June 17, 2019

California State Assembly

1315 10th Street
Sacramento, CA 95814

Dear California Senate Member:

As sexual assault survivors of former University of Southern California (USC) gynecologist

George Tyndall, and supporters of the pending class action settlement, we write this letter to
respectfully urge you to vote in favor of Assembly Bill 1510. By amending the statute of
limitations in California, AB 1510 will give survivors the opportunity to pursue their civil claims
in court if they so choose.

As victims of abuse, we didn’t have a choice. We didn’t know Tyndall was a monster and didn’t
have another option for a gynecologist at the USC student health center. With the passage of
AB 1510 and the approval of the class action settlement, we and our fellow survivors will finally
have a choice as we look to hold USC and Tyndall accountable.

We chose to join the $215 million class action settlement because it offers survivors a safe and
private way to seek justice. As you may notice, several signatories to this letter are women who
have chosen to only use their initials or be identified as “Jane Doe.” A critical component of the
settlement is that it acknowledges all women regardless of whether they are willing to publicly
share their story and does so without the risk and trauma of litigation where anonymity is
impossible.

Importantly, the settlement will force USC to make real, long-term reforms to their policies and
procedures to create a safe environment for the next generation of Trojan students. This
includes:
• the appointment of an Independent Women’s Health Advocate;
• increased scrutiny and monitoring of health center employees, including pre-hiring
background checks, credential verification, and annual education and performance
reviews;
• the adoption of best practices from the American College of Obstetricians and
Gynecologist;
• new methods for collecting information about potential misconduct, including through
the solicitation of patient feedback and implementation of plain-language notice for
recognizing and reporting sexual harassment and gender-based violence;
• improved health center patient practices, including updated sensitive exam practices
and allowing students to select a physician based on gender; and
• mandatory trainings for personnel and students to prevent, recognize and report sexual
assault or misconduct.
Despite the trauma we endured, it has been inspiring to see our collective demand for action
result in real accountability at USC, and reforms that will benefit the next generation of
students to ensure this never happens again.

From the beginning of this legal process we have advocated for choices, and accordingly the
settlement was designed to give survivors a choice on how much they want to participate while
ensuring all of us are acknowledged. The settlement also revives the statute of limitations for
all survivors, ensuring all women — even if they saw Tyndall decades ago — can have their
voices heard. We, however, understand and respect that some women will choose to opt out of
the class action settlement and instead pursue individual litigation. Passage of AB 1510 will
allow those women to file civil claims without having to overcome the legal hurdle of a statute
of limitations defense.

Whether through the class action settlement or the bill, every survivor deserves the right to
choose the path that is best for her. We hope that you will join us in supporting each other in
our healing, regardless of how we choose to do it. Thank you for your consideration.

Sincerely,

Betsayda Aceituno Jane Doe A.N.

Elisabeth Treadway Jane Doe A.S.
Jennifer Puckett Jane Doe C.L.
Joyce Sutedja Jane Doe C.N.
Julia Zucker Jane Doe D.C.
Meggie Kwait Jane Doe DD
Mehrnaz Mohammadi Jane Doe J.K.
Shannon O'Conner Jane Doe K.P.
Vanessa Carlisle Jane Doe K.Y.
Jane Doe Jane Doe M.S.
Jane Doe 4 Jane Doe M.V.