Drew Cooper & ANDING “Alffontys axo COUNSELORS EERE NON aSowoRls NOU 29 PRDPEDPOS CHICAS thin ans #1" 200R%0o" C Nor ‘November 29,2016 (E-TO FILE CLAIM Court of Claims Clerks Office Hall of Justice 925 W. Ona Stret P.O. Box 30185 Lansing, MI 48909 VIA HAND DELIVERY RE: Our Clients: Potential Adverse Panties Potential Claims ‘To Whom It May Concer: Michigan Sate University Office ofthe General Counsel 426 Auditorium Rod, Room 498 East Lansing, MI 48824 Jane A. Doe (minot) by next fend Jane B. Doe, Jane C. Boe, Jane’D. Doe, Jane E. Doe, Jane'F. Doe, Jane G. Doe, Jane H. Doe, Jane Dee, Jane J. Doe, Jane K. Doe (ino) by next fiend Jane L. Doe, Jane M. Doe, Jane N. Doe, and Jane 0, Doe Michigan State University, Lawrence Nassar, MD. Violations of Tile IX; 42 US.C. §1983; Sexu Assault, Seauel Battery; Constructive | Fraud; ‘Negligence; Gross Negligence; Negligent Supervision; ‘Negligent Hizing and Retention; Negligent Failure to Warm, Train or Educate; Vicarious Libiliy-Ageney- Respondest Superior; Expresso Implied Agency Please be advised the law firms of Drew, Cooper & Anding and Many, Stewart & Fina ‘represent the individuals iste above, As this ase involves claims and allegations of sexual abuse and sssault involving minors, we fee it prudent to proceed anonymously.” Pursuant to MCL 600.6431(1), please acept ths leter es a Notice of Intent to File Claim, hich includes a notarized signature of our clients egal representative, Atlomey Stephen R. Drew. " Both Sixth Circuit and Michigan la support proceeding anonymously especially considering two of cour elients ae minors,(Cour of Claims Clerks’ Ofice “Michigan State University Page 2 November 29,2016 EVEN WoI6 ROY 29 Pr ‘This Notice serves as our clients" intent to file claims ageinst Michigan tite University and Lawrence Nassar, M.D., 2 former employee/egeavepreseratve of Michigan State University. Our liens" potential claims include, but are nt limited to the following: Violations of Title IX @2USC. 51983 Sexual Assault Sexual Battery Constrctve Fraud ‘Negligence Gross Negligence Negligent Supervision "Negligent Hiring and Retention ‘Negligent Failure to Warn, Train or Educate ViesriousLiabilty-Agency-Respondeat Superior Express or Implied Agency ‘The claims atise out of multiple instances of sexual assault and battery, molestation, and ‘harassment of our lients by Dr. Lawrence Nassar, an employee/egentepresenatve, ete of Michigan ‘State University fom 1996 t0 ag cent as 2015, Specialy, the Clans arise out of Dt. Nassar Aigitl penetration of our cients without proper notice, gloves, ibrican, or cheperones under he guise of providing medical care and teatment this office at Michigan Site University. Ii our belit Dr [Nassar usd his postion of trust and confidence in an abusive manner. It is also our understanding Michigan State University received complaints regarding Dr. [Nassar and failed to propery investigate, discipline, and sanction Dr, Nasser for his abusive end harassing conduct. (Our cients were made aware of Dr. Nassr's conduct on or around September 12, 2016 {following publication ofa story regarding recent complaint filed with the Michigan State University Police (ee stached article, "Former USA Gymnastics doctor accused of Abuse,” originally published September 12,2016). Our clients have varied injuries include among others shock, humiliation, emotional distress ‘and related physical manifestations thereof, embarrassment, loss of self-esteem, disgrace, and loss of enjoyment of life.Cour of Claims Ces’ Office ‘Michigan Sate University Page 3 November 29,2016 2IbKOV 25 PH ies 29 i Finally, please be advised we contin to receive contact from other vietims of Dr. Nassar's conduct and reserve th right to amend this Notice to include all future cients who engage our firms {orepresentatin related to this matter. Respectfully, DREW, COOPER & sdeew com ‘Subscribed and sworn to before me ‘on his 2h day of November 2016, ‘Gala Jo Coton, Notary Public ‘State of Michigan, County of Kent My Commission Expires 09-29-2017 ‘Acting inthe County of Kent ‘s! John C. Manly (with permission) John C. Manly ‘imantvi@imanlystewart.com SRDIg