THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

STEVE SNYDER-HILL, et al., ) Case No. 2:18-cv-00736-MHW-EPD 

) 

Plaintiffs, ) Judge Michael H. Watson 

) 

v. ) Chief Magistrate Judge Elizabeth P. 

) Deavers 

THE OHIO STATE UNIVERSITY, ) 

) 

Defendant. ) 

 ) 

UNOPPOSED MOTION FOR VOLUNTARY DISMISSAL WITH PREJUDICE 

Pursuant to Rule 15(a)(2), Rule 21, and Rule 41(a)(2) of the Federal Rules of Civil 

Procedure, Plaintiffs Hugh Dyer, John Doe 24, John Doe 26, John Doe 38, John Doe 48, John 

Doe 51, John Doe 53, John Doe 55, John Doe 61 (the “Dismissing Plaintiffs”) hereby move 

the Court to DISMISS WITH PREJUDICE any and all claims which have been, could have 

been, or should have been asserted by the Dismissing Plaintiffs against Defendant The Ohio 

State University (“OSU”) in the Second Amended Complaint. The Dismissing Plaintiffs and 

OSU will bear their own attorneys’ fees, costs and expenses. 

In support of this motion, the Dismissing Plaintiffs state their claims against OSU have 

been settled in full and that the dismissal with prejudice of the Dismissing Plaintiffs from this 

action will make the litigation of this action more efficient, will not prejudice OSU, and will not 

have any impact on the material issues involved in this litigation. The claims of the following 

plaintiffs in this matter are not being dismissed and remain pending: Steve Snyder-Hill, Ronald 

McDaniel, David Mulvin, Kelly Reed, William Rieffer, William Brown, Kurt Huntsinger, Steve 

Hatch, Melvin Robinson, Douglas Wells, James Khalil, Jerrold L. Solomon, Joseph Bechtel, 

Michael Murphy, John David Faler, John Doe 17, Estate of John Doe 18, John Does 19-23, 

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John Doe 25, John Does 27-37, John Does 39-47, John Does 49-50, John Doe 52, John Doe 54, 

John Does 56-60, and John Does 62-77. 

The undersigned has conferred with counsel for OSU, and counsel for OSU does not 

oppose this motion. A Proposed Agreed Order of Dismissal with Prejudice is attached. 

Dated: December 13, 2021 

Columbus, OH 

SCOTT ELLIOT SMITH, LPA 

 /s/ Scott E. Smith 

Scott E. Smith 

Michael L. Dillard, Jr. 

5003 Horizons Drive, Suite 100 

Columbus, Ohio 43220 

Phone: (614) 846-1700 

Fax: (614) 486-4987 

ses@sestriallaw.com 

mld@sestriallaw.com 

EMERY CELLI BRINCKERHOFF ABADY 

WARD & MAAZEL LLP 

Ilann M. Maazel 

Debra L. Greenberger 

Marissa R. Benavides 

600 Fifth Avenue, 10th Floor 

New York, New York 10020 

Phone: (212) 763-5000 

Fax: (212) 763-5001 

imaazel@ecbawm.com 

dgreenberger@ecbawm.com 

mbenavides@ecbawm.com 

PUBLIC JUSTICE, P.C. 

Adele P. Kimmel 

Alexandra Z. Brodsky 

1620 L Street, NW, Suite 630 

Washington, DC 20036 

Phone: (202) 797-8600 

Fax: (202) 232-7203 

akimmel@publicjustice.net 

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CERTIFICATE OF SERVICE 

I certify that a copy of the foregoing was filed electronically on December 13, 2021. 

Notice was sent by operation of the Court’s electronic filing system to all other counsel who 

have entered an appearance and any parties who have entered an appearance through counsel. 

The parties may access this filing through the Court’s ECF system. 

 /s/ Scott E. Smith 

Trial Attorney for Plaintiffs 

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