Biediger et al v. Quinnipiac Univ

Filing 107

MOTION to Certify Class by Robin Lamott Sparks, Stephanie Biediger, Logan Riker, Kayla Lawler, Erin Overdevest, Kristen Corinaldesi.Responses due by 2/22/2010 (Hernandez, Alex)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT STEPHANIE BIEDIGER, KAYLA LAWLER ERIN OVERDEVEST, KRISTEN CORINALDESI, and LOGAN RIKER, individually and on behalf of all those similarly situated; and ROBIN LAMOTT SPARKS, individually, Plaintiffs, v. QUINNIPIAC UNIVERSITY, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 3:09-CV-621(SRU)

February 1, 2010

MOTION FOR CLASS CERTIFICATION Pursuant to Rule 23 of the Federal Rules of Civil Procedure, the Plaintiffs, by and through their undersigned counsel, move the Court for the entry of an Order certifying them as a class, certifying this action as a class action, appointing Plaintiffs as class representatives, and appointing counsel as class counsel. The legal authority and

arguments in support of the Plaintiffs' Motion for Class Certification are set forth in the accompanying Memorandum of Law filed contemporaneously with this Motion. As set forth in greater detail in the Plaintiffs' Memorandum of Law: members of the class are so numerous, diverse, and fluid that joinder is impracticable; the action involves facts and issues common to all class members; claims of the named class representatives are typical of those of the proposed class; and the named Plaintiffs and their counsel will provide adequate representation for the class.

In addition, the Plaintiffs primarily seek injunctive relief. Plaintiffs request that this Court certify this case as a class action. Respectfully submitted, THE PLAINTIFFS

Accordingly, Class

By: /s/ Alex V. Hernandez Alex V. Hernandez (ct08345) Jonathan B. Orleans (ct05440) Pullman & Comley 850 Main Street Bridgeport, CT 06601 [phone] (phone) [phone] (fax) [e-mail] [e-mail] Kristen Galles Equity Legal 10 Rosecrest Avenue Alexandria, VA 22301 [phone] (phone) [phone] (fax) [e-mail] David McGuire (ct27523) ACLU Foundation of Connecticut 2074 Park Street, Suite L Hartford, CT 06106 [phone] (phone) [phone] (fax) [e-mail] Their Attorneys

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CERTIFICATION OF SERVICE I hereby certify that on the date hereon, a copy of the foregoing MOTION FOR CLASS CERTIFICATION was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

/s/ Alex V. Hernandez Alex V. Hernandez (ct08345)

ACTIVE/73061.1/AHERNANDEZ/2006947v1

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