Duke's Response To Thackurdeen Lawsuit

UNITED STATE DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
Roshni D. Thackurdeen, and Raj B.

Thackurdeen, individually and in their
capacity as Co-Administrators of the Estate
of RAVI THACKURDEEN, Case No. 1:16CV01108
Plaintiffs,
vs.
DUKE UNIVERSITY, a North Carolina
corporation; ORGANIZATION FOR
TROPICAL STUDIES, INC., a North
Carolina corporation; and DOES 1-20,
Defendants.
ANSWER OF DEFENDANT DUKE UNIVERSITY
NOW COMES a Defendant in the above-captioned matter, DUKE UNIVERSITY,
incorrectly sued as Duke University, a North Carolina Corporation, pursuant to
Fed.R.Civ.P. Rule 12 and, answering the Complaint of the Plaintiffs, alleges and states
that:
FIRST DEFENSE TO ALL CLAIMS FOR RELIEF
THE PARTIES
1. Duke University admits on information and belief that Plaintiffs Roshni D.
Thackurdeen and Raj B. Thackurdeen were, at all times relevant to the Complaint,
citizens and residents of the State of New York, that they are the parents of Ravi
Thackurdeen and that at the time of his death, Ravi Thackurdeen was a citizen and
WCSR 38442254v1
Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 1 of 15

resident of the State of New York. Except as stated, Duke University is without
knowledge or information sufficient to form a belief as to the truth or falsity of the
allegations of this paragraph.
2. Duke University admits that at all times relevant to the Complaint it was an
educational institution organized and existing under the laws of the State of North
Carolina and that its principal campus and principal administrative offices are located in
Durham, North Carolina. Except as stated, Duke University denies the allegations of this
paragraph.
3. Duke University admits on information and belief that the Organization for
Tropical Studies, Inc., is a corporation organized and existing under the laws of the State
of North Carolina with its principal place of business in Durham, North Carolina. Except
as stated, Duke University is without knowledge or information sufficient to form a belief
as to the truth or falsity of the allegations of this paragraph.
4. Duke University is without knowledge or information sufficient to form a
belief as to the truth or falsity of the allegations of this paragraph except that Duke
University denies that the Plaintiffs have any right to amend the Complaint.
VENUE AND JURISDICTION
5. Duke University admits, on information and belief, that this Court has
jurisdiction under 28 U.S.C. 1332(a)(1) premised upon the existence of diversity in that
the parties appear to be citizens of different States.
2
WCSR 38442254v1

6. Duke University admits that the Plaintiffs have alleged that the damages in
this case exceed seventy-five thousand dollars ($75,000). Except as stated, Duke
University denies the allegations of this paragraph.
7. Duke University denies the allegations of this paragraph.
FACTUAL BACKGROUND
belief as to the truth or falsity of the allegations of this paragraph.
10. Duke University admits that, for the Spring Semester of 2012, Ravi
Thackurdeen enrolled in a Duke University administered Global Education Program
organized and operated by the Organization for Tropical Studies (OTS), a separate
entity that is separately incorporated and has its own Board of Directors, and that the
successful completion of the course of studies administered by OTS made Ravi
Thackurdeen eligible for credits to be transferred to Thackurdeen s college, Swarthmore,
by Duke University. A copy of the application and enrollment forms relating to Ravi
Thackurdeen is attached to this Answer as Exhibit 1. Duke University denies that at any
time Ravi Thackurdeen was admitted as a student to Duke University or was a student at
Duke University. Duke University further admits that OTS is a separate legal entity and
that the relationship between OTS and Duke University is set forth in the Memorandum
of Understanding attached to this Answer as Exhibit 2. Except as stated, Duke
3
WCSR 38442254v1

University is without knowledge or information sufficient to form a belief as to the truth
or falsity of the allegations of this paragraph.
belief as to the truth or falsity of the allegations of this paragraph as to OTS. Duke
University denies the allegations of this paragraph.
17. Duke University admits on information and belief that Ravi Thackurdeen
died on April 29, 2012. Except as stated, Duke University is without knowledge or
information sufficient to form a belief as to the truth or falsity of the allegations of this
paragraph.
18. Duke University admits that the Assistant Vice Provost for Duke
Universitys Global Education Program, once advised by OTS employees that Ravi
Thackurdeen was missing in Costa Rica, telephoned from Durham and spoke with his
4
WCSR 38442254v1

relatives, informed them that Ravi Thackurdeen was missing in the ocean at that time,
and provided them with direct contact information for OTS employees in Costa Rica.
Except as stated, Duke University denies the allegations of this paragraph.
19. Duke University admits that the Thackurdeens made arrangements to travel
to Costa Rica. Except as stated, Duke University denies the allegations of this paragraph.
20. Duke University admits on information and belief that, accompanied by
OTS employees, the Thackurdeens were taken to the area in Costa Rica where Ravi
Thackurdeen was last seen. Duke University denies that its employees were in Costa
Rica at any time relevant to Ravi Thackurdeens death. Except as stated Duke University
is without knowledge or information sufficient to form a belief as to the truth or falsity of
the allegations of this paragraph.
21. Duke University denies that its employees were in Costa Rica at any time
relevant to Ravi Thackurdeens death. Except as stated Duke University is without
22. Duke University admits on information and belief that Ravi Thackurdeens
body was found on May 1, 2012.
relevant to Ravi Thackurdeens death. Except as stated Duke University is without
5
WCSR 38442254v1

24. Duke University denies the allegations of this paragraph and adopts by
reference and incorporates Exhibit 1 and Exhibit 2.
25. Duke University admits the allegations of this paragraph on information
and belief.
26. Duke University admits the allegations of this paragraph on information
and belief.
27. Duke University adopts by reference and incorporates Exhibit 1 and
Exhibit 2. Duke University denies the allegations of this paragraph.
28. Duke University admits that it recognized and warned the Plaintiffs,
including Ravi Thackurdeen, of the risks of international travel and that the Plaintiffs,
including Ravi Thackurdeen, acknowledged those risks (including death) as set forth in
Exhibits 3 and 4, and further released Duke University from any liability whatsoever and
otherwise released, indemnified and discharged Duke University from all liability arising
from death or personal injury. Duke University further admits that the
acknowledgements and waivers set forth in Exhibits 3 and 4 were conditions precedent
to consideration for acceptance by OTS into its educational programs. Duke University
further admits that it has formed oversight committees and otherwise acted in a
reasonable fashion to address the opportunities and risks of international travel. Except
as stated, Duke University denies the allegations of this paragraph.
29. Duke University denies that it promoted its OTS program and otherwise
denies that it is anything other than a separate entity from OTS. Duke University adopts
6
WCSR 38442254v1

by reference and incorporates the contents of Exhibit 1 and Exhibit 2. Except as stated,
Duke University denies the allegations of this paragraph.
30. Duke University denies that it allowed Ravi to die in the waters of Costa
Rica or that its employees were in Costa Rica at any time relevant to Ravi Thackurdeen
s death. Duke University admits that it has experience with international programs and
has a deep commitment to the safety of its students. Except as stated, Duke University
denies the allegations of this paragraph.
relevant to Ravi Thackurdeen s death and otherwise denies that it is anything other than
a separate entity from OTS. Duke University adopts by reference and incorporates the
contents of Exhibit 1 and Exhibit 2. Except as stated, Duke University denies the
33. Duke University denies the allegations of this paragraph on the grounds
that these are not allegations of fact made to support a claim for relief, but are argument
and thus improper.
34. Duke University admits on information and belief the allegations of this
paragraph.
35. Duke University denies the allegations of this paragraph as applied to the
factual circumstances of this Complaint.
7
WCSR 38442254v1

37. Duke University denies the allegations of this paragraph as applied to the
factual circumstances of this Complaint except that, to the extent that the Complaint
alleges that Ravi Thackurdeen as a weak or non-swimmer[ ], Duke University is
without knowledge or information sufficient to form a belief as to the truth or falsity of
that allegation.
39. Duke University admits on information and belief that warnings and
cautions about swimming in the waters of Costa Rica are abundant and were available
to all, including Ravi Thackurdeen, and that these warnings were communicated to Ravi
Thackurdeen by OTS employees and others. Except as stated, Duke University denies
the allegations of this paragraph.
40. Duke University admits on information and belief that drownings occur in
the waters off of Costa Rica and that many involve rip tides, rip currents, and other
common causes of drowning, and that the overall incidence of drowning in Costa Rica as
a function of the number of swimmers and swimming episodes is small and not
statistically different than many beaches in the United States of America. Except as
stated, Duke University denies the allegations of this paragraph.
8
WCSR 38442254v1

FIRST CLAIM FOR RELIEF
SURVIVAL CLAIM BASED ON NEGLIGENCE
43. Duke University adopts by reference and incorporates its response to each
allegation of the Complaint.
46. Duke University denies the allegations of this paragraph and each subpart
thereof.
SECOND CLAIM FOR RELIEF
WRONGFUL DEATH
THRID CLAIM FOR RELIEF
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
9
WCSR 38442254v1

SECOND DEFENSE: RELEASE, WAIVER AND DISCHARGE
The Complaint, and each cause of action set forth in the Complaint, is and are
barred by the releases set forth in Exhibit 3 and 4, executed by Ravi Thackurdeen and the
Plaintiffs. Specifically, in two separate releases, Ravi Thackurdeen and the Plaintiffs:
(1) released Duke University from all liability in damages for any injury or loss to
person . . . and we hereby release Duke University, its trustees, officers agents and
employees from any liability whatsoever for personal injury or property damage arising
from participation in the program, (2) RELEASE[ED], WAIVE[ED],
DISCHARGE[ED], AND COVENANT[ED] NOT TO SUE . . . Duke University, its
trustees, officers, employees, or agents . . . for any liability, claim, and/or cause of action
arising out of or related to any loss, damage, or injury, including death . . . as a result of
my traveling to and from, and participation in this activity, (3) agreed to indemnify and
hold harmless Duke University from negligence or the negligence of any third party, and
10
WCSR 38442254v1

(4) agreed to release Duke University from any liability from any injuries arising out of a
deviation from the activities.
Ravi Thackurdeen and the Plaintiffs further expressed the written intent that these
releases shall bind the members of my family . . . and my heirs, assigns and personal
representatives, if I am deceased, and shall be deemed as a RELEASE, WAIVER,
DISCHARGE, and COVENANT NOT TO SUE.
Execution of these releases, waivers, discharges and covenants not to sue were
conditions precedent to consideration for admission to the OTS program.
THIRD DEFENSE: CONTRIBUTORY NEGLIGENCE
The claims set forth in the First and Second Claims for Relief are barred by Ravi
Thackurdeens failure to exercise reasonable care and that this failure contributed to his
death. Specifically, Thackurdeen failed to exercise reasonable care in swimming at a
time and in a place where he was aware that there were potential dangers, in a manner
that increased the risk to him, and failed to take into account his limitations as a
swimmer. In addition, Thackurdeen failed to follow the instructions that he had been
given concerning the currents, and otherwise failed to act as would a reasonable person
under the same or similar circumstances. To the extent that the THIRD CLAIM FOR
RELIEF is premised on alleged actions or omissions that occurred before or in
connection with the death of Ravi Thackurdeen, Duke University specifically pleads this
defense as a bar to the claims of the THIRD CLAIM FOR RELIEF.
11
WCSR 38442254v1

FOURTH DEFENSE: ASSUMPTION OF RISK
The claims set forth in the First and Second Claims for Relief are barred by Ravi
Thackurdeens assumption of the risks of the activity. In support of this FOURTH
DEFENSE, Duke University adopts by reference and incorporates the matters set forth in
its THIRD DEFENSE.
In addition, in the materials attached as Exhibits 3 and 4, Thackurdeen and his
parents both acknowledged and stated that by participating in this activity I will
ASSUME THE RISK of injury and damage from risks and dangers that are inherent in
any activity.
To the extent that the THIRD CLAIM FOR RELIEF is premised on alleged
actions or omissions that occurred before or in connection with the death of Ravi
Thackurdeen, Duke University specifically pleads this defense as a bar to the claims of
the THIRD CLAIM FOR RELIEF.
FIFTH DEFENSE: STATUTE OF LIMITATIONS

The claims set forth in the Complaint are barred by the applicable statutes of
limitations, N.C.G.S. 1-52 and 1-53.
SIXTH DEFENSE: PUNITIVE DAMAGES
To the extent that the Plaintiffs seek an award of punitive damages, the allegations
for such damages as set forth in the Complaint fail to state a claim upon which relief may
be granted under N.C.G.S. Chapter 1D; this defense is interposed pursuant to
Fed.R.Civ.P. Rule 12(b)(6).
12
WCSR 38442254v1

SEVENTH DEFENSE: FAILURE TO COMPLY WITH FED.R.CIV.P. RULE 4(m)
Pursuant to Fed.R.Civ.P. Rule 4(m), the Plaintiffs failed to serve a valid summons
within the time prescribed by Rule 4(m). To the extent that this Plaintiffs failure to
serve a valid summons within the time prescribed by Rule 4(m) makes process
insufficient, Duke University further pleads insufficiency of process and service of
process as defenses pursuant to Fed.R.Civ.P. Rules 12(b)(4) and 12(b)(5).
WHEREFORE, having fully answered the Complaint of the Plaintiffs, Duke
University prays that:
1. The Plaintiffs have and recover nothing;
2. The claims of the Plaintiffs be dismissed or otherwise barred pursuant to
the defenses set forth in this Answer;
3. The costs of this action be taxed against the Plaintiffs;
4. This court order such further relief as it deems just and appropriate.
13
WCSR 38442254v1

This 24th day of February 2017.
/s/ James P. Cooney III

James P. Cooney III
N.C. State Bar #12140
Marcey R. Selle
N.C. State Bar #22298
WOMBLE CARLYLE SANDRIDGE & RICE, LLP
One Wells Fargo Center, Suite 3500
301 South College Street
Charlotte, NC 28202-6037
Telephone: 704.331.4980
Facsimile: 704.338.7838
E-Mail: jcooney@wcsr.com
E-Mail: mselle@wcsr.com
Attorneys for Defendant Duke University,

incorrectly sued as Duke University, a North
Carolina Corporation
14
WCSR 38442254v1

CERTIFICATE OF SERVICE
I hereby certify that on the 24th day of February, 2017, I electronically filed the
foregoing ANSWER with the Clerk of Court using the CM/ECF System, which will send
notification of such filing to the following:
James A. Roberts, III Tina Glandian, Esq.

jar@lewis-roberts.com tina@geragos.com
Jessica E. Bowers Ben Meiselas, Esq.
jeb@lewis-roberts.com meiselas@geragos.com
LEWIS & ROBERTS, PLLC GERAGOS & GERAGOS, APC
P.O. Box 17529 644 S. Figueroa Street
Raleigh, NC 27619-7529 Los Angeles, CA 90017
Local Civil Rule 83.1 Counsel Attorneys for Plaintiffs

for Plaintiffs
Reid L. Phillips
rphillips@brookspierce.com
William Michael Dowling
mdowling@brookspierce.com
BROOKS, PIERCE, MCLENDON,
HUMPHREY & LEONARD, LLP
2000 Renaissance Plaza
230 North Elm Street
Greensboro, NC 27401
Attorneys for Defendant
Organization for Tropical Studies,
Inc.
/s/ James P. Cooney III

James P. Cooney III
Attorney for Defendant Duke University,
incorrectly sued as Duke University, a North
Carolina Corporation
15
WCSR 38442254v1

EXHIBIT 1
Application and Enrollment Form
Case 1:16-cv-01108-NCT-JLW Document 66-1 Filed 02/24/17 Page 1 of 24

Ravi Thackurdeen - OTS/Global Health Tropical Medicine and Public Health ... Page 1 of 10
DUKE UUIVERSIr ._....,_--- ......_... _.__ _.. _.__ ._.._._..........
0 Gl ob al Education
_....._. _. _.._..__.. ..._____ Off ie I(Nl U[gUtA 14AptlA0:!,
Created: 04/20/2011 (by Applicant)

Last Updated: 01/09/2012 @ 09:23:16 AM
Last Viewed by Applicant: 01/08/2012
ID# 11528:no label
Applicant Information
Gender: M
Date of Birth: 06/06/1992
Confidentiality Flag:
Email Address: rthacku2@swarthmore.edu
SMS Email Address:
CC Email Address:
Home institution SWARTHMORE COLLEGE
Custom Parameters
Nickname: Ray
Country of Birth: United States of America
State/Province of Birth: NY
City of Birth: Long Island
U.S. Citizenship Status: US Citizen
Country of Citizenship: USA
Country of Citizenship Code:
I
Are you Hispanic or Latino?: No
Ethnicity: I choose not to reply
Second Citizenship:
Duke Student ID Number: rl 1
~
Major:
https://borodin ,aas.duke,edu/index.cftn?FuseAction7-StudentAdmin.PrintApplication 4/30/2012

Ravi Thackurdeen - OTS/Global Health - Tropical Medicine and Public Health -... Page 2 of 10
3.75
i
Date: Value(s):
06/04/2011 @ 09:38:56 3.75
AM (Current)
04/20/2011 t@
a 02:12:48 3.67
PM
Class of 2014
Sophomore
9176587207
2011-2012
Spring 2012
512
S12
Yes
Addresses on File:
Campus Address:
Address not on file.
Home Address:
5 Anchor Drive
Newburgh, NY 12550
f United States
,(8457844499
Parent I Address:
15 Anchor Drive
Newburgh, NY 12550
I United States
8457844499
Addressee Name: Raj Thackurdeen
Relationship: Father
https://borodin.aas.duke.edu/index.cfm?FuseAction=StudentAdmin,PrintApplication 4/30/2012

Ravi Thackurdeen - OTS/Global Health - Tropical Medicine and Public Health Page 3 of 10
United States
1 8457844499
I Addressee Name: Roshni Thackurdeen
Relationship: Mother
Mailing Address:
5 Anchor Drive
Newburgh, NY 12550
United States
8457844499
Program & Term

Program:
OTS/Global Health - Tropical
Medicine and Public Health
(San Jose)
Term:
Spring, 2012
Application Status
Status : I Enrolled
Decision
Date: 02/08/2011 (This date is specific
to this program.)
Application Comments
CommenterDate,Comments
Responses for "General Application"

Instructions:
In addition to this questionnaire, please make sure to complete the "Additional

Information" and "Addresses" sections on your applicant homepage so that we will have
all the necessary information for processing your application.
DUKE STUDENTS: Upon submission of the General Application questionnaire the GEO-U will conduct a check of
your academic and disciplinary record to determine study abroad eligibility.
1. Parent/Guardian I Fir st Name

Rai
2. Pa rent/G ua rdia n I Last Name
Thackurdeen
3. Parent/Guardian I E-mail
fo p936@ao l.co m
4. Parent/Guardian 2 First N ame ^~
https://borodin.aas.duke.edu/index.cfm?FuseAction=StudentAdmin.PrintApplication 4/30/2012

Ravi Thackurdeen - OTS/Global Health Tropical Medicine and Public Health -... Page 4 of 10
I Roshni
8. Parent/Guardian 2 Last Name
Thackurdeen
6. Parent/Guardian 2 E-mail
rthackur@aoLcom
7. Study Abroad Advisor
If you are a non-Duke student, please enter the name of your study abroad advisor at your
institution. Duke students do not need to answer this question.
Patricia Martin
8. Study Abroad Advisor E-mail
pmartinlswarthmore.edu
9. Study Abroad Advisor Phone
6103288451
10. Please list your native or first language.
English
11. Additional languages
Please list any additional languages you speak, including number of years of study and your level of
speaking, comprehension, reading and writing. Please use the following scale: poor, fair, good,
excellent.
At the time of entrance into the program, I will have the equivalent of two semesters of college level
Spanish instruction. I have current permission to enter into SPAN 002 B - Intensive Spanish for
Advanced Beginners (Prof. Olga Ferrer,osendral@swarthmore.edu ), an instruction course with an
accompanied drill session, equivalent to Duke's Spanish 14.
12. Current courses
Please list your current courses in progress including the course title, expected credit, and instructor.
(Example: PubPol 166 - The Insurgent South, 1 credit, Professor Korstad)
CHEM 32 - Organic Chemistry II, 1 credit, Prof. Robert Paley PHYS 3 General Physics 1, 1 credit,
Prof. Carl Grossman SOAN 43E - Health, Culture, & Illness, I credit, Prof. Christine Schuetze SPAN
2B - Intermediate Spanish for Advanced Beginners, 1.5 credits, Prof. Olga Ferrer
13, If your current major is undeclared, what is your intended major?

Biology
14. Do you currently have a valid passport?
If you do not yet have a passport, apply for one immediately. Passport processing can take 6-8 weeks
or more.
YES
15. If you have lived, studied, or traveled in a foreign country, state where and when.
I have traveled to the following places: Grenada, January 2011 Canada, Summer 2010 Scotland,
Summer 2010 Trinidad & Tobago Puerto Rico Dominican Republic Germany Austria Bulgaria
https://borodin.aas.duke.edulindex.cfm ?FuseAction=StudentAdmin.PrintApplication 4/30/2012

Ravi Thackurdeen - OTS/Global Health - Tropical Medicine and Public Health -... Page 5 of 10
16. Will you be participating in Duke Engage in conjunction with your study abroad? (Duke
Students Only)
If you answer yes, please describe your Duke Engage p roject. Non-Duke students s ho uld select "No"
NO
17. Contact List
May the Global Education Office for Undergraduates at Duke University release your name, address,
em ail, and phone number t o other interested Duke p a rties or fel l o w p rogram students?
YES
18. H ow d id you hear about Duke Global Education ?
Professor
Instructions:
1. Personal Statement
Drenched with creeks of tears meandering about the cheeks of my grimaced face, I laid clutching a
blanket and my ears eighteen years ago. My mother knew the antibiotics would not be ready until the
next day, and that would mean the constant visuals of her little child distraught with what seemed the
worst of earaches. It seemed to recall her very own experiences with earaches, and she reverted to her
childhood memories back in Trinidad, 1968. She knew what she had to do.
A skewered garlic roasted as my mother slowly turned it over the stove, making the outside charred,
whilst the insides turned to a pungent slurry, With the garlic paste removed, she blended it into in a
ladle of olive oil. After steeping and cooling, relief was poured into my ears.
1 It was an experience I did not recall until I was reminded this past summer. After shadowing an
~
i integrative pediatrician at Bambini Pediatrics, I was shocked by the prescriptions he handed out, so I
told my mother every day. For colds, there was elderberiy extract, For colic, there was probiotics and
gripe water. And for earaches, of all things, he prescribed garlic and olive oil. The very same
concoction my mother brewed for me eighteen years ago, and my grandmother brewed for her back in
a third world country in the nineteen-sixties. What past doctors once called "bush-medicine," this
cultural wisdom to treat illnesses has become legitimatized through research, and even prescribed by
integrative physicians.
When I told my mother about the garlic and olive oil, she reciprocated with her childhood experiences
of the same nature. We sat for the next two hours discussing the ethnomedicine of Trinidad.
https://borodin ,aas.duke.edu/index.cfm?FuseAction=StudentAdmin.PrintApplication 4/30/2012

However, many other idiosyncratic uses of plants, Trinidadian culture included, have not explored by
science. Generations upon generations have lived without the advances of modern science, whether it
may be due to poverty or isolation, These people have managed to employ their indigenous knowledge
of the surrounding fauna to heal ailments and illnesses in the absence of modern medication. Despite
this track record of maintaining a population without today's advances, their idiosyncratic methods of
healing have been left unexplored, much cast aside under the moniker "bush-medicine." Casting aside
cultural knowledge is something I hold to be profane; I would like to embrace the knowledge passed
down over generations and explore the potential for integration into modern medicine. By researching
ethnomedications, they can be legitimized, if effective in treatment. The research can ensure that those
using ethnomedications are using them in a safe and effective manner, reducing medical expenses,
preserving knowledge and culture, and allowing those using ethnomedications to continue to be self-
sufficient and healthy. Ethnomedications can provide inexpensive and/or easily homemade alternatives
to those in need of treatment, such as my mother in Trinidad, 1968.
At Swarthmore College, I am currently pursuing a degree in Chemistry, whilst tackling the Pre-Med
requirements. After medical school, I wish to pursue a Ph.D, in ethnobotany, with an emphasis on
ethnomedicine. With a medical degree, a firm understanding of chemistry, and a background in
ethnobotany, I would like to travel throughout Latin America and the Caribbean to preserve the
cultural knowledge of locals and indigenous people, and then research the ethnomedications of the
peoples for effectiveness. The experience, whilst academic, will also be a "return to home," allowing
me to learn of my cultural roots.
My time as a pharmacy technician assistant at St. Luke's Cornwall Hospital introduced me to the
product of modern medicine, and the sheer quantities of resources needed to maintain
health. Shadowing at Bambini Pediatrics made me realize that there are alternatives. My grandmother
and travels to Trinidad connects me to the wisdom held from generations past. Swarthmore teaches me
the modern approach to science: from Cell and Molecular Biology to the larger Organismal and
Population Biology, and how it all works through Organic Chemistry; the Sociology and
Anthropology department also provides insight on the cultural understandings of well-being, disease,
and healing in the course, Health, Culture and Illness. However, the Global Health Semester is the
culmination and tic between all of these experiences, Throughout the semester, I will gain my first
experience with the academic view of ethnobotany. I have experienced the practice of ethnobotany
first-hand and learned of biology, but I will not have connected the two in any part of my education
until this semester abroad. The opportunity to Iearn about public policy will help shape the way I
approach the application of research. Lastly, learning of a non-Western approach to health from those
who practice it will broaden my understanding of other cultures and will influence my care of
others. In essence, the experience of the Global Health Semester will provide me an opportunity to
begin experiencing my career goal now.
Responses for "Family Assignment Form"

Instructions:
Please complete the following information regarding your preferences for your homestay
family. We will do our best to find the right family for you.
1. List some of your i n terests or hobbies.
Indigenous medicine, cooking, farming, music, traveling to new places. Would like to learn Costa
Rica n dan ce.
2. Favorite Weekend Activities
Jogging, swi mming, c ooking, bike ridi ng.
-- - ----------- -- __
3. Vegetarian
I prefer a family that is:
Non-veget arian
4. Smoking
I prefer a fami ly that is:
Non-smoking
5. Dogs
I prefer a family that has:
No dogs
6. Cats
I prefer a family that has:
No cats
7. Additional Comments
Please note anything you feel should be taken into consideration as we attempt to find the right family
for you. Please include any special requirements, allergies, or anything else you deem important for
your ho st f amily to know.
I have asthma that may be triggered by mold, dust, pet dander and ragweed.
I would love to do a lot of traveling about the country to experience Costa Rica and Its culture from a native's point of view.
Responses for "OTS Costa Rica Participant Registration Form"
Instructions:
All students MUST obtain a passport that is valid for at least six months from the end date of the program, If you do
have a passport and the expiration date falls within the OTS guidelines, then please fill out the information below.
Otherwise, If you currently do not have a passport and need to apply for one OR need to renew your passport, then
please do so immediately) It may be wise to use the expedited service offered by the passport agency to ensure
receipt of your passport before the program begins. Passport Information Is available at:
http:/!travel.state.gov/passport_services.html. If you are not a US citizen, you may be required to obtain a visa to
enter into Costa Rica, in which case you should contact the OTS office Immediately.

Ravi Thackurdeen - OTS/Global Health Tropical Medicine and Public Health/B> ...Page 8 of 10
Flight Reservations:
Please make flight reservations to Juan Santamarla International Airport In San Jos, Costa Rica (SJO). To enter
Costa Rica you MUST purchase a round-trip ticket. You should schedule your flights to arrive and depart on the
dates indicated indicated in the announcements on your Duke University Studio Abroad account. After the staff in
Costa Rica receives your flight information in Costa Rica, An OTS driver will be at the airport to pick you up. Some
students have chosen to travel in Costa Rica before the start or after the end of the program, If you decide to
include travel plans that are outside of the OTS program dates, please know that you must make your own
arrangements for transportation and lodging during this time and that OTS is not responsible for any problems that
occur during this time. Should you have any logistical questions for the OTS program, please contact Kattla
Mendez In Costa Rica: kattIa.mendeztots.ac.cr .
1. Name as It appears on your passport:

Ravi Neal Thackurdeen
2. Place of Birth
New York, USA
3. Citizenship
United States
4. Do you have dual citizenship?
If you answer "yes" please list your other country of citizenship.
NO
5. Arrival Date & Time
8:50 PM on January 16, 2012
16. Airline Name & Flight Number
I American Airlines Flight 611
7. Passport Number:
1
477523543
8. Place Issued
United States
9. Date Issued
03/18/2011
10. Expiration Date (Month/Day/Year):
03/17/2021
11. Issuing Agency
US Department of State
12. Departure Date & Time
This is your departure information for travel from your host country at the end of your program.
https ://borodin.aas.duke.edulindex.cfm?FuseAction=StudentAdmin.PrintApplieation 4/30/2012

Ravi Thacicurdeen OTS/Global Health - Tropical Medicine and Public Health ... Page 9 of 10
7:50 AM on May 1, 2012

13. Departure Airline Name & Flight Number
American Airlines Flight 622
14. Mother's Maiden Name
Ramroop
15. Emergency Contact Name
Please list the name of the person we should contact first in case of an emergency.
Raj Thackurdeen
16. Emergency Contact Relationship
Father
17. Emergency Contact Address
5 Anchor Drive Newburgh, NY 12550 United States
18. Emergency Contact Daytime Phone

917-843-4870
19. Emergency Contact Evening Phone
917-658-8580
20, Emergency Contact E-mail
rthackur@gmail.com
Application Materials (Outgoing Program)

Pre-decision (Application) Materials:
Material Submissions
Title Received Notes
OTS Approval of Participation Form Received Material received on
05/27/2011 @ 03:24 PM
by Kala Wolfe
OTS Recommendation Received Material received on
0613012011 @ 12:20 PM
by Patricia Kustron
Transcript(s) Received Material received on
06130/2011 @ 12:20 PM
by Patricia Kustron
Post-decision Materials:
Material Submissions
Title Received Notes
Deposit Received $1040, Swarthmore check
#00415391
Material received on
https://borodin.aas.duke.edulindex.cfm ?FuseAetion=StudentAdmin,PrintApplication 4/30/2012

Ravi Thackurdeen - OTS/Global Health - Tropical Medicine and Public Health</B,.. Page 10 of 10
Form A: Statement of Authorization and Consent - Spring Received Material received on

11/16/2011 by Jennifer
Kelley
4
International Travel Registry
OTS Medical Form Received Material received on

12/05/2011 by Kala
Wolfe
OTS Participation Agreement CR Received Material received on
Kelley
OTS Scholarship Application Received Material received on
Kelley
Scholarship Application
form received in OTS on
11/15/11 (J Kelley)
Photo Received Material received on
Kelley
Third Party Billing Form Received Option #2
Material received on
09/14/2011 by Joy
Searles
No recommendations exist.
https://borodin.aas.duke.edu/index.cfm?FuseAction=StudentAdniin.PrintApplication 4/30/2012

Drenched with creeks of tears meandering about the cheeks of my grimaced face, I laid clutching a
blanket and my ears eighteen years ago. My mother knew the antibiotics would not be ready until the
next day, and that would mean the constant visuals of her little child distraught with what seemed the
worst of earaches. It seemed to recall her very own experiences with earaches, and she reverted to her
childhood memories back in Trinidad, 1968. She knew what she had to do.
A skewered garlic roasted as my mother slowly turned it over the stove, making the outside charred,
whilst the insides turned to a pungent slurry. With the garlic paste removed, she blended It Into In a
ladle of olive oil. After steeping and cooling, relief was poured into my ears.
It was an experience I did not recall until I was reminded this past summer. After shadowing an
integrative pediatrician at Bambini Pediatrics, I was shocked by the prescriptions he handed out, so I
told my mother every day. For colds, there was elderberry extract. For colic, there was problotics and
gripe water. And for earaches, of all things, he prescribed garlic and olive oil. The very same concoction
my mother brewed for me eighteen years ago, and my grandmother brewed for her back In a third
world country In the nineteen-sixties. What past doctors once called "bush-medicine," this cultural
wisdom to treat illnesses has become legitimatized through research, and even prescribed by integrative
physicians.
When I told my mother about the garlic and olive oil, she reciprocated with her childhood experiences
of the same nature. We sat for the next two hours discussing the ethnomedicine of Trinidad.
However, many other Idiosyncratic uses of plants, Trinidadian culture included, have not explored by
science. Generations upon generations have lived without the advances of modern science, whether it
may be due to poverty or Isolation. These people have managed to employ their indigenous knowledge
of the surrounding fauna to heal ailments and illnesses in the absence of modern medication. Despite
this track record of maintaining a population without today's advances, their idiosyncratic methods of
healing have been left unexplored, much cast aside under the moniker "bush-medicine." Casting aside
cultural knowledge Is something I hold to be profane; I would like to embrace the knowledge passed
down over generations and explore the potential for Integration Into modern medicine. By researching
ethnomedications, they can be legitimized, if effective in treatment. The research can ensure that those
using ethnomedications are using them In a safe and effective manner, reducing medical expenses,
preserving knowledge and culture, and allowing those using ethnomedications to continue to be self-
sufficient and healthy. Ethnomedications can provide inexpensive and/or easily homemade alternatives
to those in need of treatment, such as my mother In Trinidad, 1968,
At Swarthmore College, I am currently pursuing a degree in Chemistry, whilst tackling the Pre-Med
requirements. After medical school, I wish to pursue a Ph.D. in ethnobotany, with an emphasis on
ethnomedicine. With a medical degree, a firm understanding of chemistry, and a background In
ethnobotany, I would like to travel throughout Latin America and the Caribbean to preserve the cultural
knowledge of locals and Indigenous people, and then research the ethnomedications of the peoples for
effectiveness. The experience, whilst academic, will also be a "return to home," allowing me to learn of
.my cultural roots.

My time as a pharmacy technician assistant at St. Luke's Cornwall Hospital introduced me to the product
of modern medicine, and the sheer quantities of resources needed to maintain health. Shadowing at
Bambini Pediatrics made me realize that there are alternatives. My grandmother and travels to Trinidad
connects me to the wisdom held from generations past. Swarthmore teaches me the modern approach
to science: from Cell and Molecular Biology to the larger Organismal and Population Biology, and how It
all works through Organic Chemistry; the Sociology and Anthropology department also provides insight
on the cultural understandings of well-being, disease, and healing in the course, Health, Culture and
Illness. However, the Global Health Semester is the culmination and tie between all of these
experiences. Throughout the semester, I will gain my first experience with the academic view of
ethnobotany. I have experienced the practice of ethnobotany first-hand and learned of biology, but I will
not have connected the two in any part of my education until this semester abroad. The opportunity to
learn about public policy will help shape the way I approach the application of research. Lastly, learning
of a non-Western approach to health from those who practice it will broaden my understanding of other
cultures and will influence my care of others. In essence, the experience of the Global Health Semester
will provide me an opportunity to begin experiencing my career goal now,

W y, 27 2( 11 2:16 o, i44O P. 1
Orgcmbaton for
L TJk( V
U N t V E P S 1 T Y
APPROVA L OF T T N*
N ON- D UKE STUDENTS

( ON LY)
TO THE STUDENT;
Instruction: Please fill out the section directly below and hand it to your Study Abroad Advisor, Dean for Study Abroad, or Academic
Dean at your home institution for approval to participate in the OTS Program, if your university representative Chooses to return this
form to you for submission, ploase send it to OTS using one of the following options listed at the bottom of this page.
Student Name: ,R9v Th,gnhii lemon Institution: Swarthmore College
Please Select Program, Ckrcle Term and Specify Year of Participation;
,Semester , all/a ing)
0 Field Tropical Biology in Costa Rica: Fall Spring

(7TropzGalIV[iiue l Pulic .Health iit:Costa Pii;Ca Fall grin , 2012
fl Savanna Ecology in South Africa: Fall Spring
Summer
Field Tropical Biology in Costa Rica (4 weeks): Summer
0 Global Health Issues in South Africa; Summer
Instructions' Please complete this form and return it to the student OR submit n u. ' ng the instructions listed at the bottom of this page.
1. Do you recommend this student to participate in the t TS Program? {YES ( ) NO
Comments:
2. To the best of your knowledge, has this student ever been on academic or probation? { ) YES { } NO
If yes, please explain; C R, C S. - rkt
3. To the best of your knowledge, has this student ever been convicted of a felony? { ) YES { } NO
If yes, please explain: _
4, Approval of Pat-ticlpation
1 approve of the smdeut listed on this form to participate in a study abroad program through the Organization for Tropical Studies (01'S)
and Duke University. Following the student's return to campus, our institution will evaluate the crcdirs earned by the student through
Duke University and will consider them for transfer credit the fiilfilhnent ofgrad anon r quireme
Print Name G ~C7 C~ ,- Sig Date;
Working Title: `tea lS* (2 E-mail: (` -
Address: Phone:
To SUBMIT THIS FORM, PLEASE CHOOSE ONE OF THE FOLLOWING OP TIONS;
1) FAX TO : 919.684-6661 WITH ATTENTION WRiTTEN To: OTS ENROLLMENT MANAGEMENT
2) SCAN AND E-MAIL AS ATTACHMEN T TO; otsadmicsions ),duke.eclTe
3) SEND VIA POSTAL MAiL TO TH E ADDRESS LISTED BELOW , Off-Campus Study Office
Swarthmnore College
500 College Avenue
OTS, Duke University, PO Box 90630. Durham, NC 27708-0630 Tel: 919-654-5774 'Swarthmore, PA 19081-1391

MMiay, 27. 2(111 2: 16Plti i&. 14 P. 2
Sgwarthmore College
500 College Avenue
Swarthmore, PA 19081-1397
Oft- Campus Study Office
610-328-7826
May 27, 2011
Re: Ravi Thackurdeen,
Dear Colleagues:
Re: Procedures for Program Approvals for Study Abroad. , Spring 2012
Enclosed is a program approval completed by the Off-Campus Study Office for our
student who has applied to your study abroad program.
We have completed the form and have answered the questions to the best of our ability
(following student transcripts). Please know that we do not have access to
comprehensive student information. We will meet with. the Dean's Office in mid
October to review student eligibility for study abroad_ After this meeting, we will update
you with any revisions to the Coma.
Please let us know if the student's application will be hindered by not providing a
completed form.
We appreciate your patience.
Many thanks and best wishes,
Rosa M. Bernard
Assistant Director
Ofl.'-Campus Study
Swarthmore College
Cunningham House

1__fA
HA'ISJ
Department of Biology William F. Gresh, Jr.

Swarthmore College Tel: (610) 690-5761
500 College Avenue Fax: (610) 328-8663
Swarthmore, PA 19081-1390 Wgreshl @swarthmore.edu
Summer contact: williamegrehilr@ua oo.com
Tel: (610) 532-4391
May 12, 2011
Organization for Tropical Studies

Duke University
Attn: OTS Enrollment Management
P.O. Box 90630
Durham, NC 27708-0630
To Whom it May Concern:
It is my pleasure to write on behalf of Ravi Thackurdeen, an applicant to your program. I have

known Ravi for one year. I served as his Laboratory Instructor during the fall semester of 2010
in Biology I (Cellular and Molecular Biology) and the spring semester of 2011 in Biology II
(Population and Organismal Biology).
Ravi is very bright and inquisitive, hard working and disciplined. He strives for excellence and
expects nothing but from himself, This is particularly evident in his writing assignments. All of
my students can earn an A if they put forth the effort. Ravi has always goes the extra mile to do
so. He also placed in the top 15% of Biology I, which is a challenging course.
He has grown a great deal during his first year of college. At the beginning of his first semester,
he was a bit impatient and he did not realize that he needed to be flexible with his schedule.
However, he has taken a 180 turn. I am very proud of him,
Ravi is a caring person around and is always willing to lend a helping hand; he works well with
others and he is a team player. He is sincere and genuine and has a great sense of humor. Ravi
is simply a pleasure to be around. His personal potential is immense. I know that he is going to
excel in all that he does. I highly recommend that you admit Ravi to your program.
Sincerely,
l i c1
William E. Gresh, Jr.
Biology Laboratory Instruc or

NI; r1,'luila1 ,,`', I' cI .,Ift'". t Lll,
SWARTH1VORE COLLEGE
GE f tfk.{) oftho I ogl ~ scraY
i SwarUi ..6 ) l'A 'I t)Q81 ,' ,.: t
1 l&e " ri' t\ idomi rti
od ot
12ay. Nea L x'klackurdeerl
I ()_ ) i'Ipt of ~
.
(' ; 5 . Anchor IJr i vc 91~~
f: ' bxr ~
Iraq Ia qUP(I OL.dtJN 2O1 I
Ne47hi1Xgh :N . 17, 550
. -:... ..-.:. aQt1(PnP
9 II _1 A 1t36 :II .aUO ).
1 VLIl, Undergraduate :rranscxip1.
1s ~ taad tcA` .
~ -
P9,
Ravi. ;.t'htickurdeen C '

... S AnchcOr. Dr:L y r
Newburgh,
,
,1'Y.]:L5 0
,
'i Course; Leve'1, Uddt;rcjzdu,ltYi:e T'San. , ez ipL

It}{}Ii..cc'hcx,1 1 ' M.& 1bc
is C4t,J(.xi41 :L gh Sc honl : 26,iI(1N 2010
C:t,rrent. Lr. - -milt

{òllc.gc s iart.11 u:c a Co]
Pin major ..
~ IJES: Ri4.' : COURSE T).'I'(.e .,. CRSE ORD R
INS1'I'I'FJ,IION (RI I) i
2p1'n .
stt')
BCOL 001 ' re]lultir ItuleG lug Tip1 (W) 1.00 CR a
CF31 :'...A0, eeeL C)tetn3.sl-ry r 1.00 CR
h17iTI1 Q26 ;-' AdV!'0pi3.i Sinc!le Varj (;a1cu1us 1.00 CR
. hilJS 011 Ifa nu 1Y rind t ,iJntptpPjt:,t 1 1.00 CR
' MU I .040A E1t ulents' of !aosici1nship I 0 .50 !C '
..Tonal 'I.AY'neU Credits 4.50
sp)2)c3 2011 C
' 13Y01 O ?. :';';7' or .] ism' 1 . - . o uTBIOT. W 3.00 B+ .... ..': ....` ,,,.:. ...,:. ... ~`
..
:... .. Ihr.!i`. ::. ::.. < : ~ < .QI) g> 11 ,lq..}9t
.::.. 0. L2sa::' m . I ;i(< 1 00 A . . . 3,
o 1L O.OY ,:.: :::::FY..:3,1 11to .t',ean1nc3 oC,;;irUe;. (W) 1.00 A-
.! Lil;f.,(i:.:.0.16 :.:;.?'fYR.tS ?Ka.I:LV.ItrnC g;Int.OTh6W11d '1.00 A .. .... }:r 'ts; :s :.:>:>:;':::''a''i.> 'i i v
,al.ul, ,,nrnl.d...r,..tedi.t,.a, ,.:.4: 00 :<::........ -
.... ... . .. .. -
k 11 z of P'
r'
:.:anPRQss U".RI 1.QRK... ~ . ~ c :.:.:::..:.::.. . ~ ' ,:'.,'.:; ::::: ~ `.
. . '::''a':: ;.: >': . .: . :: .: :ar; : :`.'"' ' f
_
C}}.[.i7-0.:;032;': i,; !:;:.:,'a:0 yjinte ,: Chemistry .11 _ .,1 .00 IN PROGRESS
, PRY:I 003 CCnc.Yal Phy ics I -- i 00 IN PROGRESS
, COM 0431; , Calf laL JtealLh j . 11Yir s,, ' ('p) 1 Oq IN PROGRESS
S1?II 00'ltl Int SpaiinsY} for .Pdv gin eja; 1 0 1N, PROGRESS
.. ,,.,
. ~ .:+ac ~~ ,{, **1*vtit* i ar**k.* v-17N1) ON`,'.PRAk'CRit_r1` i1a -W i asc Fiq }rJ. +t+i"sta:ft .
5 .,:,.
t.
3s
v
...:...:.. . 'i
II
.:.... ...... ...:'
:ii'
..
I
~ f
Not otflCtAt 1\Ittl4llt [a(Slll Sl` ~fit 41111 t CQI S,tl or~ 5 .clgn,tuCf, > '

11 I a T O) ~$D ~f6 61 61 u4

No. 1591 P. 1/1
Sep. 13. 2011 2:54PM
P11K6 VNIVQRu r? --------
Edu c ation
orn,ss roR UN0gaNAeUATC$
Q
Our Institution Is not Invuived In the billing arrangements for (student name),
participant In (name of program). Please bill the student diredlly.
Study Abroad/Off Campus Study Rep.

Title:
Signature , Date:
l'TIO N 2: Third Party Billing Request & Authorixatien '

a Per this agreement, ~' \ 1 r,I 1 ~~ (name of university) Is authorizing
Duke University to bill our)nstitutbn on behalf of'the stud nt named below for the tuition and fees
Indicated, We will t prompt payment upon receipt of an invoke from Duke , University,
Student Name;
Name of Program:
Tuition
Program Fee
Transcript Fee L
'ur institution Is responsible for paying the advanced deposit required prior to enrgllment. This
deposit payment will appear as a credit on the student's bill.
Please note that the Ouke UAlverslly Burger does not lilt! for prt5grsm deposits. Also, if the student pays a deposit to
Duke Unlvvrsfly, any everpayments on the account, ap to the deposit a Fr{Hunt, will be refunded to the Student
Please nnto tde nt will also receive a bill athlsllterlwme dddrsssi
I
Bi lin Informal o '
Billing a dress for this authorization; gwA7ttMdtet
R08A M.13ERN ARD

ASSISTANT DIRECTOR PON 0i P-CAMPU$ STUDY
SWARTWA08h COU,Ea2
CUNNINCHAM HOU$
505 COULG6AVENUE
5WM tHMAF19. PA, uWA 19081-10Y
Phone:($10)328.7$x'5 F* (610)528.7523
E l; rtwnaiI OeIjhflu
wabfiM, h1VJMW4wRAhmore.c ~tvloce
Please return the form using one of the following;

~ M _.~~~. .... .~. ,., ..,., . .. ._war 919.68803080......_........
Emaih globaled@duke,edu
Mall: Duke University, Global Eduoation Off lee for Undergraduates
Box 90057, futham, NO 27700.0067
.i: l rPP1.mli~7 7ai hl,dj, ? ybllILru%n,,,F ,11-11 R/.V,I t.dnr

OaaaL LLISb/b0 L6SL4100
't~ ' .,,,J rr. F. u..1
+7 ~tiy,.-.
N~~?
~Cr.~`.~i ~- ~ d'4' a ~ :a
f~j~ 1 t.sa~1'~ ~y "'
i.. '+' yur ,~]' e ~ '~+.a
ta ,.1;' ^-iy','r,,iCC~.~f
!:~~
:!.-+ - _ r: -.f1 r.? - T \~^ t~' ~ A. .,L y ;'y~ ~`?
S!? 00070'6 btsc,ldS - SZISOdaa meJBJd CL08L70I LLI76i60
"s~_-`5'.tr
~~ra , rs -.~~ >~ ~
a yy c' S
{t t?}' >x '_" -r
' 7; ~ gyp",' a. j ~ I~ ~ ~
q~ 'y ~ ta ' ~ ~~ .
~ wt Mr ' .- ~~7/$"i[ Y
df1 ", pT a "~ 7 M. .+
u{iv
~
u'iOT 'ib ~ 5I 3_IR :"ES_OO OO1 EON Al bES 51OOAn .
u-.J-. 3^ '~ ^ :- 7
t. ''7
fi'I- F ='i
. ~.~1..-.-'Y:a':s.._:GSaJV.~~ iF~ .G VCALIWT - Z~- :~"~ V. I.I. - _ .
y ~i
o _-
_`'A, -..,
' ` ="`{3F+ir?'' }iL.%W
~
11d ~ :3 ~ 1r1's
- "'">> c, -^.
Y'.r' i:.<-
~ .. oo C'
'. ,^9 'ia ~-S ~.' :C~~Z'
`+L{
'L ~.`. .. ~? t
6 ; ~-y~~: r,~"~-'~ vJyy~ ~rp7~-~ fir.. ~~~T
%4 ~:"'+ ~:1,,4'' ~ ..Yf - " --...,: ~:,.. ;"1:- ~'.S_Si'f
e.wa-~ .
t!A'Cr; ~{~ t7:
-G;S;
-(a. .:^"_`1 ~ 'Jk T - r, ~4
~....,.(_ c ~ r'tii-'. ~ r Fc ~<::: ~ +tFrl. :'I'L
'-L's:.'ir.; w.- '

/-;y . Jh' ~iwJ Yi . ; !%
:^..Ctt`' ~r~ y a- . :?- l~ ..
:~ < .~
- ~l;.;:.`., ~ .N
. ,.
' i-"tJ'Sr: . .:+': -,,'c.;:.. 5.n't:`]"..
%le';~1 . Y .fir . - -..+-i a
~: - - ^ if ~r _
."'n_wf
1. yl,.~ l~ .Y
- .~.+r
- -<"' ~ ..
:,;, x ~'^ ;;,. :'X :~ r~ ;` :- .; ~~::'.. - : ~

N3 % ,: ' ~`f:~x!"~ f3'0
QT f o _'-?y
'tY2. ~'c0 art G ~ '
~~ i.-:, r .. _. 7. ,;....'".
xw;, -'.:.=~ 0. :r:~4+:.-~ _.c-'t v`"_-.~
.-" '_.:t..F:"' ~'~r=``- ~[`.,yl~ _'~,Ny.., .
~
u-,..:~ ; _ _ .7S:.v-~':.
~
_ :;16E; ~~ LB!363:luei~l!Ssis id; àlouii{~n4S-~ ~r ~ziowì~vv,KS.,~.

~~'':S::i':: ..?. ~ :Y.
-y,er _ w _e_,: - , ~~~2a7.L( ~115~.0~~

:
4g '.:~. ~t ~`~_ :y';c~'_ ~-~ i'.' _ 0 {~ - _ .-
a.- -- im '
.' ,- ~% % of }~ 4t
,...e:' iF3 Q'"rT~Id-a. ~ :o- y , `'
~
= ' ~ i. .a,(?W
,.I a: _ ''
..:h: - . ~ --
;:.`~ ao4~ ossY~'uofjzt~i:,~~'~~ ~'::..,-;c. _. :?c_
<va. ~ :, w ~-'. y_.., :ry - ,Z:% x r r
^. ~ - ~ ti
;
!.. =.,4`= -try F~'E, . ~.~,; ,.1

Name Ravi Neat Thackurdeen Emorgcncy Contact
Permanent Address 5 Anchor Drive Person to Contact First:
city, State, zip Newburgh, NY 12550 Name Raj Thackurdeen
Home Telephone (845) 784_4499
RelationshipF?thcr
Address 5 Anchor Drive
E-mail address rthaeku2@swarthmore.edu _.Newburgti NY 1255Q
Daytime 7 8 7Q
ti U.S. Citizen El Non-U.S. Citizen Evening phone 845 784-4499
Passport Number 219825658 E-mail
Country United States of America
Backup Contact (Relative or Friend):
Date of Birth 06/08/1992 Name Roshni Thackurdeen
Sex Male height 5 1 5 " Weight . 150 lbs. Relationship Mother
Address 5 Anchor Drive
OTS course you will be takin g Global Health Semester t4ewburnh. NY 12550
Now would you describe your general health? Daytime phone 9 658-8580
Evening phone 439-9205
Physically fit. Email tthackur@ mttil.com tt lac curC aol.oam
Do you have any physical limitations that might affect your ability to
engage in strenuous physical activity?
Mod/cal Insurance Policy information
Dietary restrictions None. Are you covered by health insurance? Yes.
Policy Holders Name Roshni D. Thackurdeen
* ll you are a vegetarian, do you eat eggs or dally products? Do you Address 5 Anchor Drive. Ncwburgh,
eat sonic kinds of moat, but not others?
Employers Address 525 W50th St New York, NY 10019
Allergies Seasonal Occupation Business Manager
Describe allergic reaction neezing,congestion,CintbS Policy Holders Date of Birth 01/06/1963
pressure, itchy eyes, and a runny nose. Relationship to Participant Mother
Insurance Company Name GHI
* Participants with a known or suspected severe allergic reaction Insurance Company Address PO Box 3000. NY, NY 10116-'
should/it/ny two Anaklts or Epipens
PolicyNumber 930453218
Recent illnesses None. Plan// Category, 263
Expiration Date N/A
Please describe any emotional or psychological conditions that might
affect ypur a demie performance.
Possible home sickness,
List y medications you take regularly, prescription, or non-prescription. Signature
pal y vitamins,
* it so, check expiref/on date and bring a spare supply.
I (please print), Ravi Thackurdeen
Do you wear corrective lenses? have honestly disclosed all the information requested above,
No. and I understand that withholding information may contribute
I/ so, please bring a spare set. Bring spare glasses as eye irritation to Injury or illness complications, and possibly compromise
may prevent use of contacts. we in the event of an emergency. If any of the above
Date of last tetanus Inoculation or booster: Information changes prior to or during the course, I will
immediately n r e the curse coordinators.
06115/2010 Signature
Current recommendation Is no later than 5 years ago.
Once complete please submit via postal mail to the following address: Organization for Tropical Studies
Duke University
Attn; O.TS Enrollment Management
Box 90630
Durham, NC 27708-0630

(Please make a copy for yourl(es) Form A
Statement o f Authorization a nd Cons ent
Student's Pull Name _.. 0.~ l "- c~ . ~c~ -e ' h _ Due Date : Friday, November 18, 2011
ProgramTitle/Site Ric ~
The following agreements are designed to protect all participants in Duke-administered or Duke-a p provedprogrnms; the students, the
faculty, Duke University, Its trustees, officers, agents and employees, and the agencies and Individuals cooperatingwith Duke University,
We require that all students and their parents sign these forms to Indicate their agreement and permission.
Duke University does notdiscriminate against Individuals who have had physical, emotional or mental disorders. A medteal examination is
required forthose programs which are physically arduous and/or when ills arequirement ofthohost institution, )lowever rifa student has
a history of any medical or psychiatric problems during the previous two years, we strongly advise that the student consult with a
medical professional before departure to discuss Cite potential stress and difficulty of study abroad.
I, We understand that partiolpation in tho program is entirely voluntary andthat anyprogram of travel involves somoelement of risk, We
agree that in partial consideration of Duke University's sponsoring this aotivItyand periUlti1ng the student to participate, we will not
attempt to hold Duke University, Its trustees, officers, agents and employees liable In damages for any injury or loss to person or
property the student might sustain while so partlolpating; and we hereby release Duke University, its trustees, officers agents and
,
employees from any liability whatsoever for any personal Injury or property damage arising from participation in the program.
2, We understand that Duke University or the sponsoring institution reserves the right to make cancellations, changes or substitutions In
oases of emergency or changed conditions or In the Interest ofthe group. Should DukoUnlversity cancel the program, full refunds will
bo made unless the cancellation is due to political, natural, technological or other catastrophes beyond Its control, In which we Duke,
University will be able to refund only uncommitted and recoverable flrnds, Should another sponsoring Institution cancel Its progmm, its
refuund policy, if any, will apply.
In addition, we understand that the program's costs are based on airfares, lodging rates, exchange rates, and other costs expected to be
In force, and are subject to increase.
We also understand that any deposit made fbr a Duke-adiulnisterede program Is nonrefkmdable, In the case of withdrawal, any
remaining paid tuition will betefl nded as follows, in accordance with the Duke Universityretbnd policy ouilined in the Undergraduate
Bulletin; flefore start of program - full reflwd minus the deposit; during the first or secondweek - 80 percent; during the third, fourth,
or fifth week . 60 percent; during the sixth week . 20 percent; after the sixth week- none, Other (non-Duke) sponsors/instliutions have
their own refund policies which we understand will be followed.
All students who need to terminate their participation in their study abroad program for any reason must notify the Duke Global
Education Office by signing and submitting our official withdrawal form before leaving the program. Duke students who leave their
programs without providing the Duke Global Education Office with this official withdrawal notification maybe withdrawn from Duke
and will need to apply for readmission in accordance with official Duke University guidelines. In either case, grades reported by the
program will appear on the student's Duke record in accordance with Duke grading and grade requirements as stated In the
Undergraduate Brdtelln.
A Duke student who receives financial aid fora Duke-administered program should understand that by signing this agreement and the
Agreement to Partiolpato (in someD uke programs) upon admission to the progran , he or she is committed to pay the program fees and
that charges will be put on the student 's Bursar account,
3. Stu;lents are expected to comply fully with the laws and regulations of the host country regarding required travel documents such as
student visas and study permits. Obtaining the necessary permission to enter or remain In a country Is the solo responsibility of the
student , We understand that if I plan to participate in sequential overseas programs we must pay particular attention to the logistics
required to obtain multiple visas.
4, Wo understand that continuation requirements , as described in the UndergradrtateBullelln, also apply to academic performance
abroad, We understand that Juniors who plan on ebanging their status from full time to part-time must register their Intention to do so
by April 15th preceding the academic year in wbioh theparttlme semester will be taken. We also understand that graduation dates may
need a4Justment if study abroad transcripts are not received and credit transfers are not completed by the specified deadlines, We
understand that students receiving conditional waivers must meet all specified conditions In order to be eligible to study abroad.
5. We understand that the student, as a participant in the program, is a representative of Duke University and the United States and by
signing this agreement pledges to deport himself or herself In a manner that reflects , ihvorably an both and upholds the Duke
Community Standard . We understand that In addition to regular classes the program may include planned lectures and field trips which
are germane to the educational experience, and that the student agrees to participate willin ly in such activities in addition to attending
the regular classes. Duke University and/or the sponsoring institution may discipline a student or dismiss him or her from the program
for behavior detrimental to the, program. A dismissed student will receive no refund firom Duke University,

Borne A page 2
b. We understand that Duke, Uuiverylty requires that appropriate sickness and accident Insurance cover all students for the duration of the
program and that they be financially responsible for all medical ecpeusos. in addition, we understand that payment for medical
expenses customarily will have to be advanced and reimbursement sought later from the Insurance carrier,
with
# ` iitt kWtffi (name ofstudent)isInsuredunderpolloyorgroup/membet/lDnusnber
(company) for sickness and accident Insurance. Date ofexpiration
do . v A (list it
notappitcable;inad tion, the student erobyassurnesresponslbilityforati medical expenses Incurred byes onbe lfoftbeshtdent
while, ptrtlelpating in the program,
Duke University requires that afl students register with the Duke Travel Registry. Students must forward the contirmadon email (with
subject line Under Grad Travel Reg) to dkeanrey@duke.edu so that may be Included with iflnal study abroad forms, See
https://eruditlo,sus,duko.cdu/internatdonai/index,pbp for additional details and the link to the Duke International Travel Registration
lForm.
While Duke discourages students from purchasing or renting vehicles abroad, we recommend that those students planning to o$rcrato a
motor vehicle obtain liability and collision Insuranco that will cover them in the applicable foreign countries. Duke University also
recommends that students Insure their property from loss or theft.
We understand that programs abroad may not regularly employ health cure professionals overseas and make no
representatton With respect to accessibility of services and facilities abroad, Appropriate treatments; espectaliy)rsyebolog)cal,
may not be as readily available, abroad as In the United States The student must, therefore make provision before departure
, ,
for continuation of medical treatments such as prescriptions or special diets, The director of the program should be fully
Informed of any special needs at the start of the program , Duke University can make no representation with respect to
accessibility of services and facilities abroad,
In the event (1) (we) cannot be reached to give (nay) (our) consent, (1) (we) the parent(S) ofthe above named student, hereb y authorize
Duke University's representative to consent for (me) (us) to any x-ray examination, anaestlietio, medical or surgical diagnosis or
treatment and hospital care deemed neoessaty or advisebte by it licensed physiolan during the period the student is enrol led In thoDuke
program.
It is understood that this authorization is given in advance of any specific diagnosis, treatment, or hospital care being required, but Is
given to provide authority and poweron I bepart offluke Univemsity to give specific consent tothedlagnosis, treatment orhespital care
which In the best judgment of it licensed physician is deemed adv cab e,
Wouuderstand that the Study Abroad I'ee ofS4,O67 (2011-2012) per semesterwill be charged by Duke University to students
partleipatlngin progr ams administered byluslitutlonsother than DukeUniversity for thepurpose ofmaLntnIningjD student's
enrollment atDuke. This mandatory fee actbythe Board of'f ustees Is notwaived under any circumstances. j (initials
of parent/guar:dian)
Paren VOuardinn
I certify that tam the parent or legal guard of the student nam ve; the I have read the entire preceding agreement and I join In all the
arttcies of the agreement nvhhout resew ,gran g my co r~lo'_aIf acI is pr Ided for heroin,
/
Signature otparent or guardian yy ti r 'G hate ` /_
Printed name of parent or guardian ._ ~ tb i Thar P kLtAJ-P Vol
0 rMY
Number & Street City State
Telephone number
Area Coda Phone number
Signature of student Date

The signatures of both a pareu or legal guardian and the student are rettulred . Please sign this form and return It to Global Education Office for
Undergraduates , Duke University , Smith Warehouse , Bay 6, 2nd Floor , 114 S. Buchanan Blvd., Box 90057 , Durham, NC 277084057
(Tel, 919.684,2174, Fax 919,684,30113) by Friday, November 18, 201 f, if malting, Box 90057 MUST be included In the address.
'$ Duke-administered programs are: Duke lathe Andes; Duke in Berlin; ]Duke Study in China; OT /Duko In Costa Rica. '1 opieal Biology , OTS/IJrrko
In Costa Idea - Global Heaith/rropieat Medicine and Public Health; Duke in Frencc/BDUCO; Duke in Glasgow; Duke Semester in India; Duke in
tstanbul; Global Semester Abroad; intercollegiate Center for Classical Studies (ICCS) in Rome; Duke in Madrid; OTS/Duko In South Africa - Savanna
beelogy; Duke in St. Petersburg; and Duke In Venice,
i, ms koFamudoe fastrs,fud05n4,It

~
Y>qarnzhon for i
;.
N tt UNIVERSITY
IVERSITY
Page 1 of 2
.ii 11ii i .r
You have requested to participate in one of the Undergraduate Study Abroad Programs sponsored by the Organization for Tropical
Studies at Duke University. All activities associated with travel involve risks, and it is important for you to have information about
this activity and to provide the Organization for Tropical Studies with information about yourself before participating in this activity.
The Participation Agreement must be read carefully and signed by all participants who take part in the activity offered by the
Organization for Tropical Studies.
PLEASE READ THIS AGREEMENT CAREFULLY. IT IS A LEGAL CONTRACT AND AFFECTS ANY RIGHTS YOU MAY
HAVE IF YOU ARE INJURED OR OTHERWISE SUFFER DAMAGES WHILE PARTICIPATING IN THIS ACTIVITY.
In consideration of the Organization for Tropical Studies, Duke University allowing me to participate in this activity, I agree and
understand the following:
1, NA TURE OF TRAVEL: I understand that I will be traveling to Costa Rica and possibly driven by faculty or employees of the
Organization for Tropical Studies or its contractors. I understand the Organization for Tropical Studies and the University's
position on student drivers and will follow the rules that have been set by the Organization for Tropical Studies and Duke
University.
2. INHERENT RISKS AND DANGERS OF TRAVEL : I understand and appreciate that risk and dangers are inherent when traveling long
distances, I understand that not following procedures correctly could result in property damage and personnel injury, including
death. I agree to accept and assume all risks associated with the activity whether present or future, known or unknown, arising
from or as a result of, my voluntary participation in the activity. Understanding all of the risks involved, I hereby elect to
voluntarily participate.
3. BEHAVIOR EXPECTATIONS OF THE PARTICIPANT: I know that it is important to follow the directions of the activity leader at all
thnes. I understand that as a participant I have the responsibility to help make the activity a safe experience for all participants
through appropriate behavior and conduct. I also understand the danger associated with deviating from the planned activity and
agree not to deviate from the plans as stipulated in the procedures.
4. HEALTH CONDITION OF THE PARTICIPANT : By signing this participation agreement you agree:
To furnish the Organization for Tropical Studies health information.

To inform the Organization for Tropical Studies of any medication, ailment, condition, or injury that may affect your
performance in the activity.
a That the participant will bear all financial responsibility for any medical treatment arising from participation in the activity.
B That the participant understands that the Organization for Tropical Studies, Duke University reserves the right to make
cancellations, changes, or substitutions in cases of emergency or changed conditions or in the interests of the group,
That the participant understands that as a participant in this Duke University program, I am a representative of the
Organization for Tropical Studies and Duke University. By signing this agreement, I pledge to conduct myself in a manner,
which reflects favorably on all.
That the participant understands that the Organization for Tropical Studies and Duke University requires all participants to be
covered by appropriate health and accident insurance and those participants and their families must be financially responsible
for all medical expenses and for expenses related to evacuation and repatriation unless otherwise provided. In addition, I
understand that payment for medical expenses customarily is advanced and reimbursement sought later from the insurance
carrier. The Organization for Tropical Studies and Duke University require that any participant planning to operate a motor
vehicle obtain liability and collision insurance that will cover him or her in the applicable foreign countries. The
Organization for Tropical Studies and Duke University also recommends that participants insure their property against loss or
theft.

5. RELEASE, ASSuMptioN of RISK, WAVER OF LI ILITY, AND HOLD HARMLESS AGREEMENT
In return for the Organization for Tropical Studies and Duke University allowing me to participate in this activity and having read
and understood this Participation Agreement, I hereby state that I voluntarily agree to the following:
A. I hereby RELEASE, WAIVE, DISCHARGE, AND COVENANT NOT TO SUE the Organization for Tropical Studies, Duke
University, its trustees, officers, employees, or agents, (hereinafter referred to as RELEASEES) for any liability, claim, and/or
cause of action arising out of or related to any loss, damage, or injury, including death, that may be sustained by me, or to any
property belonging to me that occurs as a result of my traveling to and .from, and participation In this activity.
B. I agree to INDEMNIFY AND HOLD HARMLESS the RELEASEES whether injury or damages is caused by my negligence,
the negligence of the RELEASEES, or the negligence of any third party from any loss, liability, damage or costs, including court
costs and attorneys' fees, that RELEASEES may incur due to my traveling to and from, and participation in this activity.
C. It Is my express intent that this RELEASE and HOLD HARMLESS AGREEMENT shall bind the members of my family and
spouse, if I am alive, and my heirs, assigns and personal representative, if I am deceased, and shall be deemed as a RELEASE,
WAIVER, DISCCARGE, and COVENANT NOT TO SUE the above-named RELEASEES.
D. I hereby further agree that this Participation Agreement, Release, Assumption of Risk, Waiver of Liability, and Hold Harmless
Agreement shall be construed in accordance with the laws of the state of North Carolina.
E. If I deviate from any aspect of this activity, such deviation Is purely voluntary, and I agree that RELEASEES shall not be liable
for any injuries resulting or arising out of such deviation,
P. I understand that by participating in this activity I will ASSUME THE RISK of injury and damage from risks and dangers that
are inherent in any activity.
G. I understand that any photograph, video or PowerPoint presentation in which I am depicted can be used in OTS promotional
materials,
IN SIGNING THIS RELEASE,'I ACKNOWLEDGE AND REPRESENT that I have read the foregoing PARTICIPATION
AGREEMENT, understand it, and sign it voluntarily,
SIQNATURE$
The signatures of both the student and their parent or legal guardian are required.
Name ofParticivant
,
Date
Page 2 of 2

EXHIBIT 2
Memorandum of Understanding

EXHIBIT 3
Statement of Authorization and Consent

EXHIBIT 4
OTS Participation Agreement Costa Rica

Duke's Response To Thackurdeen Lawsuit

Încărcat de

Informații document

Titlu original

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

Duke's Response To Thackurdeen Lawsuit

Încărcat de

Drepturi de autor:

Formate disponibile

UNITED STATE DISTRICT COURT

FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

Roshni D. Thackurdeen, and Raj B.

ANSWER OF DEFENDANT DUKE UNIVERSITY

NOW COMES a Defendant in the above-captioned matter, DUKE UNIVERSITY,

incorrectly sued as Duke University, a North Carolina Corporation, pursuant to

FIRST DEFENSE TO ALL CLAIMS FOR RELIEF

1. Duke University admits on information and belief that Plaintiffs Roshni D.

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 1 of 15

knowledge or information sufficient to form a belief as to the truth or falsity of the

allegations of this paragraph.

as stated, Duke University is without knowledge or information sufficient to form a belief

as to the truth or falsity of the allegations of this paragraph.

4. Duke University is without knowledge or information sufficient to form a

VENUE AND JURISDICTION

the parties appear to be citizens of different States.

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 2 of 15

University denies the allegations of this paragraph.

7. Duke University denies the allegations of this paragraph.

8. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

9. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

Thackurdeen enrolled in a Duke University administered Global Education Program

successful completion of the course of studies administered by OTS made Ravi

Thackurdeen eligible for credits to be transferred to Thackurdeen s college, Swarthmore,

of Understanding attached to this Answer as Exhibit 2. Except as stated, Duke

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 3 of 15

or falsity of the allegations of this paragraph.

11. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

12. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

13. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

14. Duke University is without knowledge or information sufficient to form a

University denies the allegations of this paragraph.

15. Duke University denies the allegations of this paragraph.

16. Duke University is without knowledge or information sufficient to form a

belief as to the truth or falsity of the allegations of this paragraph.

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 4 of 15

Except as stated, Duke University denies the allegations of this paragraph.

20. Duke University admits on information and belief that, accompanied by

is without knowledge or information sufficient to form a belief as to the truth or falsity of

the allegations of this paragraph.

relevant to Ravi Thackurdeens death. Except as stated Duke University is without

knowledge or information sufficient to form a belief as to the truth or falsity of the

allegations of this paragraph.

body was found on May 1, 2012.

relevant to Ravi Thackurdeens death. Except as stated Duke University is without

knowledge or information sufficient to form a belief as to the truth or falsity of the

allegations of this paragraph.

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 5 of 15

reference and incorporates Exhibit 1 and Exhibit 2.

25. Duke University admits the allegations of this paragraph on information

26. Duke University admits the allegations of this paragraph on information

27. Duke University adopts by reference and incorporates Exhibit 1 and

Exhibit 2. Duke University denies the allegations of this paragraph.

as stated, Duke University denies the allegations of this paragraph.

Case 1:16-cv-01108-NCT-JLW Document 66 Filed 02/24/17 Page 6 of 15

Duke University denies the allegations of this paragraph.

denies the allegations of this paragraph.

31. Duke University is without knowledge or information sufficient to form a