IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

STEVE SNYDER-HILL, et al.,

Mass Tort Plaintiffs,

v.

THE OHIO STATE UNIVERSITY,

Defendant.

Case No. 2:18-cv-00736-MHW-EPD

Judge Michael H. Watson

Magistrate Judge Deavers

PLAINTIFFS’ SUBMISSION OF AN ALTERNATIVE PROPOSED MEDIATOR

Plaintiffs Steve Snyder-Hill et, al. hereby propose Judge Steven W. Rhodes as an

alternative mediator if Plaintiff’s previously proposed mediators are not selected for consideration 

by the Court in the above-referenced matter. The Plaintiffs in this action, along with the related 

class action Plaintiffs (Garrett, et al. v The Ohio State University, Case No. 2:18-cv-00692) have 

collectively proposed two qualified mediators as their first and second choices to mediate these 

claims in the Parties Joint Submission Regarding Mediation Pursuant to January 17, 2019 Order 

(Doc #44) filed on January 31, 2019. Defendants, likewise have proposed two alternative choices 

to serve as possible mediators in the Joint Submission. Unfortunately, there is no meeting of the 

minds between the Plaintiffs and Defendant on this subject.

In a continued effort to move this process along and in hopes of finding a mediator that 

perhaps all parties can agree upon, Plaintiffs in the Synder-Hill action have continued to research 

qualified mediators and have identified Judge Rhodes as an alternative qualified candidate for 

consideration if the Court should not accept the collective Plaintiffs’ proposal of Judge Phillips or 

Mr. Feinberg. Plaintiffs in the Snyder-Hill action identified Judge Rhodes to counsel for OSU last 

week, in an effort to find agreement before meeting with the Court at the February 19, 2019 

scheduled status conference, however, OSU has not yet responded to this alternative proposal. 

Case: 2:18-cv-00736-MHW-EPD Doc #: 46 Filed: 02/18/19 Page: 1 of 4 PAGEID #: 728
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In brief summary, Judge Rhodes qualifications are as follows:

Steven W. Rhodes, is the Retired Chief Judge, US Bankruptcy Court for the 

Eastern District of Michigan, and is presently serving as a mediator with JAMS 

following 30 years of distinguished service to the federal judiciary. After beginning 

his career in private practice, Judge Rhodes was appointed as a U.S. Magistrate 

Judge for the Eastern District of Michigan from 1981-1985 before serving on the 

U.S. Bankruptcy Court from 2002-2009. 

Judge Rhodes is best known for his role presiding over the City of Detroit’s 2013 

bankruptcy, the largest municipal bankruptcy in United States history. Judge 

Rhodes was appointed by the Chief Judge of the Sixth Circuit Court of Appeals to 

preside over the City of Detroit bankruptcy case in July 2013, and Confirmed the 

City’s Plan of Adjustment in November 2014. Recently, Judge Rhodes has been 

retained to serve as the mediator for the claims of over 160 additional plaintiffs that 

have come forward in a second phase of the Michigan State University sex abuse 

cases. 

Judge Rhodes is known for his keen intellect, ability to manage complex, highstakes litigation and creativity in solving problems. In addition, he has extensive 

experience in the resolution of complex disputes to include Class Action/Mass Tort 

actions, employment claims, business/commercial actions and fraud claims.

https://www.jamsadr.com/rhodes/

Respectfully submitted,

 /s/ Jack Landskroner 

JACK LANDSKRONER (0059227)

HANNAH KLANG (0090470)

Landskroner Grieco Merriman, LLC

1360 W. 9th Street, Suite 200

Cleveland, Ohio 44113

Phone: 216.522.9000

Fax: 216.522.9007

E-Mail: jack@lgmlegal.com

E-Mail: hannah@lgmlegal.com

 /s/ Scott E. Smith _ 

SCOTT E. SMITH (0003749)

BRIAN R. NOETHLICH (0086933)

Scott Elliot Smith, LPA

5003 Horizons Drive, Suite 100

Columbus, Ohio 43220

Phone: 614.846.1700

Fax: 614.486.4987

E-Mail: ses@sestriallaw.com

E-Mail: brn@sestriallaw.com

Case: 2:18-cv-00736-MHW-EPD Doc #: 46 Filed: 02/18/19 Page: 2 of 4 PAGEID #: 729
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 /s/ Adele P. Kimmel _

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 Plaintiffs

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CERTIFICATE OF SERVICE

A copy of this document was served by the Court’s ECF System on all counsel of record 

on February 18, 2019, pursuant to Fed. R. Civ. P. 5(b)(2)(E).

/s/ Jack Landskroner 

JACK LANDSKRONER (0059227)

Case: 2:18-cv-00736-MHW-EPD Doc #: 46 Filed: 02/18/19 Page: 4 of 4 PAGEID #: 731