Order Miami University to take such affirmative steps as may be necessary to restore, as nearly as practicable, each identifiable person aggrieved and harmed by Miami discriminatory conduct to the position that he or she would University’s have been in but for Miami conduct; University’s Award compensatory damages in an appropriate amount to persons aggrieved and harmed by Miami discrimination. University’s Order such other appropriate relief as the interests of justice may require. Respectfully submitted, Dated: ____________, 2015 LORETTA E. LYNCH Attorney General ___________________________ VANITA GUPTA Principal Deputy Assistant Attorney General EVE L. HILL Deputy Assistant Attorney General CARTER M. STEWART Civil Rights Division United States Attorney Southern District of Ohio MATTHEW J. HORWITZ _____________________________ Assistant United States Attorney REBECCA B. BOND 221 E. Fourth Street, Suite 400 Chief Cincinnati, Ohio 45202 KATHLEEN P. WOLFE (513) 684-6823 (Horwitz) Special Litigation Counsel (513) 684-6972 (Fax) KEVIN J. KIJEWSKI Deputy Chief Disability Rights Section _____________________________ WILLIAM F. LYNCH Trial Attorney PEARLINE M. HONG Trial Attorney Disability Rights Section (NYA) U.S. Department of Justice 950 Pennsylvania Ave., N.W. NYA –
Order Miami University to take such affirmative steps as may be necessary to restore, as nearly as practicable, each identifiable person aggrieved and harmed by Miami University’s discriminatory conduct to the position that he or she would have been in but for Miami University’s conduct; Award compensatory damages in an appropriate amount to persons aggrieved and harmed by Miami University’s discrimination. Order such other appropriate relief as the interests of justice may require. Dated: ____________, 2015 CARTER M. STEWART United States Attorney Southern District of Ohio MATTHEW J. HORWITZ Assistant United States Attorney 221 E. Fourth Street, Suite 400 Cincinnati, Ohio 45202 (513) 684-6823 (Horwitz) (513) 684-6972 (Fax) Respectfully submitted, LORETTA E. LYNCH Attorney General ___________________________ VANITA GUPTA Principal Deputy Assistant Attorney General EVE L. HILL Deputy Assistant Attorney General Civil Rights Division _____________________________ REBECCA B. BOND Chief KATHLEEN P. WOLFE Special Litigation Counsel KEVIN J. KIJEWSKI Deputy Chief Disability Rights Section _____________________________ WILLIAM F. LYNCH Trial Attorney PEARLINE M. HONG Trial Attorney Disability Rights Section (NYA) U.S. Department of Justice 950 Pennsylvania Ave., N.W. – NYA
proposed_complaint.docx