Duquesne would like to provide an update on its actions related to Ms. Dannielle Brown's claims and demands of the University.

1. The University has ordered body cameras. While city and Duquesne police officers have interviewed multiple witnesses who have shared the same account relative to what happened on that evening when Marquis "Jaylen" Brown tragically died, and we believe without a doubt that our officers acted in the most prudent manner possible, we believe that body cameras are a public safety and community relations best practice. Duquesne had already been undergoing due diligence as it relates to acquiring body cameras, prior to the tragic incident.

Duquesne has funded the camera program. The first-year cost is $90,000, and the system will cost $43,000 annually thereafter, in order to cover the technology support needs. We expect the cameras to arrive within three weeks, but have requested expedited shipping. The University is working with the union that represents its public safety officers to complete the due diligence relative to adopting the cameras for use.

2. The University has made clear to Ms. Brown in recent statements that the safety of Duquesne's students, faculty and staff are our top priority, and that our COVID-19 conduct policies must be followed. All visitors, including students' parents and other guests, must follow strict protocols before coming onto campus, in compliance with our COVID-19 rules. Ms. Brown and those who may join her will be held to the same standards. Also, we have asked Ms. Brown to voluntarily stop using a bullhorn, due to its creating disruption of students in exams and studying, and to ensure she does not visit or invite others to visit without permission from the University. While Duquesne has worked to respectfully accommodate Ms. Brown's right to share her message, and very much wishes to reach closure for all concerned in this tragic matter, the University cannot tolerate non-compliance with our safety measures or disrupting our students' academic pursuits.

3. The University has requested the Court to require Ms. Brown to file a complaint to specify her exact allegations against the University.

On February 15, 2019, Dannielle Brown initiated a lawsuit against Duquesne University by filing a Writ of Summons in the Court of Common Pleas of Allegheny County. Since that time, Ms. Brown has continued to issue demands and led protests, but has not specified the nature of her allegations of wrongdoing or basis for legal liability. As a result, Duquesne has requested the Court to require Ms. Brown to file a complaint setting forth her allegations against the University. The Court has now directed Ms. Brown to do so.

Ms. Brown's prior attorney, S. Lee Merritt, no longer represents her, and Ms. Brown has not disclosed the identity of her present counsel. Nor has any lawyer contacted the University on her behalf. This has made it impossible for Duquesne's counsel to provide, through the proper legal channels and following the correct procedures, documents and information that Ms. Brown continues to demand.

The University is eager to make available all relevant information through a transparent and proper process. All such information and evidence Duquesne presently has in its possession corroborates what the City of Pittsburgh Police investigation and the independent investigation commissioned by the University already determined: that the University and its public safety officers acted appropriately, and that Ms. Brown's son died as a result of jumping out of a sixteenth floor window after going off-campus and ingesting drugs while celebrating his twenty-first birthday with friends.

By requesting that the court direct Ms. Brown to file a complaint and set forth her allegations, the University hopes that the traditional methods of obtaining evidence and testimony-through requests for documents, depositions, and (if necessary) a trial in open court-will allow all of the evidence to be obtained by Ms. Brown through a fair, open, and comprehensive process, thus allowing her to find the answers she seeks so she and the University can reach closure in this tragic matter.

Duquesne University

Founded in 1878, Duquesne is consistently ranked among the nation's top Catholic universities for its award-winning faculty and horizon-expanding education. A campus of nearly 8,500 graduate and undergraduate students, Duquesne prepares students by having them work alongside faculty to discover and reach their goals. The Universitys academic programs, community service, and commitment to equity and opportunity in the Pittsburgh region have earned national acclaim.

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September 25, 2020