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CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 1 of 8 NITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Roger M. Lindmark, we Jury Trial Demand Plaintiff, COMPLAINT v. Saint John’s University, Case No /B-LV- OIE KF Collegeville, Minnesota, Defendant, Plaintiff as and for his Complaint against Saint John’s University, Minnesota (“St. John’s”) respectfully alleges as follows: ‘THE NATURE OF THIS ACTION 1, Plaintiff brings this action seeking return of funds paid to St. John’s as part of the Lindmark Endowment for a Corporate-Business Ethics Program (hereinafter “Endowment”) as a result of the failure of St. John’s to administer the Lindmark Endowment in accordance with the terms of the program as established by the parties. THE PARTIES 2. Plaintiff resides in Los Angeles, California and is a 1974 graduate from St. John’s. He is a licensed attorney in the State of California and in Washington, D.C. 3. Defendant Saint John’s University, Minnesota is a private, Catholic liberal arts college and a domestic non-profit corporation incorporated in Minnesota, with its principal place of business located at 2850 Abbey Plaza, Collegeville, Minnesota $6321. CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 2 of 8 JURISDICTION AND VENUE 4. Plaintiff invokes this Court’s jurisdiction pursuant to 28 U.S.C. § 1332, because the matter in controversy exceeds the sum or value of $400,000.00, exclusive of interest and costs, and is between citizens of different states. 5. This Court has personal jurisdiction over Saint John’s on the grounds that it is conducting business within the State of Minnesota. 6. Venue for this action properly lies in this district pursuant to 28 U.S.C. §1391 because Saint John’s is considered to reside in this judicial district and a substantial part of the events or omissions giving rise to the claim occurred in this judicial district. FACTUAL BACKGROUND 7. In 2004, as part of a lawsuit Plaintiff was involved in as a Plaintiff, Lindmark et al. v. Am. Express Co. et al., No. 2:00-CV-08658, C.D. Cal. (2004), Plaintiff directed a grant of $50,000.00 from the settlement fund established as part of the resolution of the lawsuit brought against American Express Company related to St. John’s. 8. This grant was made from the settlement that otherwise would have been paid directly to Plaintiff. 9. On February 9, 2004, St, John’s accepted the grant as the initial contribution to the Lindmark Endowment. A document setting forth the purpose of the Endowment was executed by Lindmark and St. John’s University President, Dietrich Reinhart. 10.In 2008, as part of a lawsuit Plaintiff was involved as an attorney, Continental Forge Co. v. Cal. Gas Co., No. BC237336 (L.A. Super. Ct.), Plaintiff directed a grant of $250,000.00 CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 3 of 8 from that settlement fund as part of the resolution of that class action lawsuit to St. John’s for the Endowment. 11. This gift was made from the settlement that otherwise would have been paid directly to Plaintiff. 12.In early 2010, Plaintiff and St. John’s executed a document (the “Amended Fund Document”) amending the Endowment. The Amended Fund Endowment recites the purpose of the Fund to be as follows: The annual endowment proceeds from the Lindmark Endowment for Corporate Business Ethics is to be used to fund programs and activities in the field of Corporate-Business Ethics in the following order of priority. 1. The Lindmark Fellowship in Ethics will be an attractive and competitive on- campus, summer undergraduate research fellowship experience for Saint John’s students who have completed their junior year. The summer award will be substantial so the recipients will have summer income in order to return to SIU. Upon completion of the 10 week summer fellowship, students will submit their work during their senior year for presentation at conferences and/or publication in professional journals. The work will also be submitted for competition in the annual undergraduate research “Scholarship and Creativity Day.” The fellowship program will be administered by Office of the Associate Provost and Academic Dean in consultation with Institutional Advancement. 2. Guest lecturers will be funded to speak on business ethics in classes offered to future executives and entrepreneurs, including in the departments of business management, accounting, economies and philosophy; such lecturers will also be invited and expected to speak to the larger campus community. 3. Corporate ethics internships will be established in partnership with several Fortune 500 companies headquartered in Minneapolis/St. Paul, and funds will provide student stipends and modest living or travel expenses. 4. Additional course offerings will be designed to complement existing courses in business, biomedical and environmental ethics and other ethics courses with the goal of strengthening the focus on ethics education specifically for students ely to pursue corporate-business careers. When additional funds are raised, Saint John's will designate one of its outstanding professors of ethics as the 3 CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 4 of 8 holder of the Lindmark Professorship in Corporate-Business Ethics. 5. A book fund will be established with the University library for the acquisition of published materials on the topic of corporate-business ethics. Awards from the Fund shall be made in a manner that is consistent with Federal and Minnesota law. A determination by Saint John’s University and its, legal counsel regarding compliance with applicable law shall be conclusive. (A copy of this Endowment Agreement is attached as Exhibit 1). 13. The primary intent of the Lindmark Endowment for Corporate-Bus ness Ethics Fund, in Plaintiff's understanding, was to provide a fellowship fund for two students for the summer between their junior and senior years to work on a substantial research project in the area of Corporate-Business Ethics by providing money to two students to allow each student to focus on this academic pursuit to enhance the student’s future with a substantial research writing sample for graduate school or employment and to further St, John’s reputation as a leader in business and corporate ethics. 14, Since at least 2010, and likely earlier, St, John’s has mishandled the Lindmark Endowment by failing to monitor and supervise the two summer student Fellows and by failing to use the funds in accordance with Amended Fund Document, which called for use of the funds in the field of Corporate-Business Ethics. 15. Since 2012, of the 10 research papers Plaintiff was provided, only one was, arguably, relevant to the stated purposes of the Lindmark Endowment in the field of Corporate- Business Ethics, with that being a paper entitled “Corporate Political Campaign Finance Ethics”, from the summer of 2012. 16. Other topics selected and approved by St. John’s and its faculty agents have included, inter alia soil conservation, wonderment in the classroom, solar power for low income people, and 4 CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 5 of 8 romance in the work place. An example of a five page, unentitled, paper drafted during the summer of 2014 is attached as Exhibit 2. This student did not fulfill the research project, with a substantive paper but was paid his $7,000.00 summer stipend from the Endowment Fund anyway. 17. Through telephone calls and emails, Plaintiff has expressed his concern with St. John’s officials regarding the administration of the Lindmark Endowment. In particular that fellowship funds are provided to students not in any way engaged in the research of Corporate-Business Ethics and that students are allowed to do irtually nothing and still receive their summer stipend of $7,000.00. These discussions did not yield any meaningful results toward resolving this dispute. 18. Unable to obtain resolution of his complaints, Plaintiff has initiated this lawsuit seeking to disband the Lindmark Endowment in Corporate-Business Ethics and seeks return of any undisbursed funds in the remaining fund balance. COUNT Breach of Contract 19, Plaintiff repeats and realleges paragraphs | through 19 as if fully set forth herein. 20. The Lindmark Endowment for Corporate-Business Ethics Instrument/Criteria Statement is a valid and enforceable agreement between the parties. 21. Plaintiff has performed all of the obligations required of him under the Corporate-Business Ethics Fund Gift Instrument/Criteria Statement. CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 6 of 8 22. As set forth above, St. John’s has materially breached the Corporate-Business Ethics Fund Gift Instrument/Criteria Statement through its failure to administer the Endowment in accordance with the Corporate-Business Ethics Fund Gift Instrument/Criteria Statement. 23. As a direct and proximate result of St. John’s promises about how the money would be used, Plaintiff granted substantial sums of money to St. John’s on the condition that it would be used to fulfill the objectives under the Corporate-Business Ethics Fund Gift Instrument/Criteria Statement. 24, As a direct, proximate, and foreseeable consequence of those breaches, Plai significant damages in excess of $400,000.00, which Plaintiff estimates to be the current balance in the Endowment Fund. COUNT II Breach of Covenant of Good Faith and Fair Dealing 25. Plaintiff repeats and realleges paragraphs | through 25 as if fully set forth herein, 26. The contract between St. John’s and Plaintiff imposed upon St. John’s a duty of good faith and dealing. 27.St. John’s breached and violated the covenant of good faith and fair dealing implied in its agreement with Plaintiff by failing to use the funds in the specified manner and by failing to fulfill the objectives under the Corporate-Business Ethics Fund Gift Instrument/Criteria Statement 28. As a direct, proximate, and foreseeable consequence of those breaches, Plaintiff sustained significant damages in excess of $400,000.00. CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 7 of 8 COUNT It Breach of Fiduciary Duty 29, Plaintiff repeats and realleges paragraphs 1 through 29 as if fully set forth herein, 30. By establishing the Lindmark Endowment for Corporate Business Ethics and undertaking the commitment to administer its funds in accordance with the terms of the Corporate-Business, Ethics Fund Gift Instrument/Criteria Statement St. John’s undertook a position of trust and a corresponding fiduciary duty toward Plaintiff to achieve the objectives of the endowment. 31.St. John’s violated its pos! ion of trust and fiduciary responsibility with Plaintiff by, among, other things, failing to perform its obligations under the Lindmark Endowment by failing to monitor and supervise the two summer student Fellows and by failing to use the funds in the Endowment for its stated purpose. 32. Accordingly, St. John’s has failed to implement the purpose of the Endowment in good faith and with the care, loyalty, and obedience an ordinarily prudent person in a like position would exercise under similar circumstances. 33. As a direct, proximate, and foreseeable consequence of those breaches, Plaintiff sustained significant damages in excess of $400,000.00. COUNTIV Conversion 34. Plaintiff repeats and realleges paragraphs | through 33 as if fully set forth herein 35. Plaintiff has requested dissolution of the Lindmark Endowment in Corporate-Business Ethics Fund and retum of the remaining money from the fund. CASE 0:18-cv-01577 Document 1 Filed 06/06/18 Page 8 of 8 36. St. John’s continues to exercise control over the assets and funds and refuses to return them to Plaintiff as held in the Lindmark Endowment in a manner that is contrary to Plaintiff's continued right to ownership and control. 37.8t. John’s exercise of this unlawful control over Plaintiff's assets and funds holds those assets for its own benefit to the detriment of Plaintiff who is denied their possession and use. 38.As a result of the actions of St. John’s, Plaintiff suffered damages in excess of $400,000.00, with the exact amount to be determined at trial, RELIEF REQUESTED WHEREFORE, Plaintiff prays that this Court enter judgment in his favor and against the Defendant and asks that this Court order the Defendant to retum all amounts remaining in the Lindmark Endowment for Corporate-Business Ethics Fund; and pre-judgment and post- judgment interest; and attorney's fees, expenses and costs; and such other relief as this Court may deem just and proper and to which Plaintiff may be entitled as a matter of law. DEMAND FOR JURY TRIAL Plaintiff demands a trial by jury of all claims so triable, Dated: June 5, 2018 MCGRAW LAW FIRM, P.A. /s/Beau D. McGraw Beau D. McGraw, LD. Ni Attorney for Plaintiff 10390 39" Street North, Suite 3 Lake Elmo, MN 55042 Telephone: (651) 209-3200 beau@megrawlawfirm.com 31190X, EXHIBIT--“1” CASE 0:18-cv-01577 Document 1-1 Filed 06/06/18 Page 1 of 5 Revised: Spring 2010 SAINT JOHN’S UNIVERSITY ‘The Lindmark Endowment for Corporate-Business Ethics Fund Gift instrument/Criteria Statement Background Consistent with its mission of values-based education and its vision to be the finest Catholic liberal arts college in America, Saint John's University wil establish the Lindmark Endowment for Corporate-Business Ethics, named in honor of 1974 graduate, attomey Roger M. Lindmark. Saint John's University is located in Central Minnesota, just outside metropolitan Saint Cloud, and 70 miles northwest of the twin cities of Minneapolis/St. Paul, Founded In 1857, it has a deep respect for the Catholic intellectual tradition and the Benedictine principles that guide it, Students come from 40 states and 37 foreign countries and trust territories. The faculty includes approximately 275 professors, among them Benedictines and lay professors with diverse religious and cultural backgrounds. The liberal arts education provided by Saint John's University is guided by the Benedictine principles of the colleges’ founders and sponsoring religious communities. The liberal arts, valuable in themselves, are the center of disciplined inquiry in ethics and values and a tich preparation for professions in business, law, medicine, education, public life and service to others in many forms of work. Roger Lindmark graduated from Saint John’s University in 1974 with a Bachelor of Arts Degree in Psychology. Following graduation, he enrolled at Long Island University in New York where he completed his Master of Arts in Clinical Psychology in 1977. In 1983, Roger received his Juris Doctor Degree from Pepperdine University in Malibu, California. Roger is currently a practicing attorney specializing in employment and labor iitigation, personal injury and appellate practice. Roger Lindmark was the lead plaintiff in an action filed in Federal District Court in Los Angeles against the American Express Company bearing Case No. 00-CV-8658 on ‘August 15, 2000 on behalf of credit card holders who incurred finance charges on ‘American Express credit cards under the "average daily balance" method of calculating interest. The plaintiffs alleged that defendants American Express Company, American Express Centuriori Bank and American Express Travel Related Services Company, Inc. (together, "American Express” or "Defendants”) charged dally compounded interest Under the average daily balance method without adequately disclosing this practice in card member agreements, allegedly in violation of certain federal and California statutes and California common law. Plaintiffs also alleged that American Express applied payments and credits to lower interest rate balances on card accounts (such as balances for promotional balance transfers) before applying them to higher interest rate balances (such as balances for purchases), that this practice wes not adequately ‘exe {4 CASE 0:18-cv-01577 Document 1-1 Filed 06/06/18 Page 2 of 5 The Lindmark Endowment for Corporate-Business Ethics Fund Page 2 disclosed to cardholders, and that it resulted in higher finance charges in alleged violation of certain federal and Califomia statutes and California common law. ‘American Express denied all of the Plaintiffs’ claims and contentions, including, among other things, that it failed adequately to disclose its practices of compounding interest on a daily rather than monthly basis and applying payments and credits first to lower interest rate balanoas. American Express agreed to settle the action solely to avoid the expense and inconvenience of further tigation As part of the Settlement, American Express in August and September 2001, mailed amendments to its card rember. agreements (the “Amendments") with respect to the above finance charge practices. The Amendments also contained disclosures regarding changes to other fees and charges, which changes were implemented in 2001 However, due to an administrative error, approximately five million American Express, cardholders did not receive the Amendments, potentially causing the members of the Delayed Notice Class to incur certain fees and other charges before they were disclosed. American Express corrected this administrative error by mailing the ‘Amendments in 2002 to cardholders who did not previously receive them. The Plaintiffs alleged that Defendants are required to refund to members of the Delayed Notice Class all fees and charges pald between September 1, 2001, and September 15, 2002 based on the Amendments. The Cy Pres Settlement Gift To establish the Lindmark Endowment for Corporate-Business Ethics an initial donation and gift by American Express Company of $50,000 was received as directed and stipulated to by the parties to the Lindmark v. American Exoress (Case No. 00-CV- 8658) Settlement, which requires a cy pres donation to “compensate society.” The sift will be made to Saint John’s University (SU), an operating division of the Order of St. Benedict, a Minnesota corporation. In addition, Saint John’s will acgept additional support for this endowment fund from alumni, corporations and other businesses who seek to promote the highest standard of ethics in the education of our nation’s future generations of executives arid entrepreneurs. Saint John’s shall hold the Fund and all additional gifts to it as an endowed fund. Account No.: 66010-92060 58854 2600 CASE 0:18-cv-01577 Document 1-1 Filed 06/06/18 Page 3 of 5 ‘The Lindmark Endowment for Corporate-Business Ethics Fund Page 3 Purpose The annual endowment proceeds from the Lindmark Endowment for Corporate- Business Ethics is to be used to fund programs and activities in the field of Corporate- Business Ethics in the following order of priority. 1 3. The Lindmark Fellowship in Ethics will be an attractive and competitive on- campus, summer undergraduate research fellowship experience for Saint John's students who have completed their junior year. The summer award will be substantial so the recipients will have summer income in order to retum to SJU. Upon completion of the 10 week summer fellowship, students will submit their work during their senior year for presentation at conferences andlor publication in professional journals. The work will also be submitted for competition in the annual undergraduate research “Scholarship and Creativity Day.” The fellowship program will be administered by Office of the Associate Provost and Academic Dean in consultation with institutional Advancement. Guest lecturers will be funded to speak on business ethics in classes offered to future executives and entrepreneurs, including in the departments of business management, accounting, economics and philosophy; such lecturers will also be invited and expected to speak to the larger campus community. Corporate ethics internships will be established in partnership with several Fortune 500 companies headquartered in Minneapolis/St, Paul, and funds will provide student stipends and modest living or travel expenses, Additional course offerings will be designed to complement existing courses in business, blomedical and environmental ethics and other ethics courses with the goal of strengthening the focus on ethics education specifically for students likely to pursue corporate-business caréers. When additional funds are raised, Saint John's will designate one of its outstanding professors of ethics as the holder of the Lindmark Professorship in Corporate-Business Ethics. ‘book fund will be established with the University library for the acquisition of published materials on the topic of corporate-business ethics. ‘Awards from the Fund shall be made in a manner that is consistent with Federal and Minnesota law. A determination by Saint John’s University and its legal counsel regarding compliance with applicable law shall be condusive. CASE 0:18-cv-01577 Document 1-1 Filed 06/06/18 Page 4 of 5 The Lindmark Endowment for Corporate-Business Ethics Fund Page 4 Payout 1. To further the purpose of the Fund, Saint John’s University shall pay out an annual amount (“the draw”) determined by the endowment spending policy currently approved by Saint John's University’s Board of Regents for its endowment funds. 2. For any year in which the aggregate net income and appreciation on the Fund's assets ("return") exceeds the draw from the Fund for that year, the excess shall be accumulated in the Fund, For any year in which the return on the Fund's assets is less than the draw from the Fund for that year, accumulated return and amounts representing contributions to the Fund, in that order, shall be used lo pay the difference. Reservation Because circumstances change from time to time, It is possible that the above criteria for making awards cannot be met at some future date (e:g., a major or program is. dropped from the curriculum, so awards in that field can no longer be made). In such a case, after consultation with all available living donors who signed the document that governs the Fund, the Board of Regents may modify the award criteria in a way that it deems appropriate. In all cases, the intent of the donors to the Fund shall be foremost in this process, and new criteria shall adhere as closely as practical to the original criteria. ‘The Fund shall be subject to Saint John's University’s Articles of Incorporation, Bylaws, and Investment Guldelines as they may be amended from time to time. Administration Saint John’s University may commingle the assets of the Fund with assets of its other ‘endowment funds for purposes of investment but shall keep separate records and books of account with respect to the Fund. Saint John’s University shall place the assets of the Fund under the management and direction of one or more of the investment advisors that it uses from time to time in managing its other endowment assets, and Saint John’s University shall manage the Fund according to its prevailing investment policies for its endowment funds. CASE 0:18-cv-01577 Document 1-1 Filed 06/06/18 Page 5 of 5 The Lindmark Endowment for Corporate-Business Ethics Fund Page S Miscellaneous Matters This document constitutes a “gift instrument’ within the meaning of and governed by Minnesota's Uniform Prudent Management of Institutional Funds Act, and this document constitutes the entire gift instrument with respect to all gifts to which it applies, The Fund does not constitute a trust. The laws of the State of Minnesota relating to ‘endowment funds shall govern this gift instrument and the Fund. Notification ‘Anannual report of the Lindmark Endowment for Corporate-Business Ethics Fund activities and information concerning the investment performance of the endowment with the new fund balance shall be sent to: Roger M. Lindmark, Esq. 1429 South Bedford Street Los Angeles, CA 90035 Donor’s Signature %, % % Acceptance ‘The undersigned gratefully accepts on behalf of Saint John’s University the establishment of the Lindmark Endowment for Corporate-Business Ethics Fund together with the criteria and terms of the gift as specified above. Date: Lure 1%, 201d. wf Assdciate Vice President for Development EXHIBIT--“2” CASE 0:18-cv-01577 Document 1-2 Filed 06/06/18 Page 1 of 5 Tanner Wright, Lindmark Fellow My experience with the Lindmark Fellowship had its ups and downs as | researched throughout the summer. When I first applied to the fellowship, I was set on researching the moral obligations that authors have in th literature. My original aspiration transformed under the guidance of my adviser into a project that was geared toward the role of literature in the pursuit of moral truths. This path led me to reading many works by Martha Nussbaum, Wayne Booth, and various articles written by a plethora of theorists. In this research, I learned the basic foundation of many different arguments for this topic. 1 began to try to formulate my own argument after spending a majority of the summer reading. My original attempt at a paper aimed to create a distinct relationship between literature and the individual that allowed for the revelation of moral truths. However, I turned in my first 35 pages of my research paper to my adviser and his comments pushed me into a new realm of inquiry. I began to wonder about the role of the emotions as a conduit for morality. This inquiry shaped my second draft as | scrapped the first draft. My new thesis came to fruition as an argument against Kant and his view that the emotions are not able to yield moral truths. In this draft of the paper, I misunderstood Kant's allowance for ‘emotions in certain circumstances. This draft was not eloquent and it was not up to par. I rushed through the draft and I did not give it the best effort that it deserved. The summer fellowship had expired and I did not have a product that I considered worthy of submission. I was planning on finishing a final draft by September 15" but I had family matters that I needed to attend. However, | am currently taking my time to ensure that | finish a paper that I am proud to put my name on. The new paper is a combination of my first and second drafts. | aim to demonstrate that literature is a complete friend (Aristotelian terminology) and can help us come to ‘an understanding of morality. Friendship is one of the greatest ways to find the good in life and it is something that | hold dear in my personal life as a virtue. The emotional attachments are influential in our lives and show us what is acceptable and what we CASE 0:18-cv-01577 Document 1-2 Filed 06/06/18 Page 2 of 5 wwe should abstain. Therefore, | am trying to articulate an argument that denies Kantian’s hesitation toward emotional intimate ‘clationships as conduits for morality then | can deduce that literature attends to our emotions in the same manner as a friend and thus, literature can yield moral truths by representing the emotional aspects of life. The Lindmark Fellowship was a very beneficial experience for me. The Lindmark Fellowship allowed me the ability to ‘esearch a topic that | find very interesting. It was very intriguing to see the intersection between my majors, philosophy and English. | did not know that there was such a great debate and overlapping material between the two disciplines. 1 found it very interesting to see the history between the two disciplines on my topic. The fellowship was also beneficial for my personal development. | leamed many key life lessons such as time ‘nanagement, self-discipline, and the woes of indecisiveness. T fellowship was very liberating in regards to time management, It was not an 8-5 job but rather it was very independent. It was my job to make sure that I worked my hardest and for the full time. Time management and the woes of indecisiveness are tied together as my time management was poor ‘oward the end of the summer. | spend the first eight weeks of the summer with reading of many different texts and articles. 1 focused so much on the reading aspect that the writing portion suffered. My first two drafts were not up to part and I believe that my time management was a leading cause. | should have spaced out writing in between my readings so that I could begin to formulate my argument while continuing to deepen my understanding of the material. Self-discipline was a very big life lesson that | learned over the summer. Self-disciplin is something that I have struggled with ever since | was a little kid as | ‘would rather do the “fun” things instead of that which is my duty. There were times when I was tempted to go fishing, or go throw the pigskin in the gorgeous weather. I leamed to control myself and to discipline myself to limit these distractions while Ineeded to work. When I worked, I would eradicate distractions by turning off the television, shutting my door, and closing my computer when I was not reading an article that was not online. | believe that this summer was one of the first times that I felt that 1 took control of myself and limited my desires while focusing on the work that I needed to accomplish. When I say the Woes of indecisiveness, | refer to the fact that my main argument changed three different times. 1 tussled with the moral CASE 0:18-cv-01577 Document 1-2 Filed 06/06/18 Page 3 of 5 sbligations of authors, the role of literature in morality, and the role of the emotions in morality. I needed to have on clear ‘ocus from the start and I failed to adequately decide which one that | should pursue wholeheartedly. Instead, | changed topics nore times and | believe that it caused my overall product to suffer. If were to have an opportunity to start the summer over, there would be a few things that | would have done Jifferently. First off, | would ick to one specific topic for the course of the whole summer. It is true that sometimes research shifts after learning more information. However, my topic shifted a couple times but the shifts came late in the summer. My ‘rst shift came in the ninth week of my summer after the first thirty pages. Under the discretion of my adviser, | moved onto a different aspect of ethics and how the emotions influence morality. It was difficult to work on this topic because my summer. “esearch was focused on the role of literature in morality. | believe that it would have been better if | stayed on one topic nstead of changing so late in the summer. Another change that | would make is to write the paper as I read. | feel as if | struggled in the writing portion because | would be writing about topics that I had read eight weeks prior. | took notes as | read. The notes were clear to me but it was difficult to recall the entirety of the author's intentions, tone, and specific examples for their arguments. | believe that it would have been better to read and write simultaneously. While reading and then writing is beneficial to some, I have found that it is not my style. | like to be able to express my own ideas of what I'm reading through writing as | am reading many different ideas on the same topic. Therefore, writing while reading would have been more beneficial for me as | could sort through my ideas in a more coherent manner. Overall, this summer was a great experience for me as I found out many things about myself that | would not have discovered working at a “high school” job. As I previously stated, | learned many life lessons as well as learning about myself and how | operate. | am disappointed in myself that I have not finished a full length paper at the current moment because of the reasons that I have listed. 1am currently working on a new paper that unites the first two papers. 1 will analyze how literature CASE 0:18-cv-01577 Document 1-2 Filed 06/06/18 Page 4 of 5 slays a role in morality by accessing the emotions. The emotions demonstrate the cares and concems of the individual in the ‘vorld and what is important. Literature has the ability to access these emotions in representations of real life (in the cases of jection) to demonstrate the moral laws of society. I hope to present this paper as a poster session during Scholarship and Creativity Day in the spring. Even though things did not turn out how I had hoped over the summer, | am determined to finish what | started with the topic that I have chosen. | would like to say thank you for a great opportunity and I will finish this vaper. Attached below is a bibliography of what | have read this summer which includes articles and full books. Works Cited 3elluck, Pam. "For Better Social Skills, Scientists Recommend a Little Chekhov." Well For Better Social Scientists Recommend a Little Chekhov Comments. Web Booth, Wayne C. The Company We Keep: An Ethics of Fiction. Berkeley: U of California, 1988. Print. “aws, Mary Ann, "Moral-Reading, or Self-Containment with a Flaw."JSTOR. The John Hopkins University Press, Web. Cunningham, Anthony. The Heart of What Matters: The Role for Literature in Moral Philosophy. Berkeley: U of California, 2001. Print. Diamond, Cora. "Having a Rough Story about What Moral Philosophy Is." JSTOR, John Hopkins University Press, 1983. Web. Gardiner, Patrick. "Response to Nussbaum by Professor Nussbaum on The GoldenBowl." JSTOR. New Literary History, Web. George, Stephen K. "Against Ethical Criticism." Ethics, Literature, and Theory: An Introductory Reader. Lanham, MD: Rowman & Littlefield, 2005. Print. Harpham. Geoffrey Galt "Ethies." Critical Terms for Literary Study. Chicago: The University of Chicago Press. 1995 Credo Reference. Web. Johnson, Charles, "The Truth-Telling Power of Fiction." The Chronicle of Higher Education Web. Leddy, Chuck. "Truth in Fiction." Harvard Gazette. Web. Morrison, Toni. Beloved: A Novel. Knopf Doubleday Group, Print. Nussbaum, Martha Craven. "Flawed Crystals: James's The Golden Bowl and Literature as Moral Philosophy.” JSTOR. Web. Nussbaum, Martha Craven, Love's Knowledge: Essays on Philosophy and Literature. New York: Oxford UP, 1990. Print EEE CASE 0:18-cv-01577 Document 1-2 Filed 06/06/18 Page 5 of 5 Nussbaum, Martha C Web. 30 June 2014 iterature and Ethi Enevelopedia of Ethics. London: Routledge. 2001 Credo Reference. Nussbaum, Martha Craven. "Reply to Richard Wollheim, Patrick Gardiner, and Hilary Putnam." JSTOR. The John Hopkins Jniversity Press, Web. Nussbaum, Martha Craven, The Fragility of Goodness: Luck and Ethics in Greek Tragedy and Philosophy. Cambridge: Cambridge UP, 1986. Print. >utnam, Hilary. "Taking Rules Seriously: A Response to Martha Nussbaum."JSTOR. The John Hopkit ress, Web. University Raphael, D. D. "Can Literature Be Moral Philosophy.” JSTOR. The John Hopkins University Press, 1983. Web. Raphael, D. D. "Philosophy and Rationality: A Response to Cora Diamond." JSTOR. John Hopkins University Press 1983. Web, Robinson, Sal. "Stanford Center for Ethics Panel Finds That Reading Literature Makes You a _Better Bully” Melville House Books, Web. Romano, Tom. "The Way Writing Works." JSTOR. National Councils of Teachers of English, Web. Siskind, Patrick. Perfiume. London: Penguin Classics, 2010. Print. Tiemey, Robert J., and Jill LaZansky. "The Rights and Responsibilities of Readers and Writers: A Contractual Agreement." JSTOR. National Councils of Teachers of English, Web. Wollheim, Richard. "Flawed Crystals: James's The Golden Bow! and the Plausibility of Literature as Moral Philosophy." JSTOR. The John Hopkins University Press, Web.

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