**StrataLift Mobility — Board Decision One-Pager**  
**Safety-Reporting Consent Order**

**Recommendation:** Approve settlement through the consent order. Do not litigate. Principal legal risk is the ten central-office late reports, which are supported separate violations; two involved fractures. Litigation would not suspend remediation duties, would add $850,000 defense cost, and risks a $1.4–$1.8 million adjudicated penalty plus possible inclusion of the four local complaints. Settlement limits cash exposure, preserves no-admission, reporting-date-only recitals, and no recall or sales restriction. The company’s clean reporting history and existing intake/alert/legal-review controls support a contained outcome.

**Two cash numbers for the board:**  
1. **Current all-in consent cost:** $1,200,000 ($950,000 penalty + $250,000 monitor).  
2. **Maximum all-in authority requested:** $1,300,000 ($1,050,000 penalty + $250,000 monitor), to be used only if necessary to preserve no-admission, limited recitals, and no-recall/no-sales-restriction terms.

**Deadline:** Only the penalty amount is negotiable; the offer expires at **5:00 p.m. on September 4**. Management should be authorized to execute before that deadline if the protected terms are confirmed.

**Ten reports vs. four complaints:** Ten reports reached central safety and were filed 9–34 business days later; they are the supported late reports. Four complaints stayed at local service centers until the agency inquiry; policy required escalation, but no central employee is shown to have received them earlier. We should distinguish those four and avoid accepting them as violations, while recognizing litigation may allow the agency to add them.

**“Confirmed defect” email:** The email concerning three events is adverse because the rule requires reasonable indication, not confirmed defect. It is not automatically knowing misconduct, but it could support a higher penalty in litigation and remains discoverable in private litigation. The no-admission clause does not eliminate that discovery risk.

**Resolutions and next steps:**  
1. Authorize management to settle within a **$1,300,000 all-in ceiling**, conditioned on no admission; recitals limited to reporting dates; no recall or sales restriction; and an 18-month independent monitor at fixed $250,000.  
2. Direct management to execute the consent order by **5:00 p.m. September 4** if those terms are preserved.  
3. Approve funding for the penalty and monitor, and direct management to maintain the central intake queue, automatic deadline alerts, weekly legal review, escalation discipline, and monitor cooperation.