Motion for Alternative Forms of Relief — Norris v. Stanley

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IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF MICHIGAN 
 
 
 
    
    
 
   
JEANNA NORRIS, on behalf of herself 
) 
and all others similarly situated, 
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   ) 
 
   
 
 
 
 
 
Plaintiffs, 
 
 
   ) 
             
   ) 
 
v. 
 
    
                           ) 
 
 
    
 
 
 
   ) 
Case No. 1:21-cv-756 
SAMUEL STANLEY, JR., in his        
   ) 
 
 
 
 
official capacity as President of 
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Michigan State University; DIANNE            ) 
 
BYRUM, in her official capacity as Chair    ) 
 
of the Board of Trustees, DAN KELLY,       ) 
in his official capacity as Vice Chair              ) 
 
of the Board of Trustees; and RENEE 
) 
JEFFERSON, PAT O’KEEFE,   
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BRIANNA T. SCOTT, KELLY TEBAY,  
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and REMA VASSAR  in their official  
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capacities as Members of the Board of 
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Trustees, of Michigan State University, 
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and John and Jane Does 1-10, 
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Defendants.   
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MOTION FOR ALTERNATIVE FORMS OF RELIEF IN LIGHT OF THE 
UNAUTHORIZED LATE FILING OF A SECOND DR. ZERVOS DECLARATION 
 
 
 
Pursuant to Fed. R. Civ. P. 12(f) and this Court’s inherent authority to manage this 
litigation, Plaintiff hereby moves for the Second Declaration of Dr. Zervos filed yesterday (Dkt # 
17) to be stricken or for alternative relief to be granted as explained in the accompanying brief in 
support of this motion. 
September 21, 2021 
Respectfully submitted, 
 
 
/s/ Jenin Younes  
Jenin Younes 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22,  PageID.740   Filed 09/21/21   Page 1 of 2

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Litigation Counsel 
Jenin.Younes@ncla.legal 
Admitted in this Court 
* Admitted only in New York.  DC practice 
limited to matters and proceedings before 
United States courts and agencies.  
Practicing under members of the District of 
Columbia Bar. 
/s/ Harriet Hageman  
/s/ Harriet Hageman,* MSB #87482  
Senior Litigation Counsel 
Admitted in this Court 
Harriet.Hageman@ncla.legal 
* Admitted only in Wyoming, Colorado, and 
Nebraska.  Practice limited to matters and 
proceedings before United States Courts and 
agencies.  Practicing under members of the 
District of Columbia Bar. 
 
/s/ John Vecchione  
/s/ John Vecchione  
Senior Litigation Counsel 
John.Vecchione@ncla.legal 
 
 
 
 
 
 
 
Admitted in this Court 
 
NEW CIVIL LIBERTIES ALLIANCE 
1225 19th Street NW, Suite 450 
Washington, DC 20036 
Telephone: (202) 869-5210 
Facsimile: (202) 869-5238 
 
 
Attorneys for Plaintiffs 
Case 1:21-cv-00756-PLM-SJB   ECF No. 22,  PageID.741   Filed 09/21/21   Page 2 of 2

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