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 8: Roster Projections

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

Emails (pestilential)

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

Joint Motion for Settlement

Exhibit A

Exhibit B

Notice of Proposed Settlement of Class Action Lawsuit

Class Notice 09.25.2020 (Final)

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