Free Status Report - District Court of Colorado - Colorado

Case 1:03-cv-01364-JLK

Document 59-2

Filed 01/02/2007

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EXHIBIT 1

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Case 1:03-cv-01364-JLK

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Filed 01/02/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-1364-JLK-PAC SCOT HOLLONBECK, JOSE ANTONIO INIGUEZ, JACOB WALTER JUNG HO HEILVEIL, and VIE SPORTS MARKETING, INC., a Georgia corporation, Plaintiffs, v. UNITED STATES OLYMPIC COMMITTEE, a federally chartered corporation, and U.S. PARALYMPICS, INC., f/k/a UNITED STATES PARALYMPIC CORPORATION, a Colorado non-profit corporation, Defendants.

STIPULATION CONCERNING VIE SPORTS MARKETING, INC.'S ADA AND REHABILITATION ACT CLAIMS

Plaintiff Vie Sports Marketing, Inc. ("Vie") and Defendants United States Olympic Committee and U.S. Paralympics, Inc. f/k/a United States Paralympic Corporation (collectively, the "USOC") jointly submit this stipulation (this "Stipulation") regarding Vie's claims under the Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq. ("ADA") and the Rehabilitation Act of 1973, 29 U.S.C. § 794 ("the Rehabilitation Act"). Vie and the USOC hereby stipulate and state as follows: 1. The individual athlete plaintiffs in this action--Scot Hollonbeck, Jose Antonio

Iniguez and Jacob Walter Jung Ho Heilveil--assert claims against the USOC under the ADA and the Rehabilitation Act alleging that the USOC discriminated against them on the basis of their disability (hereinafter, "the Athlete Claims"). This Court granted the USOC's motion to dismiss

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Case 1:03-cv-01364-JLK

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the Athlete Claims in their entirety in its November 16 Memorandum Opinion and Order. (See Doc. 54.) 2. Vie also asserts its own claims against the USOC under the ADA and the

Rehabilitation Act in Counts I and II of the Amended Complaint. 3. In consideration of the USOC's agreements in the Joint Status Report submitted

to the Court on January 2, 2007, Vie agrees to release and forever discharge the USOC of and from any and all actions, causes of action, claims, suits, debts, damages, judgments, losses, liabilities, and demands whatsoever that Vie now has or may have had under the ADA or the Rehabilitation Act except those based on the theory that Vie was injured by the discrimination alleged in the Athlete Claims, namely, the USOC's alleged discrimination against Paralympic athletes. 4. This Stipulation shall be binding upon and inure to the benefit of the parties

hereto and their respective predecessors, successors, and assigns. Dated: January 2, 2007 FOX & ROBERTSON, P.C. HOGAN & HARTSON LLP

s/ Amy Farr Robertson Amy F. Robertson 910-16th Street Suite 610 Denver, Colorado 80202 Attorneys for Plaintiffs

s/ Jeffrey S. George Jeffrey S. George Anne H. Turner Two North Cascade Avenue Suite 1300 Colorado Springs, Colorado 80903 Attorneys for Defendants United States Olympic Committee and U.S. Paralympics, Inc.

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