Welcome! This web page is designed to provide the class members in Cohen v. Brown University – all women student-athletes and potential student-athletes at Brown University since 1992 – and all interested others with access to key recent documents in the case. If there are particular documents not here that you would like to see, please contact abryant@baileyglasser.com. Exhibits to some of the depositions and descriptions of the exhibits are still being added.
Excellence in Athletics Initiative Documents
Brown University’s decision in May and June of 2020 to eliminate 5 women’s and 3 men’s varsity intercollegiate athletic teams – including twice as many women as men – resulted from and was part of its Excellence in Athletics Initiative. These are internal Brown documents from that process, including meetings of the Excellence in Athletics Committee.
Excellence in Athletics Committee Materials
Exhibits to Deposition of President Christina Paxson
For deposition video and transcript, click here.
Exhibit 1: May 28, 2020 Athletics Announcement
Exhibit 2: June 6, 2020 Athletics Announcement
Exhibit 3: Emails between President Paxson and Same Mencoff 6/5/2020
Exhibit 4: Emails between President Paxson, Samuel Mencoff, and Kevin Mundt 6/9/2020
Exhibit 5: Emails between President Paxson, Samuel Mencoff, and Kevin Mundt 1/5/2020
Exhibit 6: Committee on Excellence in Athletics Overview
Exhibit 7: Emails between President Paxson, Samuel Mencoff, and Kevin Mundt 1/6/2020
Exhibit 8: Committee on Excellence in Athletics Meeting PowerPoint 4/17/2020
Exhibit 9: Roster Scenarios PowerPoint
Exhibit 10: Corporation Committee on Campus Life PowerPoint 5/14/2020
Exhibit 12: Resolution on Varsity Athletics and Club Sports
Exhibit 13: Emails between President Paxson and Athletic Director Hayes 5/21/2020
Exhibit 14: Emails between President Paxson and Athletic Director Hayes 5/21/2020
Exhibit 15: Emails between President Paxson and Samuel Mencoff 6/7/2020
Paxson Exhibit 16: Emails from President Paxson to Brown Corporation 6/4/202
Exhibit 17: Emails to Committee on Excellence in Athletics 6/8/2020
Exhibit 18: Title IX PowerPoint for Committee on Excellence in Athletics
Exhibits to Deposition of Excellence in Athletics Committee Chair Kevin Mundt
For deposition video and transcript, click here.
Exhibit 1: Title IX PowerPoint from the Excellence in Athletics Committee Meeting
Exhibit 2: Emails between President Paxson and Kevin Mundt 6/5/2020
Exhibit 3: Emails between President Paxson, Kevin Mundt, and Samuel Mencoff 1/5/2020
Exhibit 4: Corporation Committee on Campus Life 5/14/2020
Exhibit 9: Emails between President Paxson and Kevin Mundt 6/6/2020
Exhibit 10: Emails between President Paxson, Keven Mundt, and Samuel Mencoff 6/9/2020
Exhibit 11: Emails with Committee on Excellence in Athletes setting June Meeting 6/8/2020
Exhibit 12: Email to Mundt from Alum 6/13/2020
Exhibits to Deposition of Athletic Director Jack Hayes
For deposition video and transcript, click here.
Exhibit 1: Emails between AD Hayes and Samuel Mencoff 6-4-2020
Exhibit 2: Emails between AD Hayes and Samuel Mencoff 6-4-2020
Exhibit 3: Committee on Excellence in Athletics Committee Charge 3-10-2020
Exhibit 4: Email between President Paxson, Kevin Mundt, and Samuel Mencoff
Exhibit 6: Email with office of President regarding roster sizes 3-8-2020
Exhibit 7: Email with Hayes’s notes from Committee on Excellence in Athletics April meeting
Exhibit 8: Draft PowerPoint for Committee on Excellence in Athletics April Meeting
Exhibit 9: Committee on Excellence in Athletics April Meeting PowerPoint
Exhibit 10: Emails between AD Hayes and Colleen Kelly 4-20-2020
Exhibit 12: Email between AD Hayes and President Paxson
Exhibit 13: Roster Comparisons
Exhibit 14: June 6, 2020 Athletics Announcement
Exhibit 15: Roster Comparisons with track reinstated
Exhibit 16: Emails between AD Hayes and coaches regarding ideal roster sizes
Exhibit 17A: Cumulative ideal roster sizes
Exhibit 18: Emails between AD Hayes and Samuel Mencoff
Exhibit 19: Emails between AD Hayes and John Mollicone 5-15-2020
Exhibit 20: Email between AD Hayes and John Mollicon 6-3-2020
Exhibits to Deposition of Sailing Coach John Mollicone
For deposition video and transcript, click here
Exhibit 1: 2019-2020 Club Sailing Roster
Exhibit 2: Email between Mollicone and AD Hayes 5-14-2020
Exhibit 3: Email with Sailing Plan from AD Hayes 6-29-2020
Exhibit 4: Email between Mollicone and Sailing Team 6-17-2020
Exhibit 5: 2020-2021 Preseason Roster (Women)
Exhibit 6: 2020-2021 Preseason Roster (Coed)
Exhibit 7: Email between Mollicone and Alumni 12-5-2019
“Kill this pestilential thing” Emails
These emails between Brown Chancellor Samuel Mencoff, President Christina Paxson, and Athletic Director Jack Hayes show how Brown’s leadership viewed the its 1998 Joint Agreement to comply with Title IX in this case: they wanted to, in Mencoff’s words, “kill this pestilential thing.” The emails garnered public attention nationwide (just Google “this pestilential thing”) and exposed how Brown’s public statements in support of the Joint Agreement and Title IX compared to its leaders’ true thinking
Plaintiffs’ Motion to Enforce Judgment, to Adjudge in Contempt, and for Emergency Relief
Filed June 29, 2020
Plaintiffs' Motion to Enforce Judgment, to Adjudge in Contempt, and for Emergency Relief
Plaintiffs’ Supplemental Brief in Support of Motion
Filed August 26, 2020
Plaintiffs' Supplemental Brief in Support of Motion
Defendants' Opposition to Plaintiffs’ Motion
Filed September 2, 2020
Defendants' Opposition to Plaintiffs' Motion
Plaintiffs’ Reply Brief in Support of Motion
Filed September 8, 2020
Plaintiffs' Reply Brief in Support of Motion
Proposed Settlement and Joint Motion for Preliminary Approval
Filed September 23, 2020
Proposed Settlement and Joint Motion for Preliminary Approval
Notice of Proposed Settlement of Class Action Lawsuit
Class Notice 09.25.2020 (Final)
Appellate Briefs
Brief of Objectors-Appellants to Court of Appeals
Brief of Plaintiffs-Appellees to Court of Appeals
How can we
Help you?
Find a Lawyer
To reach one of our lawyers directly, please click here to access our firm directory.
Toll-Free Number
If you or your client might benefit from working with Bailey Glasser’s legal team, contact us today at 877.852.0342.
Join Our Team
To express your interest in joining our team, please click here to contact Bailey Glasser's recruiting contacts.