IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF LOUISIANA

JOINT MOTION FOR DISMISSAL

1. Plaintiff, the United States of America and Defendant, the State of Louisiana (collectively “the Parties”), hereby move for the dismissal of this proceeding under Federal Rule of Civil Procedure 41(a)(2).
2. On May 29, 2018, the Parties agreed upon the attached Agreement to Resolve Department of Justice Investigation (Exhibit A).  The Agreement resolves litigation initiated by the United States with the filing of a Complaint pursuant to Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 12131–12134.
3. In consideration of, and consistent with the terms of the Agreement, the Parties jointly move the Court to dismiss the lawsuit without prejudice, subject to retention of jurisdiction and reinstatement upon the United States’ motion for the purpose of resolving any claim that Defendant materially breached any provision of the Agreement, pursuant to Paragraph 127 of the Agreement.
4. Each Party shall bear its own costs and attorneys’ fees.
5. A proposed order for dismissal is attached hereto.

This 6th day of June, 2018

Respectfully submitted,

CERTIFICATE OF SERVICE

I certify that the foregoing Joint Motion for Dismissal was served through electronic file delivery on June 6, 2018.

/s/John J. Gaupp