Key Exhibits¶
A curated selection of essential documents for new readers, journalists, and legal counsel.
These documents represent the core evidentiary record. Each entry includes a date, brief neutral description, and links to related materials.
How to Use This Page¶
- Journalists: Start here for the essential documents to verify claims
- Legal counsel: Use this as an orientation before diving into the full archive
- New readers: These documents tell the story through primary sources
For the complete archive, see the Documents Index. For court filings, see Court Filings. For the institution's own emails in chronological order, see The Paper Trail.
Federal Court Filings (February 2026)¶
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February 2026 — 104-Page Federal Complaint
The operative complaint in Bass v. TTUHSC et al., No. 5:25-cv-00244-H-BV (N.D. Tex.), asserting seven claims against eleven defendants.
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February 2026 — Plaintiff's Response Brief + 92-Page Appendix
Responds to each ground raised in the defendants' motion to dismiss with citations to the factual record and applicable law.
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January 2026 — Defendants' Brief
Seeks dismissal of all claims on qualified immunity, sovereign immunity, and failure-to-state-a-claim grounds.
Key Case Documents¶
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October 2, 2025 — Initial TPIA Request
The first formal Texas Public Information Act request for proceedings records, establishing the timeline of records requests.
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October 6, 2025 — Preservation Notice
Comprehensive preservation notice requiring TTUHSC and TTU to preserve all records responsive to pending requests. The foundational legal notice.
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October 7, 2025 — Deficiency Notice
Notice regarding non-acknowledgment of the preservation request, documenting the lack of initial response.
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October 7, 2025 — Right to Respond Request
Request regarding hearing recording integrity, raising questions about the completeness of the administrative record.
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October 9, 2025 — AG Referral
Referral to the Texas Attorney General after TPIA responses were delayed or incomplete. Key escalation document.
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October 19, 2025 — Name-Clearing Hearing Request
Formal request for a name-clearing hearing, with no substantive institutional response documented.
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November 3, 2025 — Cost Estimate Dispute
Extensive correspondence regarding cost estimates for records production, contested as potentially creating barriers.
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November 26, 2025 — Supplemental Cost Complaint
Supplemental complaint filed with the Texas Attorney General regarding cost estimates.
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December 14, 2025 — FERPA Request for Hearing Video
Request for access to the December 11, 2023 dismissal hearing recording under FERPA.
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December 19, 2025 — FERPA Complaint to DOE
Formal complaint filed with the U.S. Department of Education regarding denial of access to education records.
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December 15, 2025 — Debt Collection Referral
Documentation of TTUHSC's referral to debt collection during pending records disputes.
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December 19, 2025 — TPIA for Debt Collection Records
Request for records related to the debt collection referral.
What These Documents Show¶
Taken together, these documents establish:
- Federal lawsuit — Seven claims filed against eleven defendants in N.D. Tex.
- Timeline — A clear chronological sequence from the 2023 dismissal through 2026 litigation
- Formal requests — Multiple TPIA and FERPA requests properly filed
- Escalation — Referral to AG and DOE when responses were delayed; federal suit when administrative remedies were exhausted
- Procedural gaps — Documented non-responses and timing issues
- Ongoing disputes — Motion to dismiss pending; cost estimates, access barriers, and regulatory rulings ongoing
What These Documents Do NOT Establish¶
These documents do not:
- Prove any individual acted with malice
- Establish legal violations (that is for courts and agencies)
- Substitute for professional legal analysis
- Provide a complete account (some records are pending)
Next Steps¶
| If you want to... | See... |
|---|---|
| Understand the key discrepancies | Record vs. Reality |
| See the full timeline | Case Arc Timeline |
| Browse all documents | Documents Index |
| Read the narrative context | The Story |
| Check current status | Process Dashboard |
How to Cite¶
When referencing these exhibits:
TTUHSC Case Hub, [DOC-ID], [Title], https://case.kevinnbass.com/docs/[doc-id]/
Example:
TTUHSC Case Hub, DOC-20251006-001, "Immediate Preservation Notice," https://case.kevinnbass.com/docs/doc-20251006-001/