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The plaintiffs and the United States contend that the harassment on the basis of sex and perceived sexual orientation was severe, pervasive and objectively offensive; that District officials with authority to rectify the situation were given notice of the harassment but failed to take immediate and appropriate corrective actions; that these District officials were deliberately indifferent to this harassment; and that this deliberate indifference prevented Jeremy Lovins from enjoying educational benefits and opportunities. This Consent Order is effective immediately upon its entry by the Court and shall remain in effect for two (2) years from the date of entry or ninety (90) calendar days after the last report under Section VII is received, whichever date is later, absent an extension as set forth in Section II. C, to insure compliance with all provisions of this Consent Order. The United States may move the Court to extend the period in which this Consent Order is in effect if it determines that the defendant likely has violated one or more terms of the Order, or if the interests of justice otherwise require an extension of the terms of the Order. The parties to this Consent Order shall endeavor in good faith to resolve informally any differences regarding interpretation of, and compliance with, this Order prior to bringing such matters to the Court for resolution.The plaintiff and the United States further contend that the District's response to Jeremy Lovins's complaints of harassment constitutes a violation of the Equal Protection Clause of the Fourteenth Amendment to the Constitution of the United States and Title IX of the Education Amendments of 1972. Neither the defendant's agreement to the terms of this Consent Order nor any other action taken by the defendant in connection with this settlement constitutes an admission of wrongdoing or a violation of any state or federal law by the defendant. However, in the event that the defendant either fails to perform in a timely manner any act required by this Order or acts in violation of any provision of this Order, the United States may move the Court to impose any remedy authorized by law or equity, including, but not limited to, an order requiring performance or non-performance of certain acts and an award of any damages, costs, and attorneys' fees that may have been occasioned by the defendant's actions or non-actions. The parties agree that the time limits set forth throughout this Consent Order may be expanded upon mutual consent of the parties. Injunctive Relief The defendant, its agents, employees, successors, and all persons in active concert or participation with it, are enjoined from: A.Copies of all certifications of attendance of District school board members and employees in the Training Program; 5. PLEASANT HILL PUBLIC SCHOOL DISTRICT, R-III, Defendants. 99-0550-CV-W-2 __________________________________________ MOTION TO DISMISS COMES NOW Plaintiff, by and through counsel, and moves this Court to dismiss the above-captioned case with prejudice upon the entry of the Consent Order to which this motion is attached. Each party shall bear their own costs and fees incurred herein.A list of compliance coordinators, by sex, job title and school; 6. In support of his motion, Plaintiff states as follows: 1. WHEREFORE, Plaintiff respectfully requests that the Court enter its order dismissing all claims against defendant herein with prejudice with each party to bear their own fees and costs incurred herein; and for such other and further relief as the Court deems just and proper.

Copies of the agenda (including date of training) and all materials used in the Training Program for District school board members and employees; 4. Although this Consent Order obligates the District to develop and implement a comprehensive plan to prevent, identify and remediate harassment and discrimination on the basis of sex or sexual orientation, the District is encouraged to develop and implement similar plans to prevent, identify and remediate harassment and discrimination on the basis of race, ethnicity, national origin and disability. IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI MISSOURI, WESTERN DIVISIONJEREMY LOVINS, Plaintiff vs.Develop a comprehensive plan to prevent, identify and remediate harassment and discrimination on the basis of sex or sexual orientation ("the Comprehensive Plan"), as described in Section V, below; B.Within ninety (90) calendar days from the date of entry of this Consent Order, the defendant shall deliver to counsel for the United States, at the address set forth previously, copies of the written school climate assessments and analyses, the proposed Comprehensive Plan, the proposed Training Program, and all supporting materials. Within one hundred twenty (120) calendar days from the date of entry of this Consent Order, the United States shall provide written comments or objections, if any, to the defendant that pertain to the items set forth in Section IV. The defendant shall make a good faith effort to address any concerns of the United States, and, where appropriate, incorporate any suggestions or modifications proposed by the United States. Comprehensive Plan for Preventing, Identifying and Remediating Harassment and Discrimination on the Basis of Sex or Sexual Orientation The Comprehensive Plan shall be implemented by the District within one hundred eighty (180) calendar days from the date of entry of this Consent Order, and shall, at a minimum, include the following provisions: A. The District shall revise its written policy prohibiting harassment and discrimination on the basis of sex or sexual orientation, to insure that the written policy (1) sets forth the District's commitment to protect students from harassment and discrimination and to maintain a nondiscriminatory environment; (2) states that all students, regardless of sex or sexual orientation, are entitled to an educational environment free from harassment and discrimination; (3) reaffirms that the District shall respond to male and female students' complaints of harassment promptly, appropriately and with the same degree of seriousness; (4) requires all District employees to promptly report, to the principal or a compliance coordinator (as described in Section V. The District shall define harassment and discrimination on the basis of sex or sexual orientation, and provide concrete examples of each. Policies and procedures for reporting prohibited conduct. Department of Justice, and other state or local entities, including the right to bring an action in state or federal court. Policies and procedures for investigating complaints. The District shall describe the steps it will take to respond to reported incidents of harassment or discrimination, including but not limited to taking disciplinary measures against those found to have engaged in such acts, and, where appropriate, reporting violent or criminal conduct to law enforcement authorities. Policies and procedures for remediating violations. The District shall explain the disciplinary measures available against persons who are found to have engaged in harassment or discrimination on the basis of sex or sexual orientation. The District shall explain what efforts it will make, consistent with its legal obligations to investigate, to take appropriate action, and to conform with any discovery or disclosure obligations, to respect the privacy of the complainant, the victim, individuals against whom a complaint is filed, and witnesses. Dissemination of policies and procedures, and training of personnel.After reviewing the terms of this Consent Order, the Court concludes that the entry of this Consent Order comports with federal law and is appropriate under all the circumstances.Therefore, it is ORDERED, ADJUDGED and DECREED as follows: I. Defendant Pleasant Hill Public School District, R-III is organized under, and exists pursuant to, the laws of the State of Missouri, and is a recipient of Federal financial assistance.

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