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UNITED STATE DISTRICT COURT

FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

Roshni D. Thackurdeen, and Raj B.
Thackurdeen, individually and in their
capacity as Co-Administrators of the Estate
of RAVI THACKURDEEN, Case No. 1:16CV01108
Plaintiffs,
vs.
DUKE UNIVERSITY, a North Carolina
corporation; ORGANIZATION FOR
TROPICAL STUDIES, INC., a North
Carolina corporation; and DOES 1-20,
Defendants.

ANSWER OF DEFENDANT DUKE UNIVERSITY

NOW COMES a Defendant in the above-captioned matter, DUKE UNIVERSITY,

incorrectly sued as Duke University, a North Carolina Corporation, pursuant to

Fed.R.Civ.P. Rule 12 and, answering the Complaint of the Plaintiffs, alleges and states

that:

FIRST DEFENSE TO ALL CLAIMS FOR RELIEF

THE PARTIES

1. Duke University admits on information and belief that Plaintiffs Roshni D.

Thackurdeen and Raj B. Thackurdeen were, at all times relevant to the Complaint,

citizens and residents of the State of New York, that they are the parents of Ravi

Thackurdeen and that at the time of his death, Ravi Thackurdeen was a citizen and

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resident of the State of New York. Except as stated, Duke University is without

knowledge or information sufficient to form a belief as to the truth or falsity of the

allegations of this paragraph.

2. Duke University admits that at all times relevant to the Complaint it was an

educational institution organized and existing under the laws of the State of North

Carolina and that its principal campus and principal administrative offices are located in

Durham, North Carolina. Except as stated, Duke University denies the allegations of this

paragraph.

3. Duke University admits on information and belief that the Organization for

Tropical Studies, Inc., is a corporation organized and existing under the laws of the State

of North Carolina with its principal place of business in Durham, North Carolina. Except

as stated, Duke University is without knowledge or information sufficient to form a belief

as to the truth or falsity of the allegations of this paragraph.

4. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph except that Duke

University denies that the Plaintiffs have any right to amend the Complaint.

VENUE AND JURISDICTION

5. Duke University admits, on information and belief, that this Court has

jurisdiction under 28 U.S.C. §1332(a)(1) premised upon the existence of diversity in that

the parties appear to be citizens of different States.

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6. Duke University admits that the Plaintiffs have alleged that the damages in

this case exceed seventy-five thousand dollars ($75,000). Except as stated, Duke

University denies the allegations of this paragraph.

7. Duke University denies the allegations of this paragraph.

FACTUAL BACKGROUND

8. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

9. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

10. Duke University admits that, for the Spring Semester of 2012, Ravi

Thackurdeen enrolled in a Duke University administered Global Education Program

organized and operated by the Organization for Tropical Studies (“OTS”), a separate

entity that is separately incorporated and has its own Board of Directors, and that the

successful completion of the course of studies administered by OTS made Ravi

Thackurdeen eligible for credits to be transferred to Thackurdeen’ s college, Swarthmore,

by Duke University. A copy of the application and enrollment forms relating to Ravi

Thackurdeen is attached to this Answer as Exhibit 1. Duke University denies that at any

time Ravi Thackurdeen was admitted as a student to Duke University or was a student at

Duke University. Duke University further admits that OTS is a separate legal entity and

that the relationship between OTS and Duke University is set forth in the Memorandum

of Understanding attached to this Answer as Exhibit 2. Except as stated, Duke

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University is without knowledge or information sufficient to form a belief as to the truth

or falsity of the allegations of this paragraph.

11. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

12. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

13. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

14. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph as to OTS. Duke

University denies the allegations of this paragraph.

15. Duke University denies the allegations of this paragraph.

16. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

17. Duke University admits on information and belief that Ravi Thackurdeen

died on April 29, 2012. Except as stated, Duke University is without knowledge or

information sufficient to form a belief as to the truth or falsity of the allegations of this

paragraph.

18. Duke University admits that the Assistant Vice Provost for Duke

University’s Global Education Program, once advised by OTS employees that Ravi

Thackurdeen was missing in Costa Rica, telephoned from Durham and spoke with his

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relatives. 23. informed them that Ravi Thackurdeen was missing in the ocean at that time. Duke University denies that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen’s death. Duke University denies the allegations of this paragraph. accompanied by OTS employees. Duke University denies the allegations of this paragraph. Duke University denies that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen’s death. Duke University admits on information and belief that. and provided them with direct contact information for OTS employees in Costa Rica. the Thackurdeens were taken to the area in Costa Rica where Ravi Thackurdeen was last seen. Except as stated. Except as stated. 19. Except as stated Duke University is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegations of this paragraph. 2012. 20. Duke University admits that the Thackurdeens made arrangements to travel to Costa Rica. 21. Except as stated Duke University is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegations of this paragraph. 5 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 5 of 15 . Duke University denies that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen’s death. Duke University admits on information and belief that Ravi Thackurdeen’s body was found on May 1. Except as stated Duke University is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegations of this paragraph. 22.

Except as stated. Duke University denies the allegations of this paragraph and adopts by reference and incorporates Exhibit 1 and Exhibit 2. 25. Duke University adopts by reference and incorporates Exhibit 1 and Exhibit 2. Duke University further admits that the acknowledgements and waivers set forth in Exhibits 3 and 4 were conditions precedent to consideration for acceptance by OTS into its educational programs. 24. Duke University admits that it recognized and warned the Plaintiffs. of the risks of international travel and that the Plaintiffs. including Ravi Thackurdeen. Duke University denies that it “promoted its OTS program” and otherwise denies that it is anything other than a separate entity from OTS. including Ravi Thackurdeen. 29. Duke University adopts 6 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 6 of 15 . acknowledged those risks (including death) as set forth in Exhibits 3 and 4. indemnified and discharged Duke University from all liability arising from death or personal injury. Duke University admits the allegations of this paragraph on information and belief. 28. 27. Duke University denies the allegations of this paragraph. 26. and further released Duke University from any liability whatsoever and otherwise released. Duke University admits the allegations of this paragraph on information and belief. Duke University further admits that it has formed oversight committees and otherwise acted in a reasonable fashion to address the opportunities and risks of international travel. Duke University denies the allegations of this paragraph.

Duke University adopts by reference and incorporates the contents of Exhibit 1 and Exhibit 2. Duke University denies that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen’ s death and otherwise denies that it is anything other than a separate entity from OTS. Except as stated. but are argument and thus improper. 33. 32. Duke University denies the allegations of this paragraph. Duke University denies the allegations of this paragraph as applied to the factual circumstances of this Complaint. 30.by reference and incorporates the contents of Exhibit 1 and Exhibit 2. 35. 31. Duke University is without knowledge or information sufficient to form a belief as to the truth or falsity of the allegations of this paragraph. Duke University admits on information and belief the allegations of this paragraph. Duke University admits that it has experience with international programs and has a deep commitment to the safety of its students. Duke University denies the allegations of this paragraph on the grounds that these are not allegations of fact made to support a claim for relief. Duke University denies that it “allowed Ravi to die in the waters of Costa Rica” or that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen’ s death. Except as stated. Duke University denies the allegations of this paragraph. Except as stated. Duke University denies the allegations of this paragraph. 7 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 7 of 15 . 34.

Except as stated. and other common causes of drowning.” Duke University is without knowledge or information sufficient to form a belief as to the truth or falsity of that allegation. to the extent that the Complaint alleges that Ravi Thackurdeen as a “weak or non-swimmer[ ]. 39. 38. Duke University admits on information and belief that drownings occur in the waters off of Costa Rica and that many involve rip tides. Duke University denies the allegations of this paragraph. including Ravi Thackurdeen. Duke University denies the allegations of this paragraph. Duke University denies the allegations of this paragraph. 40. and that these warnings were communicated to Ravi Thackurdeen by OTS employees and others. 36. Duke University admits on information and belief that warnings and cautions about swimming in the waters of Costa Rica are “abundant” and were available to all. Duke University denies the allegations of this paragraph. 41. Duke University denies the allegations of this paragraph as applied to the factual circumstances of this Complaint except that. and that the overall incidence of drowning in Costa Rica as a function of the number of swimmers and swimming episodes is small and not statistically different than many beaches in the United States of America. Duke University denies the allegations of this paragraph. 8 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 8 of 15 . rip currents. Duke University denies the allegations of this paragraph. 42. 37. Except as stated.

Duke University denies the allegations of this paragraph. THRID CLAIM FOR RELIEF INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 9 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 9 of 15 . 49. Duke University denies the allegations of this paragraph and each subpart thereof. 44. FIRST CLAIM FOR RELIEF SURVIVAL CLAIM BASED ON NEGLIGENCE 43. Duke University denies the allegations of this paragraph. Duke University denies the allegations of this paragraph. Duke University adopts by reference and incorporates its response to each allegation of the Complaint. 45. 47. Duke University adopts by reference and incorporates its response to each allegation of the Complaint. Duke University denies the allegations of this paragraph. 51. Duke University denies the allegations of this paragraph. 52. 48. Duke University denies the allegations of this paragraph. 46. Duke University denies the allegations of this paragraph. 53. SECOND CLAIM FOR RELIEF WRONGFUL DEATH 50. Duke University denies the allegations of this paragraph.

or agents . WAIVE[ED]. officers. Ravi Thackurdeen and the Plaintiffs: (1) released Duke University from all liability “in damages for any injury or loss to person .” (3) agreed to indemnify and hold harmless Duke University from negligence or the negligence of any third party. and each cause of action set forth in the Complaint. executed by Ravi Thackurdeen and the Plaintiffs. Duke University denies the allegations of this paragraph. . Duke University denies the allegations of this paragraph. AND COVENANT[ED] NOT TO SUE . and participation in this activity. is and are barred by the releases set forth in Exhibit 3 and 4. 57. . as a result of my traveling to and from.” (2) “RELEASE[ED]. Duke University. WAIVER AND DISCHARGE The Complaint. DISCHARGE[ED]. . including death . and we hereby release Duke University. 59. for any liability. its trustees. . Duke University denies the allegations of this paragraph. officers agents and employees from any liability whatsoever for personal injury or property damage arising from participation in the program. . damage. Duke University denies the allegations of this paragraph. and 10 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 10 of 15 . Specifically. 60. Duke University denies the allegations of this paragraph. Duke University denies the allegations of this paragraph. . 54. Duke University adopts by reference and incorporates its response to each allegation of the Complaint. 55. . claim. or injury. its trustees. SECOND DEFENSE: RELEASE. employees. 56. and/or cause of action arising out of or related to any loss. . 58. in two separate releases.

WAIVER. Duke University specifically pleads this defense as a bar to the claims of the THIRD CLAIM FOR RELIEF. discharges and covenants not to sue were conditions precedent to consideration for admission to the OTS program. in a manner that increased the risk to him. and failed to take into account his limitations as a swimmer. waivers. In addition. and my heirs. THIRD DEFENSE: CONTRIBUTORY NEGLIGENCE The claims set forth in the First and Second Claims for Relief are barred by Ravi Thackurdeen’s failure to exercise reasonable care and that this failure contributed to his death.(4) agreed to release Duke University from any liability from any injuries arising out of a deviation from the activities. 11 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 11 of 15 . and otherwise failed to act as would a reasonable person under the same or similar circumstances. To the extent that the THIRD CLAIM FOR RELIEF is premised on alleged actions or omissions that occurred before or in connection with the death of Ravi Thackurdeen. Ravi Thackurdeen and the Plaintiffs further expressed the written intent that these releases “shall bind the members of my family .” Execution of these releases. . DISCHARGE. Specifically. and shall be deemed as a RELEASE. assigns and personal representatives. Thackurdeen failed to exercise reasonable care in swimming at a time and in a place where he was aware that there were potential dangers. . if I am deceased. Thackurdeen failed to follow the instructions that he had been given concerning the currents. and COVENANT NOT TO SUE.

the allegations for such damages as set forth in the Complaint fail to state a claim upon which relief may be granted under N. Duke University specifically pleads this defense as a bar to the claims of the THIRD CLAIM FOR RELIEF.G. FIFTH DEFENSE: STATUTE OF LIMITATIONS The claims set forth in the Complaint are barred by the applicable statutes of limitations.C. SIXTH DEFENSE: PUNITIVE DAMAGES To the extent that the Plaintiffs seek an award of punitive damages. In support of this FOURTH DEFENSE.C.S.S. Rule 12(b)(6). in the materials attached as Exhibits 3 and 4. Chapter 1D.R. §§1-52 and 1-53.Civ. FOURTH DEFENSE: ASSUMPTION OF RISK The claims set forth in the First and Second Claims for Relief are barred by Ravi Thackurdeen’s assumption of the risks of the activity. this defense is interposed pursuant to Fed. 12 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 12 of 15 .G. Thackurdeen and his parents both acknowledged and stated that “by participating in this activity I will ASSUME THE RISK of injury and damage from risks and dangers that are inherent in any activity.P. N. Duke University adopts by reference and incorporates the matters set forth in its THIRD DEFENSE. In addition.” To the extent that the THIRD CLAIM FOR RELIEF is premised on alleged actions or omissions that occurred before or in connection with the death of Ravi Thackurdeen.

CIV.P. WHEREFORE. 13 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 13 of 15 . This court order such further relief as it deems just and appropriate. 4. The Plaintiffs have and recover nothing. RULE 4(m) Pursuant to Fed. Rules 12(b)(4) and 12(b)(5).R.P. Duke University prays that: 1. having fully answered the Complaint of the Plaintiffs. The costs of this action be taxed against the Plaintiffs.P. The claims of the Plaintiffs be dismissed or otherwise barred pursuant to the defenses set forth in this Answer.Civ.R. the Plaintiffs failed to serve a valid summons within the time prescribed by Rule 4(m). 2. SEVENTH DEFENSE: FAILURE TO COMPLY WITH FED. To the extent that this Plaintiffs’ failure to serve a valid summons within the time prescribed by Rule 4(m) makes process insufficient.Civ. Duke University further pleads insufficiency of process and service of process as defenses pursuant to Fed. Rule 4(m).R. 3.

331. /s/ James P.C. Cooney III James P.C. NC 28202-6037 Telephone: 704. State Bar #12140 Marcey R. Cooney III N. a North Carolina Corporation 14 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 14 of 15 . Suite 3500 301 South College Street Charlotte. State Bar #22298 WOMBLE CARLYLE SANDRIDGE & RICE. Selle N.7838 E-Mail: jcooney@wcsr.com E-Mail: mselle@wcsr. This 24th day of February 2017. LLP One Wells Fargo Center.com Attorneys for Defendant Duke University. incorrectly sued as Duke University.4980 Facsimile: 704.338.

MCLENDON. Phillips rphillips@brookspierce. PIERCE. Esq. PLLC GERAGOS & GERAGOS. HUMPHREY & LEONARD.com tina@geragos. Esq. III Tina Glandian.com Jessica E. 2017. Roberts. Cooney III Attorney for Defendant Duke University. incorrectly sued as Duke University. Cooney III James P. I electronically filed the foregoing ANSWER with the Clerk of Court using the CM/ECF System.com BROOKS.1 Counsel Attorneys for Plaintiffs for Plaintiffs Reid L. Inc. NC 27619-7529 Los Angeles. a North Carolina Corporation 15 WCSR 38442254v1 Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 15 of 15 . which will send notification of such filing to the following: James A. /s/ James P.O. jar@lewis-roberts. CA 90017 Local Civil Rule 83. APC P.com William Michael Dowling mdowling@brookspierce. CERTIFICATE OF SERVICE I hereby certify that on the 24th day of February. LLP 2000 Renaissance Plaza 230 North Elm Street Greensboro. NC 27401 Attorneys for Defendant Organization for Tropical Studies. Bowers Ben Meiselas.com LEWIS & ROBERTS. Box 17529 644 S. Figueroa Street Raleigh. jeb@lewis-roberts.com meiselas@geragos.

EXHIBIT 1 Application and Enrollment Form Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 1 of 24 .

S._...cftn?FuseAction7-StudentAdmin.edu/index..Ravi Thackurdeen ..._--....aas. _.duke.edu SMS Email Address: CC Email Address: Home institution SWARTHMORE COLLEGE Custom Parameters Nickname: Ray Country of Birth: United States of America State/Province of Birth: NY City of Birth: Long Island U..._..__ .. Page 1 of 10 DUKE UUIVERSIr ._.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 2 of 24 ...... .. _.. _........ _.<B>OTS/Global Health ® Tropical Medicine and Public Health</B> ®. 0 Gl ob al Education _.._..__.. Created: 04/20/2011 (by Applicant) Last Updated: 01/09/2012 @ 09:23:16 AM Last Viewed by Applicant: 01/08/2012 ID# 11528:no label Applicant Information Gender: M Date of Birth: 06/06/1992 Confidentiality Flag: Email Address: rthacku2@swarthmore._.._._____ Off ie I(Nl U[gUtA 14AptlA0:!. Citizenship Status: US Citizen Country of Citizenship: USA Country of Citizenship Code: I Are you Hispanic or Latino?: No Ethnicity: I choose not to reply Second Citizenship: Duke Student ID Number: rl •• 1 ~ Major: https://borodin .__— _..._...

cfm?FuseAction=StudentAdmin.(8457844499 Parent I Address: 15 Anchor Drive Newburgh. NY 12550 I United States 8457844499 Addressee Name: Raj Thackurdeen Relationship: Father https://borodin.75 AM (Current) 04/20/2011 t@ a 02:12:48 3..PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 3 of 24 .Tropical Medicine and Public Health</B> -.75 i Date: Value(s): 06/04/2011 @ 09:38:56 3.duke.Ravi Thackurdeen .edu/index.<B>OTS/Global Health . Home Address: 5 Anchor Drive Newburgh.aas.67 PM Class of 2014 Sophomore 9176587207 2011-2012 Spring 2012 512 S12 Yes Addresses on File: Campus Address: Address not on file.. Page 2 of 10 3. NY 12550 f United States .

Comments Responses for "General Application" Instructions: In addition to this questionnaire.duke.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 4 of 24 .co m 4. NY 12550 United States 8457844499 Program & Term Program: OTS/Global Health . 1.aas. Parent/Guardian I E-mail fo p936@ao l.Tropical Medicine and Public Health</B> Page 3 of 10 United States 1 8457844499 I Addressee Name: Roshni Thackurdeen Relationship: Mother Mailing Address: 5 Anchor Drive Newburgh. please make sure to complete the "Additional Information" and "Addresses" sections on your applicant homepage so that we will have all the necessary information for processing your application. Parent/Guardian I Fir st Name Rai 2. DUKE STUDENTS: Upon submission of the General Application questionnaire the GEO-U will conduct a check of your academic and disciplinary record to determine study abroad eligibility.Tropical Medicine and Public Health (San Jose) Term: Spring. Parent/Guardian 2 First N ame ^~ https://borodin. 2012 Application Status Status : I Enrolled Decision Date: 02/08/2011 (This date is specific to this program.edu/index. Pa rent/G ua rdia n I Last Name Thackurdeen 3.<B>OTS/Global Health .) Application Comments CommenterDate. Ravi Thackurdeen .cfm?FuseAction=StudentAdmin.

Duke students do not need to answer this question. 1. Study Abroad Advisor E-mail pmartinl©swarthmore. good.edulindex. Please list your native or first language. Prof.Intermediate Spanish for Advanced Beginners. (Example: PubPol 166 . Summer 2010 Trinidad & Tobago Puerto Rico Dominican Republic Germany Austria Bulgaria https://borodin.Intensive Spanish for Advanced Beginners (Prof. studied. If you have lived. Olga Ferrer 13. including number of years of study and your level of speaking. apply for one immediately. If your current major is undeclared. and instructor. Prof. 1 credit.edu ).. Olga Ferrer. what is your intended major? Biology 14. Do you currently have a valid passport? If you do not yet have a passport. I have current permission to enter into SPAN 002 B .The Insurgent South.Health. Parent/Guardian 2 E-mail rthackur@aoLcom 7. an instruction course with an accompanied drill session. excellent.cfm ?FuseAction=StudentAdmin. Prof. equivalent to Duke's Spanish 14. Additional languages Please list any additional languages you speak. Study Abroad Advisor Phone 6103288451 10. & Illness. Current courses Please list your current courses in progress including the course title. expected credit. or traveled in a foreign country. I have traveled to the following places: Grenada.duke. Parent/Guardian 2 Last Name Thackurdeen 6.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 5 of 24 . fair. 1 credit. I credit. Culture. 12.osendral@swarthmore. Professor Korstad) CHEM 32 .. 1 credit. English 11. At the time of entrance into the program. I will have the equivalent of two semesters of college level Spanish instruction. Page 4 of 10 I Roshni 8.aas.5 credits. Summer 2010 Scotland.Ravi Thackurdeen .Organic Chemistry II. Patricia Martin 8. Christine Schuetze SPAN 2B .edu 9. Study Abroad Advisor If you are a non-Duke student. Carl Grossman SOAN 43E . reading and writing. comprehension. Please use the following scale: poor. Robert Paley PHYS 3 General Physics 1. January 2011 Canada. Prof. state where and when.<B>OTS/Global Health Tropical Medicine and Public Health</B> -. please enter the name of your study abroad advisor at your institution. Passport processing can take 6-8 weeks or more. YES 15.

and that would mean the constant visuals of her little child distraught with what seemed the worst of earaches.Tropical Medicine and Public Health<B> -. 1968. What past doctors once called "bush-medicine. Ravi Thackurdeen . so I told my mother every day. After steeping and cooling. The very same concoction my mother brewed for me eighteen years ago. and even prescribed by integrative physicians. and phone number t o other interested Duke p a rties or fel l o w p rogram students? YES 18.<B>OTS/Global Health .. Page 5 of 10 16. em ail. With the garlic paste removed. For colic. For colds. Contact List May the Global Education Office for Undergraduates at Duke University release your name. I laid clutching a blanket and my ears eighteen years ago. whilst the insides turned to a pungent slurry. Will you be participating in Duke Engage in conjunction with your study abroad? (Duke Students Only) If you answer yes. She knew what she had to do. address. he prescribed garlic and olive oil. It seemed to recall her very own experiences with earaches. there was elderberiy extract. Personal Statement Drenched with creeks of tears meandering about the cheeks of my grimaced face. please describe your Duke Engage p roject. A skewered garlic roasted as my mother slowly turned it over the stove. After shadowing an ~ i integrative pediatrician at Bambini Pediatrics. she reciprocated with her childhood experiences of the same nature. https://borodin . and she reverted to her childhood memories back in Trinidad. of all things. I was shocked by the prescriptions he handed out. making the outside charred. We sat for the next two hours discussing the ethnomedicine of Trinidad. When I told my mother about the garlic and olive oil. relief was poured into my ears.cfm?FuseAction=StudentAdmin. Non-Duke students s ho uld select "No" NO 17.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 6 of 24 . and my grandmother brewed for her back in a third world country in the nineteen-sixties.edu/index. And for earaches.aas. she blended it into in a ladle of olive oil. there was probiotics and gripe water.duke. H ow d id you hear about Duke Global Education ? Professor Instructions: 1.. 1 It was an experience I did not recall until I was reminded this past summer. My mother knew the antibiotics would not be ready until the next day." this cultural wisdom to treat illnesses has become legitimatized through research.

The experience. Responses for "Family Assignment Form" https://borodin. I would like to embrace the knowledge passed down over generations and explore the potential for integration into modern medicine.<B>OTS/Global Health . Despite this track record of maintaining a population without today's advances. the experience of the Global Health Semester will provide me an opportunity to begin experiencing my career goal now.duke. I am currently pursuing a degree in Chemistry.cfm?FuseAction=StudentAdmin. After medical school. if effective in treatment. and a background in ethnobotany. At Swarthmore College. I would like to travel throughout Latin America and the Caribbean to preserve the cultural knowledge of locals and indigenous people. I will gain my first experience with the academic view of ethnobotany. the Sociology and Anthropology department also provides insight on the cultural understandings of well-being. Page 6 of 10 However. have not explored by science. 1968.aas. in ethnobotany. I have experienced the practice of ethnobotany first-hand and learned of biology. Shadowing at Bambini Pediatrics made me realize that there are alternatives. disease. they can be legitimized. I wish to pursue a Ph.edu/index. reducing medical expenses. a firm understanding of chemistry. However. but I will not have connected the two in any part of my education until this semester abroad. Generations upon generations have lived without the advances of modern science. and the sheer quantities of resources needed to maintain health. My grandmother and travels to Trinidad connects me to the wisdom held from generations past. and allowing those using ethnomedications to continue to be self- sufficient and healthy. many other idiosyncratic uses of plants. The research can ensure that those using ethnomedications are using them in a safe and effective manner." allowing me to learn of my cultural roots.. such as my mother in Trinidad. In essence.Ravi Thackurdeen . Swarthmore teaches me the modern approach to science: from Cell and Molecular Biology to the larger Organismal and Population Biology. the Global Health Semester is the culmination and tic between all of these experiences.. and healing in the course.D. These people have managed to employ their indigenous knowledge of the surrounding fauna to heal ailments and illnesses in the absence of modern medication. whilst tackling the Pre-Med requirements. Lastly. With a medical degree. By researching ethnomedications. learning of a non-Western approach to health from those who practice it will broaden my understanding of other cultures and will influence my care of others. Health." Casting aside cultural knowledge is something I hold to be profane. whilst academic. much cast aside under the moniker "bush-medicine. and then research the ethnomedications of the peoples for effectiveness. and how it all works through Organic Chemistry.Tropical Medicine and Public Health</B> -. My time as a pharmacy technician assistant at St. with an emphasis on ethnomedicine. Ethnomedications can provide inexpensive and/or easily homemade alternatives to those in need of treatment. their idiosyncratic methods of healing have been left unexplored. preserving knowledge and culture. Culture and Illness. Luke's Cornwall Hospital introduced me to the product of modern medicine. The opportunity to Iearn about public policy will help shape the way I approach the application of research. whether it may be due to poverty or isolation. Throughout the semester. Trinidadian culture included.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 7 of 24 . will also be a "return to home.

aas.edu/index.state. ----------..PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 8 of 24 .<B>OTS/Global Health .gov/passport_services.duke. farming. pet dander and ragweed.cfm?FuseAction=StudentAdmin. Passport Information Is available at: http:/!travel. I would love to do a lot of traveling about the country to experience Costa Rica and Its culture from a native's point of view. Cats I prefer a family that has: No cats 7.Tropical Medicine and Public Health</B> -. allergies. 2. Indigenous medicine. cooking. bike ridi ng. Dogs I prefer a family that has: No dogs 6. Vegetarian I prefer a family that is: Non-veget arian 4. traveling to new places. https://borodin. in which case you should contact the OTS office Immediately. or anything else you deem important for your ho st f amily to know.Ravi Thackurdeen .html. Please include any special requirements. -. Would like to learn Costa Rica n dan ce. Smoking I prefer a fami ly that is: Non-smoking 5. Page 7 of 10 Instructions: Please complete the following information regarding your preferences for your homestay family. c ooking. 1. If you are not a US citizen. then please fill out the information below. swi mming. Responses for "OTS Costa Rica Participant Registration Form" Instructions: All students MUST obtain a passport that is valid for at least six months from the end date of the program. We will do our best to find the right family for you. -.— — —__ 3. Otherwise. music. you may be required to obtain a visa to enter into Costa Rica. If you do have a passport and the expiration date falls within the OTS guidelines. dust. I have asthma that may be triggered by mold. Favorite Weekend Activities Jogging. List some of your i n terests or hobbies.. If you currently do not have a passport and need to apply for one OR need to renew your passport. then please do so immediately) It may be wise to use the expedited service offered by the passport agency to ensure receipt of your passport before the program begins. Additional Comments Please note anything you feel should be taken into consideration as we attempt to find the right family for you..

cr . Place of Birth New York.ac. Ravi Thackurdeen . Passport Number: 1 477523543 8.. Place Issued United States 9. Arrival Date & Time 8:50 PM on January 16. An OTS driver will be at the airport to pick you up.mendeztots.duke. Airline Name & Flight Number I American Airlines Flight 611 7. Some students have chosen to travel in Costa Rica before the start or after the end of the program. please know that you must make your own arrangements for transportation and lodging during this time and that OTS is not responsible for any problems that occur during this time..edulindex.PrintApplieation 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 9 of 24 . Name as It appears on your passport: Ravi Neal Thackurdeen 2. Should you have any logistical questions for the OTS program. Do you have dual citizenship? If you answer "yes" please list your other country of citizenship. After the staff in Costa Rica receives your flight information in Costa Rica. NO 5. Costa Rica (SJO). please contact Kattla Mendez In Costa Rica: kattIa. 1. You should schedule your flights to arrive and depart on the dates indicated indicated in the announcements on your Duke University Studio Abroad account. USA 3. Departure Date & Time This is your departure information for travel from your host country at the end of your program.Page 8 of 10 Flight Reservations: Please make flight reservations to Juan Santamarla International Airport In San José. 2012 16. Citizenship United States 4. https ://borodin. Expiration Date (Month/Day/Year): 03/17/2021 11. To enter Costa Rica you MUST purchase a round-trip ticket. If you decide to include travel plans that are outside of the OTS program dates. Issuing Agency US Department of State 12. Date Issued 03/18/2011 10.aas.cfm?FuseAction=StudentAdmin.<B>OTS/Global Health Tropical Medicine and Public Health/B> .

Swarthmore check #00415391 Material received on https://borodin.aas.Ravi Thacicurdeen <B>OTS/Global Health .. Page 9 of 10 7:50 AM on May 1. Emergency Contact E-mail rthackur@gmail.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 10 of 24 . Emergency Contact Relationship Father 17..duke. 2012 13.cfm ?FuseAetion=StudentAdmin.Tropical Medicine and Public Health</B> . Emergency Contact Daytime Phone 917-843-4870 19.edulindex. Mother's Maiden Name Ramroop 15. NY 12550 United States 18. Departure Airline Name & Flight Number American Airlines Flight 622 14.com Application Materials (Outgoing Program) Pre-decision (Application) Materials: Material Submissions Title Received Notes OTS Approval of Participation Form Received Material received on 05/27/2011 @ 03:24 PM by Kala Wolfe OTS Recommendation Received Material received on 0613012011 @ 12:20 PM by Patricia Kustron Transcript(s) Received Material received on 06130/2011 @ 12:20 PM by Patricia Kustron Post-decision Materials: Material Submissions Title Received Notes Deposit Received $1040. Emergency Contact Name Please list the name of the person we should contact first in case of an emergency. Emergency Contact Evening Phone 917-658-8580 20. Emergency Contact Address 5 Anchor Drive Newburgh. Raj Thackurdeen 16.

.PrintApplication 4/30/2012 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 11 of 24 . https://borodin. Page 10 of 10 Form A: Statement of Authorization and Consent .edu/index.cfm?FuseAction=StudentAdniin.aas.<B>OTS/Global Health .Ravi Thackurdeen .Tropical Medicine and Public Health</B.duke.Spring Received Material received on 11/16/2011 by Jennifer Kelley 4 International Travel Registry OTS Medical Form Received Material received on 12/05/2011 by Kala Wolfe OTS Participation Agreement CR Received Material received on 11/16/2011 by Jennifer Kelley OTS Scholarship Application Received Material received on 11/15/2011 by Jennifer Kelley Scholarship Application form received in OTS on 11/15/11 (J Kelley) Photo Received Material received on 09/13/2011 by Jennifer Kelley Third Party Billing Form Received Option #2 Material received on 09/14/2011 by Joy Searles No recommendations exist..

" this cultural wisdom to treat illnesses has become legitimatized through research. and even prescribed by integrative physicians. When I told my mother about the garlic and olive oil. Ethnomedications can provide inexpensive and/or easily homemade alternatives to those in need of treatment. whilst the insides turned to a pungent slurry. preserving knowledge and culture. 1968. Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 12 of 24 . She knew what she had to do. their idiosyncratic methods of healing have been left unexplored.my cultural roots. many other Idiosyncratic uses of plants. a firm understanding of chemistry. so I told my mother every day. It seemed to recall her very own experiences with earaches. such as my mother In Trinidad. I wish to pursue a Ph. and then research the ethnomedications of the peoples for effectiveness. With a medical degree. I would like to embrace the knowledge passed down over generations and explore the potential for Integration Into modern medicine. My mother knew the antibiotics would not be ready until the next day. Despite this track record of maintaining a population without today's advances. What past doctors once called "bush-medicine. have not explored by science. The very same concoction my mother brewed for me eighteen years ago. and she reverted to her childhood memories back in Trinidad. relief was poured into my ears. For colic. of all things. The experience. With the garlic paste removed. whilst academic. However. And for earaches. and my grandmother brewed for her back In a third world country In the nineteen-sixties. We sat for the next two hours discussing the ethnomedicine of Trinidad. she reciprocated with her childhood experiences of the same nature. with an emphasis on ethnomedicine. The research can ensure that those using ethnomedications are using them In a safe and effective manner. At Swarthmore College. Trinidadian culture included. It was an experience I did not recall until I was reminded this past summer. After medical school. I am currently pursuing a degree in Chemistry. A skewered garlic roasted as my mother slowly turned it over the stove. reducing medical expenses. in ethnobotany." allowing me to learn of . he prescribed garlic and olive oil. there was elderberry extract.D. I laid clutching a blanket and my ears eighteen years ago. she blended It Into In a ladle of olive oil. By researching ethnomedications.Drenched with creeks of tears meandering about the cheeks of my grimaced face. 1968. After shadowing an integrative pediatrician at Bambini Pediatrics. they can be legitimized. and a background In ethnobotany." Casting aside cultural knowledge Is something I hold to be profane. and that would mean the constant visuals of her little child distraught with what seemed the worst of earaches. making the outside charred. there was problotics and gripe water. I was shocked by the prescriptions he handed out. After steeping and cooling. will also be a "return to home. I would like to travel throughout Latin America and the Caribbean to preserve the cultural knowledge of locals and Indigenous people. Generations upon generations have lived without the advances of modern science. For colds. if effective in treatment. much cast aside under the moniker "bush-medicine. whether it may be due to poverty or Isolation. and allowing those using ethnomedications to continue to be self- sufficient and healthy. These people have managed to employ their indigenous knowledge of the surrounding fauna to heal ailments and illnesses in the absence of modern medication. whilst tackling the Pre-Med requirements.

Culture and Illness. Lastly. Shadowing at Bambini Pediatrics made me realize that there are alternatives. Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 13 of 24 . and how It all works through Organic Chemistry. the Global Health Semester is the culmination and tie between all of these experiences. However. I will gain my first experience with the academic view of ethnobotany. learning of a non-Western approach to health from those who practice it will broaden my understanding of other cultures and will influence my care of others. and the sheer quantities of resources needed to maintain health. In essence. and healing in the course. My grandmother and travels to Trinidad connects me to the wisdom held from generations past. Throughout the semester. The opportunity to learn about public policy will help shape the way I approach the application of research. Luke's Cornwall Hospital introduced me to the product of modern medicine. I have experienced the practice of ethnobotany first-hand and learned of biology. Swarthmore teaches me the modern approach to science: from Cell and Molecular Biology to the larger Organismal and Population Biology. the Sociology and Anthropology department also provides insight on the cultural understandings of well-being. but I will not have connected the two in any part of my education until this semester abroad. disease. the experience of the Global Health Semester will provide me an opportunity to begin experiencing my career goal now. Health.My time as a pharmacy technician assistant at St.

PA 19081-1391 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 14 of 24 . PO Box 90630. otsadmicsions ). has this student ever been on academic or probation? { ) YES { } NO If yes.duke. if your university representative Chooses to return this form to you for submission. Approval of Pat-ticlpation 1 approve of the smdeut listed on this form to participate in a study abroad program through the Organization for Tropical Studies (01'S) and Duke University. 1) FAX TO : 919. Sig Date. rkt 3. Ckrcle Term and Specify Year of Participation. Do you recommend this student to participate in the t TS Program? {YES ( ) NO Comments: 2.Semester .Health iit:Costa Pii. or Academic Dean at your home institution for approval to participate in the OTS Program. Instruction§: Please fill out the section directly below and hand it to your Study Abroad Advisor. To the best of your knowledge. 27 2( 11— 2:16 o. ' ng the instructions listed at the bottom of this page. NC 27708-0630 Tel: 919-654-5774 'Swarthmore. Off-Campus Study Office Swarthmnore College 500 College Avenue OTS. i44O P.eclTe 3) SEND VIA POSTAL MAiL TO TH E ADDRESS LISTED BELOW .R9v• Th. PLEASE CHOOSE ONE OF THE FOLLOWING OP TIONS. 1. . C R. 1 — Orgcmbaton for L TJk( V U N t V E P S 1 T Y APPROVA L OF T T N* N ON. Following the student's return to campus.684-6661 WITH ATTENTION WRiTTEN To: OTS ENROLLMENT MANAGEMENT 2) SCAN AND E-MAIL AS ATTACHMEN T TO. ploase send it to OTS using one of the following options listed at the bottom of this page.Ca• Fall grin . please explain: _ 4. has this student ever been convicted of a felony? { ) YES { } NO If yes. Student Name: .gnhii lemon Institution: Swarthmore College Please Select Program. 2012 fl Savanna Ecology in South Africa: Fall Spring Summer Field Tropical Biology in Costa Rica (4 weeks): Summer 0 Global Health Issues in South Africa. please explain. Working Title: `tea lS* (2 E-mail: (` - Address: Phone: To SUBMIT THIS FORM. . — W y. Dean for Study Abroad. all/a ing) 0 Field Tropical Biology in Costa Rica: Fall Spring (7TropzGal°IV[iiue l Pulic . Summer Instructions' Please complete this form and return it to the student OR submit n u. Duke University. Durham.D UKE STUDENTS • ( ON LY) TO THE STUDENT. To the best of your knowledge.. our institution will evaluate the crcdirs earned by the student through Duke University and will consider them for transfer credit the fiilfilhnent ofgrad anon r quireme Print Name G ~C7 C~ . C S.

Please let us know if the student's application will be hindered by not providing a completed form. Bernard Assistant Director Ofl. Spring 2012 Enclosed is a program approval completed by the Off-Campus Study Office for our student who has applied to your study abroad program. . 27. Dear Colleagues: Re: Procedures for Program Approvals for Study Abroad.Campus Study Office 610-328-7826 May 27.'-Campus Study Swarthmore College Cunningham House Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 15 of 24 . We will meet with. we will update you with any revisions to the Coma. Please know that we do not have access to comprehensive student information. 2011 Re: Ravi Thackurdeen. Many thanks and best wishes.MMiay. 2 Sgwarthmore College 500 College Avenue Swarthmore. 14 P. 2(111 2: 16Plti i&. PA 19081-1397 Oft. Rosa M. the Dean's Office in mid October to review student eligibility for study abroad_ After this meeting. We appreciate your patience. We have completed the form and have answered the questions to the best of our ability (following student transcripts).

he has taken a 180° turn. Biology Laboratory Instruc or Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 16 of 24 .O. I highly recommend that you admit Ravi to your program. He has grown a great deal during his first year of college. 2011 Organization for Tropical Studies Duke University Attn: OTS Enrollment Management P. he works well with others and he is a team player. Ravi has always goes the extra mile to do so. Gresh.com Tel: (610) 532-4391 May 12. Ravi is very bright and inquisitive. Ravi is simply a pleasure to be around. Jr. which is a challenging course. However. He also placed in the top 15% of Biology I. Ravi is a caring person around and is always willing to lend a helping hand. hard working and disciplined. His personal potential is immense. an applicant to your program. he was a bit impatient and he did not realize that he needed to be flexible with his schedule. Swarthmore College Tel: (610) 690-5761 500 College Avenue Fax: (610) 328-8663 Swarthmore. Jr. I know that he is going to excel in all that he does. I am very proud of him. I have known Ravi for one year. He strives for excellence and expects nothing but from himself. 1__fA HA'ISJ Department of Biology William F. At the beginning of his first semester. This is particularly evident in his writing assignments.edu Summer contact: williamegrehilr@ua oo. All of my students can earn an A if they put forth the effort. PA 19081-1390 Wgreshl @swarthmore. He is sincere and genuine and has a great sense of humor. Gresh. l i c1 William E. Sincerely. Box 90630 Durham. I served as his Laboratory Instructor during the fall semester of 2010 in Biology I (Cellular and Molecular Biology) and the spring semester of 2011 in Biology II (Population and Organismal Biology). NC 27708-0630 To Whom it May Concern: It is my pleasure to write on behalf of Ravi Thackurdeen.

... .ean1nc3• oC..'. - k 11 z• of P' r' :..:. 'i Course.tS ?Ka..11 u:c a Co] Pin major .a1cu1us 1. . L2sa::' m .` ..16 :.ltYi:e T'San. :'. < : ~ < .00 A ..': i.. :.4: 00 :<::.iJntptpPjt:. .. ez ipL It}{}Ii.:3. 5 •.`'. NI. 3.00 IN PROGRESS ...1 11to . . .:'.. Dr:L y r Newburgh. .}9t ... ..sl-ry r 1. .' . **1*vtit* i ar**k... Leve'1.tl or~ 5 ..: :ar. 'i II . ...'luila1 ..:...t'htickurdeen C ' .-.. . ~ .:.I:LV. :s :. (' . ~ - P9..:. .0.> 'i i v ....gc s iart.Yal Phy ics I -.A0..ul..a. !:.]:L5 0 ..50 !C ' .:.IION (RI I) i 2p1'n . COM 0431.OTh6W11d '1.. ... t. ... 1s ~ taad tcA` .::..xi41 :L gh Sc honl : 26..:.nrnl.. :: ..tuCf... > ' • • 11 I a T O) ~$D ~f6 61 61 u4 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 17 of 24 .00 CR a CF31„ :'..(i:.:. 5 . 1 VLIl. ' ('p) 1 Oq IN PROGRESS S1?II 00'ltl Int SpaiinsY} for .ItrnC g. ::::: ~ `. . .. 17.rcjzdu. - ..Ift'".?'fYR.. •::. ~ IJES: Ri4. .!•i`.:. }:r 'ts.clgn.t 1 1..f. 550 .PRAk'CRit_r1` i1a -W i asc Fiq }rJ.. . t Lll.00 CR .6 ) l'A 'I t)Q81 .'a:0 yjinte .i 00 IN PROGRESS •. 11Yir s. : :`.: t 1 l&e •" ri' t\ idomi rti od ot 12ay.:.. PRY:I 003 CCnc. ~ ' ..00 CR ' • MU I . ~` . .:' :ii' • . 0... I ~ f Not otflCtAt 1\Ittl4llt [a(Slll Sl` ~fit 41111 t CQI S.:.QI) g> 11 .t.. ..':::'•'a''i. ~ c :. o uT°BIOT. hilJS• 011 Ifa nu 1Y rind t . . ..:+ac ~~ . W 3.iI(1N• 2010 C:t... Nea L x'klackurdeerl I ()_ ) i'Ipt of ~ .:... o 1L O... ..{.00 A- .rrent.Pdv gin eja. 1 0 1N.t'.:anPRQss U"..{) oftho I ogl ~ scraY i SwarUi ...': . I' cI . Anchor IJr i vc 91~~ f: ' bxr ~ Iraq Ia qUP(I OL.11 _ .. (W) 1.Tonal 'I.: >': .:::.: .. ::.. ..: :::::FY.-milt {`ollc.00 B+ ...'I'(.:.50 sp)2)c3 2011 C ' 13Y01 O ?.: Chemistry .. +t+i"sta:ft . Calf laL JtealLh j . CRSE ORD R INS1'I'I'FJ. eeeL C)tetn3. ..[..-' AdV!'0pi3. ..7' or .:. .::. . Lr. '::''a':: .lq..040A E1t ulents'• of !aosici1nship I 0 .i(< 1 00 A . Ravi. I .RI 1.:>:>:.QRK.d. Uddt. SWARTH1VORE• COLLEGE GE f tfk.tedi.J(.'..AY'neU Credits 4..00 CR h17iTI1 Q26„ .e . PROGRESS . ..... S AnchcOr.r..:.... .cc'hcx. ~ •. stt') BCOL 001 ' re]lultir ItuleG lug Tip1 (W) 1.. ..& 1bc • is C4t..i Sinc!le Varj (.i7-0.'.. Undergraduate :rranscxip1. Ihr.al.irUe.1'Y....1 1 ' M.:.. 3s v .'"•'• °' f _ C}}.032.:.. -:..OY .dtJN 2O1 I Ne47hi1Xgh :N .' • : COURSE T).* v-17N1) ON`.. r1.:.1 .] ism' 1 .! Lil. aQt1(PnP 9 II _1 A 1t36 :II ..Int..aUO )...

. .~... Please note that the Ouke UAlverslly Burger does not lilt! for prt5grsm deposits._.. . ~ M _. 1/1 Sep.Ea2 CUNNINCHAM HOU$ 505 COULG6AVENUE 5WM tHMAF19.dj.. 13.68803080.7523 E l.I t. 1591 P. NO 27700..mli~7 7ai hl. participant In (name of program)....7$x'5 F* (610)528.. This deposit payment will appear as a credit on the student's bill. We will t prompt payment upon receipt of an invoke from Duke . h1VJMW4wRAhmore.13ERN ARD ASSISTANT DIRECTOR PON 0i P-CAMPU$ STUDY SWARTWA08h COU.. ap to the deposit a Fr{Hunt. Date: ® l'TIO N 2: Third Party Billing Request & Authorixatien ' •a Per this agreement. . .. Name of Program: Tuition Program Fee Transcript Fee L 'ur institution Is responsible for paying the advanced deposit required prior to enrgllment. if the student pays a deposit to Duke Unlvvrsfly.F .11-11 R/._war 919. University. 2011 2:54PM P11K6 VNIVQRu r? -------- Edu c ation orn. gwA7ttMdtet R08A M.ss roR UN0®gaNAeUATC$ Q Our Institution Is not Invuived In the billing arrangements for (student name)..0067 . futham.I 1 ~~ (name of university) Is authorizing Duke University to bill our)nstitutbn on behalf of'the stud nt named below for the tuition and fees Indicated...~~~.•V.. Emaih globaled@duke..dnr Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 18 of 24 . any everpayments on the account. Student Name... PA.. Please bill the student diredlly.i: l rPP1. . Study Abroad/Off Campus Study Rep.c ~tvloce Please return the form using one of the following. Title: Signature . Also. uWA 19081-10Y Phone:($10)328. ~' \ 1 r.. rtwnaiI OeIjhflu wabfiM... ? ybllILru%n.. No..edu Mall: Duke University. Global Eduoation Off lee for Undergraduates Box 90057. will be refunded to the Student Please nnto tde nt will also receive a bill athlsllterlwme dddrsssi I Bi lin Informal o ' Billing a dress for this authorization. .

~ r Fc ~<::: ~ • +tFrl. :'I'L '-L's:. •±. "'">>• c. •.. .~1. :?c_ <va..(?W .~i ~. . ~ ti — •.. . T \~^ t~' ~ A. ~ gyp".er _ w _e_.+r• . I. .: ~:.• • :.~'. :r:~•4+:.•N .L( ~115~.•_:GS•aJV... •3^ '~ ^ •:. yl. . ~.. ..-" '_.I a: _ '' . ~'c0 art G ~ ' ~~ i. ~~::'...yl~ _'~.r' i:.•• — ~ -- — .. y_..c-'t v`"_-.•iCC~.~~ iF~ ..'c.:. F ='•i . ' `✓ ="`{•3•F+ir?•'' }•iL.. ~~ LB!363:luei~l!Ssis id. :'X :~ r~ . ~ :. xw.16E..'y~ ~`? ©S!? 00»070'6 btsc. ~~~2a7.e:' iF3 Q'✓"rT~Id-a.•.Y .~ .•' a.v-~':. rs -.. OaaaL LLISb/b0 L6£SL4100 't~ ' .' :C~~Z' `+L{ 'L ~.a ta .ldS .~..: .'".a.:^"_`1 ~ 'Jk T ..:+': -.1 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 19 of 24 . ' i-"tJ'Sr: .. y ..-:. -y. . .<- ~ ... . l~ . ~ :o. -^...4`= -try F•~'E.~.'ir..' ^-iy'. y ~i o _- _`'A..~ ..Yf .. ~~7/$"i[ Y df1 ". Y'.. Jh' ~iwJ Y•i ..c..`.:~•.:h: .L y .:• ' ~`f:~x!"~ f3'0 QT f o _'-?y 'tY2. •Y . ~~'':S::i':: . • -•(a. .:.-.-.S. oo C' '..(_ c ~ r'tii-'.tr ~~ra .~l.•sa~•1'~ ~•y "' i. u-..' •_ 0 {~ ..•-.-.r.~`. .-'Y:a':s. _ ..:.G V•CALIWT . :?.. x ~'^ . _. w ~-'..` :..7S•:.:~"~ V.. ~ _ :.~[`.'r..1 +7 ~ti•y..°`~• ao4~ ossY~'uofjzt~i:.-.f1 r. ' /-....0~~ : 4g '.`. ^ if ~r _ .~~'~~ ~'::._ •r: -.... ~ ..-~ _.' .~"~-'~ vJyy~ ~rp7~-~ fir.+-i a ~: . _ . ~ wt Mr ' .Ctt•`'• ~r~ y a. ~? t • 6• .J rr.° ''7 fi'I.. t!A'•C••r.. ~~~T %4 ~:"•'+ ~:1. :ry . •~ u-. N~~? ~Cr. -•'.:t.. `' ~ = ' ~ i. u.. . ~. 7 • t...:. !. „• .c~'_ •~-~ i'.. ~4 ~.. •" --.. :~ < .~ l~ .~1 . j ~• I~ ~ ~ q~ 'y ~ •ta ' ~✓ ~~ . ~-y~~: r.. • =.SZISOdaa meJBJd CL08L70I LLI76i60 "s~_-`5'...Z•:% x r r ^.. !% :^. r ..~~ >~ ~ a yy c' S {t „ •t?}' >x '_" -r ' 7. ~ :Y.....y •.fir . . _ _ .Z•~."1•:. -. ~% % of }~ • 4•t . pT a "~ 7 M✓.. F... ..=~ 0.^9• • 'ia ~-S ~..n'•t:`]". ~t ~`~_ :y'. 5.1.%W ~ 11d ~ :3 ~ 1r1's ..?.~f !:~~ :!..F:"' ~'~r=``.wa-~ ... .-+ .:~ .Ny.+ u{iv ~ ®u'iOT 'ib ~ 5I 3_IR :"ES_OO OO1 EON Al bES 51OOAn . ~ .• ~»{~ t7:• -G... .•.~.- a.J-. w. ~ d'4' a• ~ :a f•~j~ 1 t.• %le'..~]' e ~ '~+. `alouii{~n4S-~ ~r • ~ziow`i~vv..4'' ~ . ... -<"' ~ .S_Si'f e. •7. '+' yur .I.KS.: • ~ N3 % . im ' ."'n_•wf 1. _. . ..? .

please bring a spare set. and a runny nose. Citizen Evening phone 845 784-4499 Passport Number 219825658 E-mail Country United States of America Backup Contact (Relative or Friend): Date of Birth 06/08/1992 Name Roshni Thackurdeen Sex Male height 5 1 5 " Weight . NY 12550 Now would you describe your general health? Daytime phone 9 658-8580 Evening phone 439-9205 Physically fit. NY. Bring spare glasses as eye irritation to Injury or illness complications. NY 10116-' should/it/ny two Anaklts or Epipens PolicyNumber 930453218 Recent illnesses None. Signature pal y vitamins. Email tthackur@ mttil.congestion.—Newburgti NY 1255Q Daytime 7 8 7Q ti U. Policy Holders Name Roshni D. State. we in the event of an emergency. Citizen El Non-U. Possible home sickness. List y medications you take regularly. NY 12550 Name Raj Thackurdeen Home Telephone (845) 784_4499 RelationshipF?thcr Address 5 Anchor Drive E-mail address rthaeku2@swarthmore. itchy eyes.oam Do you have any physical limitations that might affect your ability to engage in strenuous physical activity? Mod/cal Insurance Policy information Dietary restrictions None. eat sonic kinds of moat. O. NY 10019 Allergies Seasonal Occupation Business Manager Describe allergic reaction neezing. NC 27708-0630 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 20 of 24 . Relationship to Participant Mother Insurance Company Name GHI * Participants with a known or suspected severe allergic reaction Insurance Company Address PO Box 3000. zip Newburgh. If any of the above Date of last tetanus Inoculation or booster: Information changes prior to or during the course. 06115/2010 Signature • Current recommendation Is no later than 5 years ago. but not others? Employers Address 525 W50th St New York. Once complete please submit via postal mail to the following address: Organization for Tropical Studies Duke University Attn. and I understand that withholding information may contribute • I/ so.S.TS Enrollment Management Box 90630 Durham.S. Relationship Mother Address 5 Anchor Drive OTS course you will be takin g Global Health Semester t4ewburnh.Name Ravi Neat Thackurdeen Emorgcncy Contact Permanent Address 5 Anchor Drive Person to Contact First: city.CintbS Policy Holders Date of Birth 01/06/1963 pressure. check expiref/on date and bring a spare supply. Plan// Category. Thackurdeen * ll you are a vegetarian. 263 Expiration Date N/A Please describe any emotional or psychological conditions that might affect ypur a demie performance. I will immediately n • r e the curse coordinators. Are you covered by health insurance? Yes. No. * it so. I (please print). or non-prescription. prescription.com tt lac curC aol. 150 lbs.edu _. do you eat eggs or dally products? Do you Address 5 Anchor Drive. and possibly compromise may prevent use of contacts. Ravi Thackurdeen Do you wear corrective lenses? have honestly disclosed all the information requested above. Ncwburgh.

the students. We understand that partiolpation in tho program is entirely voluntary andthat anyprogram of travel involves somoelement of risk. A Duke student who receives financial aid fora Duke-administered program should understand that by signing this agreement and the Agreement to Partiolpato (in someD uke programs) upon admission to the progran . and are subject to increase. We agree that in partial consideration of Duke University's sponsoring this aotivItyand periUlti1ng the student to participate. 2011 ProgramTitle/Site Ric ~ The following agreements are designed to protect all participants in Duke-administered¢ or Duke-a p provedprogrnms. Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 21 of 24 . Other (non-Duke) sponsors/instliutions have their own refund policies which we understand will be followed. and other costs expected to be In force. during the sixth week . agents and employees.~ l ". after the sixth week. and we hereby release Duke University. 60 percent. and that the student agrees to participate willin ly in such activities in addition to attending the regular classes. In which we Duke. during the third. Wo understand that continuation requirements . Should another sponsoring Institution cancel Its progmm. 3. (Please make a copy for yourl(es) Form A Statement o f Authorization a nd Cons ent Student's Pull Name _. )lowever rifa student has a history of any medical or psychiatric problems during the previous two years. emotional or mental disorders. In addition. Duke University does notdiscriminate against Individuals who have had physical. the faculty. its trustees. We also understand that graduation dates may need a4Justment if study abroad transcripts are not received and credit transfers are not completed by the specified deadlines. officers agents and . its refuund policy.none. we strongly advise that the student consult with a medical professional before departure to discuss Cite potential stress and difficulty of study abroad. In either case.full reflwd minus the deposit. We understand that the student. changes or substitutions In oases of emergency or changed conditions or In the Interest ofthe group. Duke students who leave their programs without providing the Duke Global Education Office with this official withdrawal notification maybe withdrawn from Duke and will need to apply for readmission in accordance with official Duke University guidelines. We understand that Juniors who plan on ebanging their status from full time to part-time must register their Intention to do so by April 15th preceding the academic year in wbioh thepart•tlme semester will be taken. employees from any liability whatsoever for any personal Injury or property damage arising from participation in the program. Obtaining the necessary permission to enter or remain In a country Is the solo responsibility of the student . c~ . We also understand that any deposit made fbr a Duke-adiulnisterede program Is non•refkmdable. in accordance with the Duke Universityretbnd policy ouilined in the Undergraduate Bulletin. any remaining paid tuition will betefl ►nded as follows. We understand that if I plan to participate in sequential overseas programs we must pay particular attention to the logistics required to obtain multiple visas. Duke University and/or the sponsoring institution may discipline a student or dismiss him or her from the program for behavior detrimental to the.80 percent. program. 4.lents are expected to comply fully with the laws and regulations of the host country regarding required travel documents such as student visas and study permits. November 18. full refunds will bo made unless the cancellation is due to political.. 0. he or she is committed to pay the program fees and that charges will be put on the student 's Bursar account. 20 percent. University will be able to refund only uncommitted and recoverable flrnds. if any. We understand that students receiving conditional waivers must meet all specified conditions In order to be eligible to study abroad. is a representative of Duke University and the United States and by signing this agreement pledges to deport himself or herself In a manner that reflects . In the case of withdrawal. All students who need to terminate their participation in their study abroad program for any reason must notify the Duke Global Education Office by signing and submitting our official withdrawal form before leaving the program. agents and employees liable In damages for any injury or loss to person or property the student might sustain while so partlolpating. Duke University. grades reported by the program will appear on the student's Duke record in accordance with Duke grading and grade requirements as stated In the Undergraduate Brdtelln. as a participant in the program. and the agencies and Individuals cooperatingwith Duke University. 5. A dismissed student will receive no refund firom Duke University. also apply to academic performance abroad. flefore start of program . lodging rates. We understand that In addition to regular classes the program may include planned lectures and field trips which are germane to the educational experience. ~c~ -e ' h _ Due Date : Friday. fourth. as described in the UndergradrtateBullelln. technological or other catastrophes beyond Its control. We require that all students and their parents sign these forms to Indicate their agreement and permission. officers. 2. will apply. Its trustees. Its trustees. exchange rates. We understand that Duke University or the sponsoring institution reserves the right to make cancellations. during the first or secondweek . officers. or fifth week . I. we understand that the program's costs are based on airfares. Stu. Should DukoUnlversity cancel the program. we will not attempt to hold Duke University. ihvorably an both and upholds the Duke Community Standard . A medteal examination is required forthose programs which are physically arduous and/or when ills arequirement ofthohost institution. natural.

fud05n4. The director of the program should be fully Informed of any special needs at the start of the program . Date ofexpiration do . OTS/Duko In South Africa . Students must forward the contirmadon email (with subject line Under Grad Travel Reg) to dkeanrey@duke. Wouuderstand that the Study Abroad I'ee ofS4. abroad as In the United States The student must. Duke University can make no representation with respect to accessibility of services and facilities abroad.30113) by Friday. v A (list it notappitcable. with # ` iitt kWtffi (name ofstudent)isInsuredunderpolloyorgroup/membet/lDnusnber (company) for sickness and accident Insurance. treatment orhespital care which In the best judgment of it licensed physician is deemed adv cab e. NC 277084057 (Tel. ptrtlelpating in the program..684. Appropriate treatments. (1) (we) the parent(S) ofthe above named student. .duko. We understand that programs abroad may not regularly employ health cure professionals overseas and make no representatton With respect to accessibility of services and facilities abroad. but Is given to provide authority and poweron I bepart offluke Univemsity to give specific consent tothedlagnosis. we understand that payment for medical expenses customarily will have to be advanced and reimbursement sought later from the Insurance carrier. Duke in Frencc/BDUCO. This mandatory fee actbythe Board of'f ustees Is notwaived under any circumstances. While Duke discourages students from purchasing or renting vehicles abroad. '$ Duke-administered programs are: Duke lathe Andes.edu so that may be Included with iflnal study abroad forms. for continuation of medical treatments such as prescriptions or special diets. See https://eruditlo. Duke University requires that afl students register with the Duke Travel Registry. in addition._ ~ tb i Thar P k•LtAJ-P Vol 0 rMY Number & Street City State Telephone number Area Coda Phone number Signature of student Date The signatures of both a pareu or legal guardian and the student are rettulred . OT /Duko In Costa Rica. Petersburg.inad tion. j (initials of parent/guar:dian) Paren VOuardinn I certify that tam the parent or legal guard of the student nam ve. or hospital care being required. Duke Semester in India. Bay 6. Borne A — page 2 b. Duke University also recommends that students Insure their property from loss or theft. 919. treatment. / Signature otparent or guardian yy °ti r 'G hate ` /_ Printed name of parent or guardian .gran g my co r~lo'_aIf acI is pr Ided for heroin.O67 (2011-2012) per semesterwill be charged by Duke University to students partleipatlngin progr ams administered byluslitutlonsother than DukeUniversity for thepurpose ofmaLntnIningjDç student's enrollment atDuke. therefore make provision before departure . Fax 919. Duke in Berlin. Box 90057 .sus.2174. ms koFamudoe fastrs. the I have read the entire preceding agreement and I join In all the arttcies of the agreement nvhhout resew .684. We understand that Duke. 201 f. i. medical or surgical diagnosis or treatment and hospital care deemed neoessaty or advisebte by it licensed physiolan during the period the student is enrol led In thoDuke program. OTS/IJrrko In Costa Idea . 2nd Floor . '1 opieal Biology . It is understood that this authorization is given in advance of any specific diagnosis. Durham.Savanna beelogy. Global Semester Abroad. ]Duke Study in China. Please sign this form and return It to Global Education Office for Undergraduates . Smith Warehouse . Duke University . anaestlietio. espectaliy)rsyebolog)cal. Box 90057 MUST be included In the address. if malting. Duke in Glasgow. 114 S. November 18. Uuiverylty requires that appropriate sickness and accident Insurance cover all students for the duration of the program and that they be financially responsible for all medical ecpeusos. intercollegiate Center for Classical Studies (ICCS) in Rome. Duke in tstanbul. Buchanan Blvd.It Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 22 of 24 .pbp for additional details and the link to the Duke International Travel Registration lForm. may not be as readily available. the student erobyassurnesresponslbilityforati medical expenses Incurred byes onbe lfoftbeshtdent while. hereb y authorize Duke University's representative to consent for (me) (us) to any x-ray examination.Global Heaith/rropieat Medicine and Public Health. Duke in Madrid. and Duke In Venice.cdu/internatdonai/index. In the event (1) (we) cannot be reached to give (nay) (our) consent. we recommend that those students planning to o$rcrato a motor vehicle obtain liability and collision Insuranco that will cover them in the applicable foreign countries. Duke in St.

I understand that as a participant I have the responsibility to help make the activity a safe experience for all participants through appropriate behavior and conduct. ® That the participant understands that as a participant in this Duke University program.. 4. The Organization for Tropical Studies and Duke University require that any participant planning to operate a motor vehicle obtain liability and collision insurance that will cover him or her in the applicable foreign countries. ® That the participant understands that the Organization for Tropical Studies and Duke University requires all participants to be covered by appropriate health and accident insurance and those participants and their families must be financially responsible for all medical expenses and for expenses related to evacuation and repatriation unless otherwise provided. I understand that payment for medical expenses customarily is advanced and reimbursement sought later from the insurance carrier.r You have requested to participate in one of the Undergraduate Study Abroad Programs sponsored by the Organization for Tropical Studies at Duke University. I hereby elect to voluntarily participate. Understanding all of the risks involved. or injury that may affect your performance in the activity. 2. In addition. 3. I agree and understand the following: 1. or substitutions in cases of emergency or changed conditions or in the interests of the group. I also understand the danger associated with deviating from the planned activity and agree not to deviate from the plans as stipulated in the procedures. NA TURE OF TRAVEL: I understand that I will be traveling to Costa Rica and possibly driven by faculty or employees of the Organization for Tropical Studies or its contractors. BEHAVIOR EXPECTATIONS OF THE PARTICIPANT: I know that it is important to follow the directions of the activity leader at all thnes. INHERENT RISKS AND DANGERS OF TRAVEL : I understand and appreciate that risk and dangers are inherent when traveling long distances. N tt UNIVERSITY IVERSITY Page 1 of 2 . PLEASE READ THIS AGREEMENT CAREFULLY. Duke University allowing me to participate in this activity. my voluntary participation in the activity. and it is important for you to have information about this activity and to provide the Organization for Tropical Studies with information about yourself before participating in this activity.ii 11ii i . which reflects favorably on all. To inform the Organization for Tropical Studies of any medication. The Organization for Tropical Studies and Duke University also recommends that participants insure their property against loss or theft. Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 23 of 24 . The Participation Agreement must be read carefully and signed by all participants who take part in the activity offered by the Organization for Tropical Studies. B That the participant understands that the Organization for Tropical Studies. known or unknown. ~ Y>qarnzhon for i . arising from or as a result of. All activities associated with travel involve risks. HEALTH CONDITION OF THE PARTICIPANT : By signing this participation agreement you agree: ® To furnish the Organization for Tropical Studies health information. a That the participant will bear all financial responsibility for any medical treatment arising from participation in the activity. By signing this agreement. I understand the Organization for Tropical Studies and the University's position on student drivers and will follow the rules that have been set by the Organization for Tropical Studies and Duke University. condition. ailment. I understand that not following procedures correctly could result in property damage and personnel injury. I agree to accept and assume all risks associated with the activity whether present or future. changes. In consideration of the Organization for Tropical Studies. IT IS A LEGAL CONTRACT AND AFFECTS ANY RIGHTS YOU MAY HAVE IF YOU ARE INJURED OR OTHERWISE SUFFER DAMAGES WHILE PARTICIPATING IN THIS ACTIVITY. I am a representative of the Organization for Tropical Studies and Duke University. Duke University reserves the right to make cancellations. including death. I pledge to conduct myself in a manner.

damage or costs. I agree to INDEMNIFY AND HOLD HARMLESS the RELEASEES whether injury or damages is caused by my negligence. SIQNATURE$ The signatures of both the student and their parent or legal guardian are required. damage. IN SIGNING THIS RELEASE. video or PowerPoint presentation in which I am depicted can be used in OTS promotional materials. or agents. B. I understand that any photograph. I hereby further agree that this Participation Agreement. C. its trustees. E. and I agree that RELEASEES shall not be liable for any injuries resulting or arising out of such deviation. DISCCARGE. AND HOLD HARMLESS AGREEMENT In return for the Organization for Tropical Studies and Duke University allowing me to participate in this activity and having read and understood this Participation Agreement. I understand that by participating in this activity I will ASSUME THE RISK of injury and damage from risks and dangers that are inherent in any activity. assigns and personal representative. AND COVENANT NOT TO SUE the Organization for Tropical Studies. Release. officers. or injury. G. that RELEASEES may incur due to my traveling to and from. and sign it voluntarily. Date Page 2 of 2 Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 24 of 24 . the negligence of the RELEASEES.from. Name ofParticivant . D.'I ACKNOWLEDGE AND REPRESENT that I have read the foregoing PARTICIPATION AGREEMENT. P. liability. Duke University. including death. RELEASE. including court costs and attorneys' fees. understand it.5. if I am deceased. or the negligence of any third party from any loss. and participation In this activity. if I am alive. I hereby RELEASE. and participation in this activity. and my heirs. that may be sustained by me. Assumption of Risk. such deviation Is purely voluntary. or to any property belonging to me that occurs as a result of my traveling to and . WAVER OF LI ILITY. WAIVER. (hereinafter referred to as RELEASEES) for any liability. and/or cause of action arising out of or related to any loss. and shall be deemed as a RELEASE. DISCHARGE. WAIVE. It Is my express intent that this RELEASE and HOLD HARMLESS AGREEMENT shall bind the members of my family and spouse. employees. I hereby state that I voluntarily agree to the following: A. Waiver of Liability. ASSuMptioN of RISK. and Hold Harmless Agreement shall be construed in accordance with the laws of the state of North Carolina. and COVENANT NOT TO SUE the above-named RELEASEES. claim. If I deviate from any aspect of this activity.

EXHIBIT 2 Memorandum of Understanding Case 1:16-cv-01108-NCT-JLW Document 66-2 Filed 02/24/17 Page 1 of 2 .

Case 1:16-cv-01108-NCT-JLW Document 66-2 Filed 02/24/17 Page 2 of 2 .

EXHIBIT 3 Statement of Authorization and Consent Case 1:16-cv-01108-NCT-JLW Document 66-3 Filed 02/24/17 Page 1 of 3 .

Case 1:16-cv-01108-NCT-JLW Document 66-3 Filed 02/24/17 Page 2 of 3 .

Case 1:16-cv-01108-NCT-JLW Document 66-3 Filed 02/24/17 Page 3 of 3 .

EXHIBIT 4 OTS Participation Agreement – Costa Rica Case 1:16-cv-01108-NCT-JLW Document 66-4 Filed 02/24/17 Page 1 of 3 .

Case 1:16-cv-01108-NCT-JLW Document 66-4 Filed 02/24/17 Page 2 of 3 .

Case 1:16-cv-01108-NCT-JLW Document 66-4 Filed 02/24/17 Page 3 of 3 .