Case 1:18-cv-01070-LM Document 39 Filed 05/24/19 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE KRISTINA RAPUANO, VASSIKI CHAUHAN, SASHA BRIETZKE, ANNEMARIE BROWN, ANDREA COURTNEY, MARISSA EVANS, JANE DOE, JANE DOE 2, and JANE DOE 3, CASE NO. 1:18-cv-01070 (LM) Plaintiffs, on behalf of themselves and all others similarly situated, Expedited Treatment Requested v. TRUSTEES OF DARTMOUTH COLLEGE, Defendant. PARTIES’ JOINT MOTION FOR STAY PENDING MEDIATION Pursuant to Local Rule 7.1, Plaintiffs and Defendant in this action hereby jointly move for a stay of all deadlines and rulings in this matter until (i) three days after the mediation the parties have agreed to conduct or (ii) July 31, 2019, whichever comes earlier. The purpose of the requested stay is to allow the parties to focus their efforts on the mediation and on their attempt to resolve this matter without further litigation. In support of this motion, undersigned counsel for Plaintiffs and Defendant jointly state as follows: 1. Plaintiffs commenced this action on November 15, 2018, and filed a First Amended Complaint on May 1, 2019. 2. The Court entered its order on the Parties Rule 26 Discovery Plan on February 12, 2019. The parties exchanged initial disclosures on April 15, 2019, and are currently in the discovery phase of this litigation. 3. The parties have been in discussions about participating in mediation in an -1- Case 1:18-cv-01070-LM Document 39 Filed 05/24/19 Page 2 of 3 attempt to resolve this matter without further litigation. 4. The parties recently selected the Honorable Robert Morrill (ret.) as a mediator, and are working to select a mutually-agreeable date for the mediation. 5. So that the parties can focus their efforts on the upcoming mediation and not be engaged in active litigation at the same time they are attempting to cooperate in reaching a negotiated resolution, the parties respectfully request that the Court stay all deadlines and rulings in this case until three days after the mediation or July 31, 2019, whichever comes earlier. WHEREFORE, the parties jointly request that the Court immediately enter a stay of all deadlines and rulings in this matter until (i) three days after the mediation the parties have agreed to conduct or (ii) July 31, 2019, whichever comes earlier. Respectfully Submitted, Dated: May 24, 2019 Dated: May 24, 2019 By: /s/ Deborah K. Marcuse Deborah K. Marcuse (admitted pro hac vice) Steven J. Kelley (admitted pro hac vice) Austin Webbert (admitted pro hac vice) SANFORD HEISLER SHARP, LLP 400 Pratt Street, 8th Floor Baltimore, MD 21202 Telephone: (410) 834-7415 Facsimile: (410) 834-7425 dmarcuse@sanfordheisler.com skelly@sanfordheisler.com awebbert@sanfordheisler.com By: /s/ Joan A. Lukey Joan A. Lukey (N.H. Bar. ID #16246) Justin J. Wolosz (admitted pro hac vice) Lyndsey M. Kruzer (admitted pro hac vice) CHOATE HALL & STEWART LLP Two International Place Boston, MA 02111 (617) 248-4949 joan.lukey@choate.com jwolosz@choate.com lkruzer@choate.com David W. Sanford (admitted pro hac vice) Nicole E. Wiitala (admitted pro hac vice) SANFORD HEISLER SHARP, LLP 1350 Avenue of the Americas, 31st Floor New York, New York 10019 Telephone: (646) 402-5650 Facsimile: (646) 402-5651 dsanford@sanfordheisler.com nwiitala@sanfordheisler.com -2- Attorneys for Defendant Case 1:18-cv-01070-LM Document 39 Filed 05/24/19 Page 3 of 3 Charles G. Douglas, III (NH Bar #669) DOUGLAS, LEONARD & GARVEY, P.C. 14 South Street, Suite 5 Concord, NH 03301 Telephone: (603) 224-1988 Fax: (603) 229-1988 chuck@nhlawoffice.com Attorneys for Plaintiffs and the Proposed Class -3-