date KIANA WILLIAMS, BY her next friends ANDREW CHOO and LINDA LATTO Date For the Defendant: ~~-~fiedc_ CrJif.ti.EATHER BECK Superintendent Lake Oswego School District (00507025.DOCX 2) 18 Page 29 of 30 Case 3:16-cv-00581-SB Document 48-2 Filed 10/03/17 Attorneys for the Plaintifft GLASCOCK, STREET AND WAXLER, LLP Andrew Glascock Date THE LEGAL AID AT WORK Elizabeth Kristen Kirn Turner Date 1/2{//7 l Date ( Karen M. Vickers Blake H. Fry {00507025 .DOCX 2) 19 Page 30 of 30