SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES or AMERICA MICHIGAN UNIVERSITY UNDER THE AMERICANS WITH DISABILITIES ACT I. INTRODUCTION The parties (Parties) to this Settlement Agreement are the United States of America (United States) and Northern Michigan University (NMU or the University) - II. RECITALs NMU Is a founyear public university located' to Marquette, Michigan. NMU is a public entity within the meaning of the ADAtherefore subject to Titie II of the ADA, 42 S. C. 12131-34, as amended (Title II), and its implementing regulation, 28. Part 35. The United States Department of Justice (Department) is IreSponsible fer administering and enforcing Title II and its implementing regulation, 23 C. F. B. Part 35 This Agreement arises out of a complaintt filed with the U. Department of Justice, Civil Rights Division, Disability Rights Section that alleged that NMU discriminated against an individual with a disability to violation of Title Ii Speci?cally, the Complainant alleged that NMU threatened to dis-enroll her and required her to submit to a - assessment and sign a behavioral agreement after she sent a chat message . to a friend and fellow NMU student in which she told her friend that she has Major Depressive Disorder and her doctors ace concerned that she is at risk for suicide, The Complainant further alleged that the behavioral agreement prohibited her from engaging in any discussion of suicidal thoughts or actions with residents of her dorm, friends or other students. According to the Complainant NMU took this action toward her pursuant .m Policy Relating to Student Self-Destructive Behavior. in addition to the Complainant, the United States identi?ed three (3)-other current or fonner NMU students who alleged thatNMU discriminated against them based on disability in violation Title 11. Speci?cally, these individuals alleged that NMU required them to: (1) meet with the Dean of Students or the Associate Dean of Students, who threatened them with disciplinary action for sharing suicidal or self-destructive thoughts with other NMU students; (2) undergo mandatory assessments to maintain enrollment; (3) abide by certain conditions to maintain enrollment; and/or (4) involuntarily withdraw from NMU These current/former students alleged that NMU tacit these actions toward them pursuant to NMU 5 Policy Relating to Student Selt- Destructive Behavior 10] 11?. During the course of its investigation, the Department gathered and reviewed information from the Complainant, other NMU students, and NMU. Infonnation the Department gathered during the course of its' investigation substantiated the allegations described in Paragraphs 4 and 5, above. Through its investigation, the United States determined that Policy Relating to Student Self-Destructive Behavior does not re?ect or impose legitimate safety requirements within the meaning '01? Title II of the ADA. The United States also determined that a Dean of Students office took adverse action against NMU students with mental health disabilities who did not pose an actual risk or serious selfuhann. This action was precipitated, in some cases, by information the of?ce received through the ?Behavioral Concerns" section of the Dean of Students? webpage, where anyone may anonymously report concerns. . NMU denies that it has violated Title II 1n any way.- 111. STATEMENT or CONSIDERATION The Parties agree that it.- is in their best interests, and'the United States believes that it is in the public interest to resolve this dispute without engaging in'protracted litigation. The Parties have therefore voluntarily entered into this Settlement Agreement (Agreement) - In consideration of this Agreement, the United-States agrees to close its investigation (DJ 204-38- [27) without further enforcement action related to the facts to paragraphs 4-15, except as provided 111 Paragraph 23, below The 'Partles agree and acknowledge that this consideration'is adequate and suf?cient. THEREFORE, the Parties, through their authorized representatives, hereby stipulate and agree as follows: 1v. TITLE 11 OBLIGATIONS AND muons so as. TAKEN or 1111111 NMU will comply with the requirements of Title ll of the ADA, 42 U.S.C. l2131-34, as amended, audits implementing regulation, Part 35. Title Ii mandates that. ?no quali?ed individual with a disability will, by reason of such disability, be excluded from participation in or be denied the bene?ts of services, programs, or activitiesof a public entity, or be subjected to discrimination by any suchentity." 42 U.S.C. 12132; see also 23 C. F. R. 35. 130(11). Mental health conditions such as Major Depressive Disorder and Anxiety Disorder that substantially limit major life activities like eating, sleeping, looming, concentrating, thinking, communicating, and interacting with others are disabilities within the meaning of the ADA. 28 C. F. 35.1134, 35.103, The prohibition on discrimination requires-that: a. NMU, in providing any aid, bene?t, or service, may not, directly or through - contractual, licensing, or other arrangements, on. the basis of disability, deny a quali?ed individual with a disability the opportunity to participate in or bene?t . from the aid, bene?t or service. 28 CPR. 2 b. NMU, in providing any aid, bene?t, or service, may not, directly or through contractual, licensing, or other arrangements, on the basis of disability, afford a quali?ed individual with a disability an opportunity to participate in or bene?t from the aid, bene?t, or service that is not equal to that afforded others. .28 . c. NMU, in providing any aid, bene?t, or service, may not, directly or through contractual, licensing, or other arrangements, on the basis of disability, otherwise limit a quali?ed individual with a disability 1n the enjoyment of any right, privilege, advantage, or opportunity en; eyed by others receiving the aid, bene?t, or service. 28 C. F. 35 130(b)(l)(vii); . . d. NMU will make reasonable modi?tiations in policies, practices, or procedures when the modi?cations are necessary to avoid discrimination on the basis of - disability, unless NMU can demonstrate that making the modi?cations would fundamentally alter the nature of the service, program, or activityNMU will notirnpose or apply eligibility criteria-that screen out or tend to screen . out an individual with a disability or any. class of individuals with disabilities from fully and equally enjoying any service, program, or activity, unless such criteria can be shown to be necessary for the provision of the service, program, or activity being offered. 28 C. F. R. . 12. ADAINon?Disorirnination Eolicy. NMU will Create an ?ADAMm?Disc?minatidn Policy" that documents the requirements of Title II and its implementing regulation." Speci?cally, NMU will: 11 Within thirty (30) calendar days, draft an ?ADAMon?Discrimination Policy? to include: i. NMU does not discriminate against applicants or students on the basis of disability, including persons with mental health disabilities; 1 ii. Applicants and students with disabilities have an equal-opportunity to . participate in or bene?t frorn the services, programs, and activities provided by NMU will make reasonable modi?cations to its policies, practices and procedures when the modi?cations are-necessary to avoid discrimination on the basis. of disability, unless making the modi?cations would fundamentally alter the nature ofthe service, program, or activity; iv. For all reasonable modification determinations, NMU will conduct an individualized assessment and case-by?case determination as to whether 3 . and what modi?cation(s} can be made to allow a student with a disability to participate in the services, pro grams, and activities at NMU, and to continue to participate in and bene?t from NMU's services, programs, and activities while receiving treatment for a health condition; and v. NMU will not impose or apply eligibility criteria that screen out or tend to . screen out an individual with a disability or any class of individuals with disabilities from fully and equally enjoying any service, program, or activity, unless such criteria can be shovm to be necessary for the provision of the service, program, or" activity being offered. b. Once the United States approves the policy in accordance with Paragraph 16, Wt] will post the policy 111 the onlinc version of NMU 5 Student Handbook and 111 all subsequent versions of 5 Student Handbook for the . term of this Agreement NMU will also post the policy at for the term of this Agreement. 13. Reasonable Accommodation Policy. NMU will create a ?Reasonable Accommodation Policy? that documents the requiiements of Title ll of the ADA and its implementing regulation Speci?cally NMU will: 11. Within thirty (30) calendar days,- draft a ?Reasonable Accommodation Policy" to include: i. NMU ts committed to providing students with disabilities an equal . opportunity to participate in and bene?t ?orn its services, programs, and activities: ii. NMU provides students withreasonahle accommodations in a timely manner when such accommodations are necessary to afferd services, programs, and activities to individuals with disabilities, unless providing the accommodation would fundamentally alter the sauna of the service, program, or activity; Students with disabilities may request academic accommodations; housing and dining accommodations; modi?cations to University policies, rules, and regulations; environmental adjustments Such as the removal of architectural, commonication, or transportation barriers; and auxiliary aids and services; iv. Students should submit all requests for reasonable accommodations to NMU 5 Disability Services of?ce; v. Disability Services of?ce uses an interactive process of consulting with the student and conducts an individualized assessment of each student to determine on a case-byncase basis whether and what 4 14. 15. accommodations can be made to allow a student with a disability to participate in and bene?t from the services, programs, and activities at NMU, and to continue to participate to and bene?t from the University 3 services, programs, and activities while receiving treatment for a health .- condition. b. Once the United States approves the policy in accordance with Paragraph 16, NMU will post the policy' In the online version ofNMU?s. Student Handbook and' 111 all subsequent versions Student Handbook for the term of this Agreement. NMU will also post the policy at hm nmu edit/policies and hit, til. . eduldtervicesihornew page star the term of this Agreement. Polio Relatin to Student Sci - estruotive Behavior. While a. public entity may impose legitimate safety requirements necessary for the safe operation of its services, programs, or activities, the public entity must ensure that its'safety requirements are based on actual- risks, not on more speculation, stereotypes, or generalizations about individuals with disabilities. See 28 C.F.R. Within ten (10) calendar days, NMU will remove its Policy Relating to Student Self?Destructive Behavior from and any other websites, handbooks, and other locations where the policy is located or referenced, Any new proposed policy relating to student self-destructive behavior during the duration of this Agreement must be provided to the United States in accordance with Paragraph 16 of this Agreement, below. Withdrawal Policies, Practices and Procedures. NMU will revise its withdrawal policies, practices, and procedures to bring them into compliance with the requirements of Title lI . and its implementing regulation. NMU will refrain from using any withdrawal policy, practice, procedure, or document that discriminates on the basis ofd1sab111ty "Speci?cally, NMU. will: Within ninety (90) calendar days, revise its Voluntary Withdrawal Policy to include: i. The length ofvolantary withdrawals and any conditions for - team will be based on an individualized assessment of each student and the best available medical evidence, with carefitl consideration given to the opinions and recommendations of the student?s treating physician or mental. health professional, if available; ii. Any student who takes a voluntary withdrawal for a set length of time orwith set conditions for return they seek early retum from, or an extension of, the set length of time, or a change in the conditions for return. This request will be considered shot an individualized assessment of the student and appropriate medical evidence, as described above; If NMU requires a student who seeks to return from a voluntary 15. 17. 18. withdrawal to submit medical infonnation,it will be in the fonn of the Treat-incur Provider-Fons, attached as Attachment and iv. Any student whose request to return item a voluntary - withdrawal is denied (1) will receive a detailed written explanation of - decision not to allow the student to return, and (2) may appeal the denial of return The policy will describe the appeals process for students who wish to make such appeal 1). Once the United States approVes the revised Voluntary Withdrawal - . Policy in accordance with Paragraph 16, Defendants will post the policies in the online version ofNMU?s Student Handbook and in all subsequent- versions of Student Handbook for the term of this Agreement. will also post the policy at 11111-11 w. nmu eds! ninjas for the term of this Agreement. Development and Adoption of Policies. Upon the creation or revision of any policy, procedure, or document resulting ?'om Paragraphs 12-15, NMU will provide a copy of such policy, procedure, or document to the United States for its approval The United States may provide changes to thepolicies or other documents when necessary ,to- bring the policies or'documents into-compliance with the ADA. NMU will adopt any changes to the policies and prodedures made by the United States and will implement the revised . policies-for the term of this Agreement. Dean of Students? Wehpage. Within ten (1 0) calendar days, NMU will modify the portion of the Dean of Students webpage (hrt edit dsof) dedicated to ?Behavioral Concerns. Speci?cally, NMU will replace the tenn ?behavioral concerns? . with the term ?conduct concernsi? on the Dean of Students? webpage and the accompanying form if: n. edtiidsotnodej . To the extent that NMU students, staff, faculty, or comrnunity members contact the Dean of Students of?ce to report concerns about a student? 5 self? ~harming behavior during the term of this Agreement, the Dean of Student (or designee) will do an individualized assessment of the - student in order to evaluate actual risk before taking any action against the student. As part of this individualized assessment, the Dean of Students?(or designee) will consider such factors as the source and content of the information received, whether that information l5 reliable, and whether it is indicative of suf?cient risk to justify further investigation by the University. Training. Within .siitty (60) calendar days, NMU will develop a training program (ADA Training) that will be provided to the individuals identi?ed 1n this paragraph within ninety (90) calendar days. NMU will provide ADA training to: the Assistant Vice President/Dean of Students and the Associate Dean of Students; (2) all Counseling and Consultation Services staff; (3)111 faculty and staff responsible for receiving, evaluating, andior deci-ding'requesrs from students for reasonable accommodations; and (4) all faculty and staff responsible for receiving, evaluating, and or deciding requests ?'om students to withdraw from NMU for physical or mental health reasons and/or requests to return from such withdrawals. . a. The ADA Training will address: i. the requirements of Title 11 of the ADA, with a focus on mental health discrimination' in the post-secondary education context,- ii. a general overview of the terms and obligations of this Agreement (NMU will provide a cepy of this Agreement to each training participant); nondiscrimination obligations under Title II ofthe ADA, including speci?cally the obligations outlined in Paragraph 11 of this . Agreement as Well as the policy changes outlined 111 Paragraphs 12- I 5 of this Agreement. b, - The ADA Training will be conducted by an individual or individuals with substantive legal knowledge of the ADA and who ls/are not an employee(s) of NMU The ADA Training will be conducted live, with a group opportunity to pose questions to the individual(s) conducting the training at the conclusion of the training session. . c. For persons who must receive ADA Training pursuant to this Agreement, but who did not receive training on the designated training data required under this Agreement (for instance, because they Were on leave from NW or because they began their affiliation with NMU subsequent to the training date), NMU will provide the ADA Training to such persons within sixty (60) calendar days'a?er the individual's af?liation with NMU in a position covered bythe ADA Training - or within sixty (60} calendar days of their return to NMU (farinstance, from leave). Any training provided under this subparagraph may either be provided live or via a video recording ot?a previous 1ch session of theADA Training. If . - the ADA Training is provided via a video recording, the trainer(s)l meeting the requirements of the immediately preceding subparagraph will be accessible to directly answer any questions a participant may have after viewing the video presentation. 11. NW will send the United States the proposed curriculum for the training, as well as the name(s), quali?cations (including and contact information of the individual(s) who will conduct the training, within forty-?ve (45) calendar days. NMU will incorporate the United States proposed changes to the training curriculum . e. For each session of the ADA Training conductedunder this Agreement (including for each instance of the ADA Training conducted on a'n?onndesignated training date pursuant to subsection of this paragraph}, NMU will maintain attendance logs re?ecting the date of the training, names and titles of attendees, and the attendees signature-s1 . . . l9. Eerie?nine- a. Initial Report: in ninety (90} calendar days, NMU will submit a repair tothe United States Con?rming its implementation of the policies referenced' in Paragraphs 12-15, as Well as its fulfilment to that date of the training requirements to date in Paragraph 13 NMU will provide the United States with copies of the ADA Training attendance logs maintained to date pursuant to Paragraph 18(6). b. . Subsequent Reports: Every six (6) months, NMU will submit a report to the United States regarding its compliance with the Agreement This report will include for the period sribsequent to its immediate prior report to the United States, the following: i. All dates of any ADA Trainings conductedpursuant to this Agreement; ii. Copies of all attendance logs from any and all ADA Trainings conducted pursuant to this Agreement; Its continued ful?llment of the publication obligations. of Paragraph 1245; and iv? Copies of any written explanations NMU provided to students pursuant to Paragraph l4(a)(iv). - 0 Immediate Reports: During the term ofthis Agreement, NMU will notify the United States within ten (1 0) calendar days s: i. Decision to inVoluntarily withdraw any student for reasons. Such noti?cation shall include all documents (including, but not limited to, internal and external email correspondence) relating to the decision. ii. Knowledge of any lawsuit, complaint, charge, or other allegation that NMU has engaged in disability-based discrimination andz?or?violated the ADA. Such notice will include, at a'minirnum, a description of the nature of the allegation,' the name(s} of the individual(s) bringing the allegation, and all documentation posseSsed by NMU relevant to the ailegation, V. MONETARY DAMAGES TO AGGRIEVED PERSONS 20. Within thirty (30) calendar days of receipt of the completed releases attached hereto as Attachment and receipt of completed IRS Form. Ww9?s for each individual NMU a green to pay a total of one hundred seventy-?three thousand ?ve hundred dollars ($173,500) in damages to the aggrieved persona identi?ed by the United States in Attachment C. NMU will make these payments in the amounts Speci?ed in Attachment 8 22. 23. 24. 26. by checks made payable to the aggrieved persons in their full legal names as identi?ed in the completed versions of Attachment NMU will deliver these. checks by overnight mail to counsel for the United States. VI. IMPLEMENTATEON AND ENFORCEMENT The United States may review compliance with this Agreement at any time. NMU agrees to cooperate with the United States 111 any review of compliance with this Agreement Upon reason able notice, NMU will permit counsel for the United States to inspect all non-privileged records pertinent to this Agreement The Parties will endeavor-111 good faith to resolve informally any differences regarding - interpretationof or compliance. With this Agreement prior to initiating court action. If the United States believes that NMU has failed to perform to a timely manner any act required by this Agreement, or has otherwise not acted to conformance with any. provision thereof, whether intentionally or not, the United States will notify tn . writing of its concerns. NMU will have thirty (30) calendar days from the date of the - United States? notification to cure the breach. If the Parties are unable to reach a resolution within thirty (30) calendar days, the United States may ?le a lawsuit for breach of this Agreement, or any provision thereof,? in the United States District Court for the District of Western Michigan. In any such action, NMU consents to and agrees not to contest the exercise of Jurisdiction over it by this Court NMU ?rrther acknowledges that venue in this Court to appropriate and agree not to raise any challenge on this basis. in the eirent the United States ?les a civil action as contemplated by Paragraph .23, above; to remedy breach of this Agreement, the United States may seek, and the Court may grant as relief, the following: (1) an order mandating speci?c performance of any term or provision in thisAgreement, without regard to whether monetary relief would be . adequate; and (2) any additional [relief that may be authorized by law or equity. If such civil action is ?led, NMU expressly agrees not to count the time during which this Agreement is in place, or use the terms or existence of this Agreement, to plead, argue, or otherwise raise statute of limitations, estoppel, or lashes as defenses. . Failure by the United States to enforce any provision of this Agreement will not operate as a waiver of the United States? right or ability to enforce any provision of this Agreement. v11. nonarron. EXECUTION AND rooms The effective date of this Agreement is the date of the last signature below. . All durations speci?ed in this Agreement run from the effective date of this Agreement unless otherwise indicated. ?27. 2a 29. 7311. - 3l.? 32. 33. '34. 35. This Agreement may be executed. in multiple .1: ounterparts, each of which together will be considered an original but all of which will constitute one agreement. Facsimiies of signatures and electronically transmitted signatures will constitute acceptable, binding signatures for purposes of this Agreement This Agreement will remain in effect for three (3) years. This Agreement and the attachments hereto constitute the complete agreement between i the Parties on the matters raised herein. No prior or contemporaneous communications, - either written more], or prior dra?s will be relevant or admissible for purposes of determining the meaning of any provision herein or in any other proceeding. The undersigned represent and warrant that they are fully authorized to execute this Agreement on behalf of the entities indicated below. This Agreement is governed by and will be interpreted under the laws of the United States For purposes of construing or interpreting this Agreement, it will be deemed to have been drafted by all Parties and will not be construed or interpreted against any party for that reason in any subsequent dispute. Except where this Agreement expressly conditions or predicates perfonnance of a duty or obligation upon the performance or" a duty or obligation by another party, the performance of one party duties or obligations under this Agreement will not be discharged or excused by the actual or alleged breach of the duties and obligations by another party. Should any provision of this Agreement be declared or determined by. any court to be illegal or invalid, the Validity of the remaining parts, terms or provisions will not be affected thereby and said illegal or invalid part, term or provision will be deemed not to be a part of this Agreement. The Parties agree that they will defend this Agreement against any challenge by any third party. In the event that this Agreement or any of" 1ts terms are challenged by. a third party in a court other than the United States District Court for the Western District of Michigan the Parties agree that they will seek removal andfor transfer to the United States District Court for the Western District of Michigan This Agreement may be modi?ed only with the written consent of the Parties. Any modi?cation must be 1n writing and signed by the Parties through their authorized representatives. l?i. 36,- This Agreement is not intended to remedy any other potential violations of the ADA or any other law that is not speci?cally addressed in this Agreement. Nothing in this Agreement changes obligation to otherwise comply with the requirements of the ADA. AGREED AND CONSENTED TO: FOR THE UNITED STATES OF AMERICA: ANDREW B. BIRGE United States Attorney Western District of Michigan COBB Chief, Civil Division PO. Box 208 Grand Rapids, MI 4950] (616) 808?2031 (tel) (616) 455-2510 (fax) rvaneobb?ilusdoigov DatedVice President i?or Finance and Administration 1401 Presque Isle Ave. ll JOHN M. GORE . . Acting Assistant Attorney General Civil Rights Division ALBERTO RUISANCHEZ Acting Deputy Assistant Attorney General Civil Rights Division AM, im 01.1,qu pixel/cow REBECCA B. BOND Chief . KATHLEEN P. WOLFE. Special Litigation Counsel ROBERTA Special Legal Counsel ERIN MEEHAN RICHMOND Trial Attorney Disability Rights Section Civil Rights Division US. Department of Justice 950 Avenue, N.W. Washington, D.C. 20530 (202) 307-0385 Dated: Iz/zets Marquette, MI 49355 {906) 227-1000 Dated: m- Attachment A TREATMENT PROVIDER FORM Dear Provider: You have been asked to complete this form as part of the process by which students returning from extended time awayr from. campus are transitioned baolc into the university We want to ensure that students are able to participate in Northern Michigan University 3 campus community; with or without reasonable accommodations, and that we put in . place all that Is necessary to help students be sueCess?xl. Your assessment and recommendations are an integral part ofthis process Please contact the . at If you have any questions or concerns Please mail completed forms to: . or fax to our con?dential fax line - .. PART 1: To an comm-ran or srooaNT Name of student: Class year: Date of withdrawal: . . Application to be Reinstated to: a Fall Winter Summer Year: Undergraduate college/Graduate department: Provider(s) seen since withdrawal: I hearby authorize to obtain information from the treatment provider listed below for the - purposes of evaluating my request to return to NMU. I understand that this authorization Is voluntary and I may refuse to sign it This authorization will expire 180 days from the date on . which I sign it. I understand that I may revoke this authorization at any time by providing written notice to . Signature: i - Date: TART 11: To an COMPLETEDBY TREATMENT rnowonn - Name of Provider: Degree: . - Address: City: State: -. Telephone: . Fax: - . . Email: . 1 Please describe the delete) beginning and end of treatment, and frequency) and type(s) of treatment provided . 2. Do you have concerns about the student' 3 capacity to carry out substantial self?care obligations? . :1 No Concerns :1 Minor concerns in Moderate? concerns 1:1 Student l3 unable or unwilling to carry out substantial self-care obligations If you have indicated moderate concerns or believe that the student is unable or unwilling to carry out substantial self-care obligations, please captain below, including any recommendations on mitigating such concerns: . 2 {In} Do you have concerns about the student as it pertains to his or her personal safety? No concerns 1:1 Minor concerns :1 Moderate concerns :1 Student presents an actual risk of serious self-harm If you have indicated moderate concerns or you believe the student orcsents an actnai risk of serious self-harm, please explain below, including any recommendations on mitigating such- concerns: 2. Do you hat/e concerns about the student as it pertains to the safety of others? 1:1 No concerns Minor concerns :1 Moderate concerns 1:1 Student poses a signi?cant risk to the safety of others is. If'you have indicated moderate concerns or you-Believe the smclent poses a signi?cant risk to 'the .. safety of o?hers, please explain below, including any recommendations en mitigating such - concerns: - - 3. Please tell us if continuing treatment is recommended upon. return to school. (Be sure to Specify the type, frequency and duration of care you recommend, and the or functional . dif?culties that err-going treatment may need to address.) Dated: 1-5. Attachment RELEASE OF CLAIMS In consideration of the relief offered by Northern Michigan University (NMU) pursuant to the Settlement Agreement between the United States of America and NMU arising out of_ Department of Justice Investigation No 204-38- 127: I hereby release and forever discharge NMU from any legal and/or equitable claims arising out of the facts identi?ed in the Settlement Agreement related to Department of Justice investigation No. 204-3 8-127. As a result, Iagree and promise that I will not file any suit, charge, complaint, proceeding or action at law, in equity, or otherwise in any court, or any other judicial or administrative forum against NMU arising out of the facts identi?ed in the Settlement Agreement related to Department cf Justice Investigation No 204?38- 127. Excluded from this Release are any rights and claims that cannot be waived by law. . . This Release constitutes the entire agteement between me and NMU, without exception or exclusion. I acknowledge that a copy of the Settlement Agreement has been made aVailable to me. By signing this Release, I acknowledge that I have been provided the opportunity to review the same with an attcmey of my cheesing, This Release will be considered null and void in the event that NMU 'fail's to deli-var to the individual identi?ed In the Settlement Agreement a check made payable to me in the amount Specified' 1n the Settlement Agreement within ten (10) business days of Its receipt of this signed Release of Claims. I HAVE READ THIS RELEASE AND UNDERSTAND THE CONTENTS THEREOF AND I EXECUTE THIS RELEASE OF MY OWN FREE ACT AND DEED- Signature Print Name Date: Iii" Student A: $78,500 Student B: $50,000 Student C: 25,000 Student D: $20,000 ATTACHMENT 0