October 5, 2020 DAMARIO SOLOMON-SIMMONS 601 S. Boulder, Ste 600 Tulsa, Oklahoma 74119 Telephone: (918) 551-8999 Facsimile: (918) 582-6106 E-Mail:
[email protected] **CONFIDENTIAL SETTLEMENT COMMUNICATION** VIA EMAIL (
[email protected]) VIA EMAIL (
[email protected]; kirk- VIA CERTIFIED MAIL
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[email protected]) Bruce Harreld VIA CERTIFIED MAIL The University of Iowa Gary Barta Office of the President Kirk Ferentz 101 Jessup Hall Brian Ferentz Iowa City, Iowa 52242-1316 The University of Iowa Dept. of Athletics Hansen Football Performance Center 992 Evanshevski Drive Iowa City, Iowa 52242-1020 Re: Settlement Negotiations for Unlawful Race Discrimination by University Employees Dear Messrs. Harreld, Barta, Ferentz, and Ferentz: We write in an attempt to amicably resolve the above matter on behalf of our current clients, Akrum Wadley, Aaron Mends, Jonathan Parker, Marcel Joly, Maurice Fleming, Reggie Spearman, Kevonte Martin-Manley, and Andre Harris, prior to filing suit. To the extent necessary and in the event of filing suit, and because Athletes are still reaching out to us for representation, we will be seeking to certify a class of all similarly situated African-American student-athletes (“Athletes”). Our current clients are former members of the University of Iowa football program (“Program”). During their respective tenures as student-athletes, they were subjected to intentional race discrimination by coaching staff and administration. Through the Program’s pervasive harassment, bullying, policies causing disparate impact, and race-based threats and retaliation, our clients were deprived of a meaningful opportunity to pursue a high-quality education while competing at the highest level of collegiate athletics.