THE UNITED STATES DISTRICT COURT FOR 

THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

 

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STEVE SNYDER-HILL, et al., 

Plaintiffs, 

v. 

THE OHIO STATE UNIVERSITY, 

Defendant. 

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Case No. 2:18-cv-00736 

Judge Michael H. Watson 

Chief Magistrate Judge Elizabeth P. 

Deavers 

 ) 

JOINT STATUS REPORT PURSUANT TO COURT’S OCTOBER 8, 2019 ORDER, 

SUPPLEMENTAL RULE 25(A) MOTION FOR SUBSTITUTION, AND MOTION FOR

PERMISSION TO FILE UNDER SEAL 

Pursuant to this Court’s October 8, 2019 Order, the Snyder-Hill Plaintiffs inform this 

Court that the New York State Surrogate’s Court appointed Plaintiff John Doe 18’s widow as the 

Executor of his Estate. Attached is a redacted version of the Surrogate’s Court’s September 9, 

2019 Certificate of Appointment of Executor. Accordingly, Defendant does not oppose the 

substitution of the Executor of the Estate of John Doe 18 as party Plaintiff herein in place of 

Plaintiff John Doe 18. In light of the appointment, Defendant’s position, and for the reasons 

detailed in the original motion, the Snyder-Hill Plaintiffs ask that the Executor of the Estate of 

John Doe 18 be substituted as party Plaintiff herein in place of Plaintiff John Doe 18. 

Plaintiffs further request leave of Court, pursuant to S.D. Ohio Civ. R. 5.2.1, to file under 

seal a version of this motion that attaches the unredacted exhibit, thus revealing the true name of 

John Doe 18 and the proposed substitute Plaintiff, his widow. Defendant does not oppose 

sealing. 

The Court found that “good cause” was shown to use a John Doe designation “in all 

pleadings and documents to be filed on the public record when referring to the thirty-one 

Case: 2:18-cv-00736-MHW-EPD Doc #: 92 Filed: 10/15/19 Page: 1 of 2 PAGEID #: 981
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Plaintiffs who wish to proceed anonymously in this action.” Dkt. 33. The Court also ordered the 

Plaintiffs to “file with the Court ex parte and under seal a First Amended complaint bearing the 

thirty-one Doe Plaintiffs’ true names.” Id. Accordingly, to preserve the anonymity of John Doe 

18 and his family, Plaintiffs respectfully request permission to file under seal those exhibits that 

reveal the true name of the proposed substitute Plaintiff. 

DATED: October 15, 2019 EMERY CELLI BRINCKERHOFF 

 & ABADY LLP 

By: /s/ Debra L. Greenberger 

Ilann M. Maazel (admitted pro hac vice) 

Debra L. Greenberger (admitted pro hac vice) 

600 Fifth Avenue 

New York, New York 10020 

Phone: (212) 763-5000 

Fax: (212) 763-5001 

E-Mail: imaazel@ecbalaw.com 

E-Mail: dgreenberger@ecbalaw.com 

SCOTT ELLIOTT SMITH, LPA 

Scott E. Smith (0003749) 

Brian R. Noethlich (0086933) 

5003 Horizons Drive, Suite 100 

Columbus, Ohio 43220 

Phone: (614) 846-1700 

Fax: (614) 486-4987 

E-Mail:ses@sestraillaw.com 

E-Mail: brn@sestriallaw.com 

Adele P. Kimmel (admitted pro hac vice) 

PUBLIC JUSTICE, P.C. 

1620 L Street, NW, Suite 

630 Washington, DC 20036 

Phone: (202) 797-8600 

Fax: (202) 232-7203 

E-mail: akimmel@publicjustice.net 

Attorneys for the Snyder-Hill Plaintiffs and the 

Executor of the Estate of John Doe 18

Case: 2:18-cv-00736-MHW-EPD Doc #: 92 Filed: 10/15/19 Page: 2 of 2 PAGEID #: 982