FERPA Evidence Index¶

In January 2026, Kevin Bass exercised his right under FERPA to inspect his education records at TTUHSC. He reviewed approximately 1,500 pages across multiple sessions.

What he found is cited throughout the Third Amended Complaint. This page organizes the 35 key FERPA documents by theme. All descriptions and quotes below are drawn from the public court filing. For these documents presented in chronological order with embedded scans, see The Paper Trail.

I. Speech Surveillance (2020--2023)¶

The institution monitored Kevin Bass's social media for at least three years before the dismissal.

Date: Late 2020 | Author: Brandt Schneider (GSBS Dean)

"Hasn't posted anything too problematic" and recommended "following up with him."

The dean was monitoring a student's social media and recommending continued surveillance based on his posts — three years before any professionalism complaint. (¶133)

FERPA Doc 1058 — Williams: "Best Practices" for Managing Speech¶

Date: September 14, 2020 | Author: Simon Williams, Sr. Associate Dean

"I suspect that misbehavior on social media is going to become a bigger issue and we can learn some best practices from this experience."

Williams treated Kevin's case as a learning exercise for managing student speech — three years before the emergency removal. (¶133)

FERPA Doc 953 — Williams: "Obviously Protected Speech"¶

Date: February 1, 2023 | Author: Simon Williams

"It is obviously protected speech... we need to discuss an appropriate response."

Nine months before signing the emergency removal, Williams acknowledged Kevin's speech was constitutionally protected — then proposed finding an institutional "response" to it. (¶¶106, 134(a), 188)

FERPA Doc 1004 — Berk: "Same Free Speech Issues"¶

Date: February 1, 2023 | Author: Steven Berk (Dean, now deceased)

"We had problems with him on Twitter before... same free speech issues... I think we should discuss with legal."

The dean acknowledged prior "problems" with Kevin's Twitter and linked the institutional response directly to "free speech issues." (¶¶134(b), 188)

FERPA Doc 1219 — "URGENT" Dossier Compilation¶

Date: April 20, 2023 | Author: GSBS administrator

An "URGENT" request for Kevin's complete enrollment dates and research-lab history — seven months before the tweet that triggered emergency removal. Part of an active dossier-building effort. (¶133)

FERPA Doc 1432 — The Dossier¶

Date: Materials spanning 2020--2023 | Compiled by: GSBS administrator

A multi-page dossier retroactively assembling: social media screenshots, external complaint letters, tweet archives, academic records, registration and committee-meeting notes, and Kevin's Newsweek article. Active compilation confirmed months before any charged conduct. (¶133)

This same document number also contains an August 7, 2023 email from Forbes to Cobbs about the SPPCC letter: "Please take a swing at this and return as soon as possible. I have had a few people look over it." At least five people drafted and reviewed the adverse letter used against Kevin at the hearing. (¶69)

II. Professionalism Coaching as Speech Suppression¶

Kevin was assigned a professionalism coach. The coaching notes reveal the mechanism used to convert protected speech into disciplinary action.

FERPA Doc 0083 — Erwin Coaching Notes: Protected Speech as "Personality Defects"¶

Author: Dr. Cheryl Erwin (professionalism coach)

"Stop and think about what you really want. You love the attention from social media but recognize that a lot of people in your real life have stopped talking with you. Which do you really want?"

Erwin's notes "pathologized constitutionally protected commentary as personality defects" and explicitly targeted social media activity as the behavior to be suppressed. (¶¶39(b), 70)

FERPA Doc 0124 — Erwin Coaching Notes: Extended Entries¶

Author: Dr. Cheryl Erwin | Multiple dates

This heavily cited document reveals:

"The social media issues came up. They cannot be ignored. They raise issues of constitutional free speech, due process, and reputational harm... In the present he seems to be taking his First Amendment rights to make an idiot of himself."

"KB has imbibed the cultural atmosphere of conspiracy theories. This is reflected in his combative attitude towards me and everyone who is trying to help him."

"Because I had reformulated our relationship as friendship rather than coaching I consider a legal action against my employer a direct disregard of and abandonment of our friendship."

The coach identified First Amendment exercise with contempt, characterized mainstream policy views as "conspiracy theories," and equated filing a lawsuit (protected activity) with personal betrayal. In the same document, Erwin wrote that coaching would be "utterly ineffective if the mental health issues are not resolved" — yet neither referred Kevin to disability services nor modified the approach. (¶¶39(b), 42)

An August 22, 2023 entry attributed to Defendant Cobbs states:

"It is not a dispute that he has a right to say whatever he wishes. However as a matter of professionalism he does not have a right to disrupt the learning environment."

Cobbs explicitly acknowledged Kevin's First Amendment rights, then invoked "professionalism" as the workaround. (¶72)

FERPA Doc 0132 — Erwin Coaching: Speech Modification as Goal¶

Created: August 10, 2023 | Last saved: December 11, 2023 (the day of the hearing) | Author: Dr. Cheryl Erwin

"Goal: overarching goal is to find a path for K to stay in med school. Outcome: moderating his behavior, especially his communications with others."

The stated goal of professionalism coaching was explicitly speech modification. The metadata shows the document was last saved on the day of the hearing. (¶39(b))

III. The Complaint Pipeline¶

The FERPA records reveal how adverse evaluations were manufactured, routed to administrators, and used to build the case against Kevin — months before the tweet.

FERPA Doc 1339 — Brown to Forbes: Double-Counting Complaints¶

Date: June 13, 2023 | From: Dr. Megan Brown | To: Forbes

"I MET WITH MADELEINE, MY NP ON LTD WHO BROUGHT UP A NUMBER OF SPECIFIC EXAMPLES. I FORWARDED HER CONCERNS TO DR. ZAVALA AS BELOW AND WANT YOU TO BE AWARE OF THEM AS WELL."

Brown forwarded concerns from one person (Madeleine) to Forbes. Then both Brown and Madeleine filed separate "below expectations" evaluations — double-counting a single set of observations to reach the three-complaint threshold needed to trigger SPPCC proceedings. (¶67A)

FERPA Doc 1341 — Zavala to Forbes: Complaint Never Shared with Kevin¶

Date: June 8, 2023 | From: Dr. Noelle Zavala | To: Forbes

A detailed complaint about Kevin sent directly to Forbes, describing a delivery-room interaction in unflattering terms. Kevin was never told about it. He learned of its existence nearly three years later through FERPA inspection. (¶67A)

FERPA Doc 0542 — Zavala's Formal Evaluation: "Meets Expectations"¶

Date: June 24, 2023 | Author: Dr. Noelle Zavala

Sixteen days after sending the negative email to Forbes, Zavala gave Kevin a formal evaluation rating of "meets expectations." The formal evaluation and the informal email tell opposite stories — the evaluation was the official record; the email was for the file. (¶172(d))

FERPA Doc 0887 — Forbes to Trotter: Feeding Evaluations Pre-Tweet¶

Date: June 26, 2023 | From: Forbes | To: Trotter (Student Conduct Administrator)

"Just sending a few assessment ahead of our meeting tomorrow."

Forbes was feeding adverse evaluations to the Student Conduct Administrator five months before the tweet. (¶69)

FERPA Doc 1009 — Forbes Celebrates First Negative Evaluation¶

Date: June 2023 | From: Forbes | To: Williams, Nunez

"Well here is his first 1 in professionalism."

Five months before the tweet, Forbes celebrated Kevin's first negative professionalism evaluation. (¶138)

FERPA Doc 1002 — Williams Involved in Clerkship Placement¶

From: Faculty member Findley | To: Forbes

"This is the student that I called [you] about with Dr. Williams in the room before we committed the lottery."

Williams was personally involved in discussions about Kevin's clerkship placement before it occurred — the same administrator who later signed the emergency removal. (¶138)

FERPA Doc 1283 — Forbes Still Collecting After Removal¶

Date: November 27, 2023 | From: Findler | To: Trotter | CC: Forbes

"Rachel asked me to forward an evaluation to you for Kevin Bass from a psychiatry resident that gave a 'low score' alert."

Even after Kevin had been removed from campus and the hearing process was underway, Forbes was still actively soliciting and routing negative evaluations into his file. (¶138)

FERPA Doc 1083 — Forbes: Appeal Extension "Punted to Legal"¶

Date: August 10, 2023 | Author: Forbes

Forbes reported Kevin's appeal extension request "was punted to legal" — involving institutional counsel in denying Kevin adequate time to prepare his SPPCC appeal after Forbes had limited him to five business days. (¶138)

FERPA Doc 1236 — Cobbs Blocks Favorable Evaluations¶

Author: Not specified

"Just spoke with Dr. Cobbs and unfortunately can't provide the other clerkship evaluations from inpatient."

When someone sought Kevin's inpatient clerkship evaluations, Cobbs blocked access. Only adverse evaluations reached the hearing record. (¶71)

FERPA Doc 0436 / 0438 — SPPCC Letter: Before and After Editing¶

Authors: Forbes (initial draft, Doc 0436) and Forbes + Cobbs (edited version, Doc 0438)

The original draft lacked a "specific behaviors" section. That section appeared only after Forbes and Cobbs edited the file — changing it from a single "event" to plural "events." A collaboratively constructed document presented as an objective institutional assessment. (¶69)

FERPA Doc 1124 — Jensen Notes: Administratively Directed Complaints¶

Author: Jensen (PGY-2 resident) | Forwarded to: Conser, then Wilson

Jensen testified that the pediatrics clerkship coordinator (McGraw) told her to write these notes, titled "Covenant Students.docx." The notes were forwarded through institutional channels to the decision-maker (Wilson). Not organic complaints — administratively directed. (¶105)

IV. Emergency Removal and the BOLO¶

FERPA Doc 1132 — Kevin's Appeal Filed the Same Day as the Tweet¶

Date: November 3, 2023 | Author: Kevin Bass

On the same day as the tweet that supposedly triggered emergency removal, Kevin submitted a formal appeal of his pediatrics clinical assessment through institutional channels — actively and constructively engaging with the processes TTUHSC provided. (¶85)

FERPA Doc 0043 — Forbes: "I Did Not Feel Physically Threatened"¶

Date: August 14, 2023 | Author: Forbes

Forbes's own contemporaneous written account:

"At the time of this conversation, I did not feel physically threatened by Kevin."

No document in Kevin's FERPA file contains a contemporaneous claim by Forbes of physical threat. The only contemporaneous account says the opposite. Forbes later recharacterized this as: "I did not feel physically threatened by Kevin but I sure felt like he was threatening my career at the institution." (¶137)

FERPA Doc 0835 — Williams Investigation: "Not as Severe as First Perceived"¶

Date: November 6, 2023 | Author: Williams

Williams's own investigation report documented:

Forbes "subsequently reflected that this was more of a threat to her career and not an overt physical threat."

"The threat level was not as severe as first perceived."

Despite these conclusions — written two days after the emergency removal — no corrective action followed. The BOLO remained posted, the criminal trespass remained in effect, and the institution proceeded to dismissal. (¶137)

FERPA Doc 1057 — BOLO Disseminated to UMC Hospitals¶

During FERPA review, Kevin discovered the BOLO flyer was disseminated beyond TTUHSC to University Medical Center (UMC) and other clinical affiliates. A BOLO recipient texted a colleague: "a poster saying that if anyone sees Kevin Bass at UMC to contact security immediately." The BOLO reached the regional medical community. (¶116)

Author: J. Edward Bates (investigator) | To: A grievance respondent

"He has been removed from all TTUHSC and affiliated clinical sites under criminal trespass. This is due to recent posts on social media. There is no threat to you specifically, but I wanted to let you know."

Bates instructed: "Please do not forward this email."

In one sentence, the institution's own investigator (1) admitted the removal was caused by speech, (2) admitted Kevin posed no specific threat, and (3) tried to conceal the dissemination. (¶120)

FERPA Doc 1499 — Student Compiled BOLO + Tweet + Forbes Email Within Hours¶

Date: November 4, 2023, 7:55 PM | From: Student (Mendoza) | To: Cobbs, Williams, DeToledo

By 7:55 PM on the day of emergency removal, a fellow student had already compiled the BOLO flyer, the November 3 tweet, and the Forbes email screenshot into a single package and delivered it to three named defendants. Forbes's characterization spread so rapidly that a student — not an administrator — assembled and delivered it within hours. (¶89)

V. The Hearing¶

FERPA Doc 1509 — SDS Accommodation Request: No Response¶

Date: December 8, 2023, 2:19 PM | Author: Kevin Bass

Kevin submitted a formal disability accommodation request through TTUHSC's Student Disability Services system, requesting accommodations "generally but in particular concerning a student conduct hearing scheduled for Dec. 11 at 8 AM." The application was printed from TTUHSC's Banner system on December 12, 2023 — the day after the hearing. SDS issued no determination before the hearing — no denial, no approval, no alternative. (¶41)

FERPA Doc 1166 — "The Hearing Is Academic in Nature and Not Legal"¶

Date: November 16, 2023 | Exchange between: Conser and Kevin Bass

Conser: "These are academic student conduct issues... the word deposition is not applicable to these procedures. The hearing is academic in nature and not legal."

Kevin: "I still do not understand the process, given that it will apparently deviate in a major way from anything in the Student Handbook."

The institution denied Kevin legal protections by calling the hearing "academic" — while the hearing officer then selectively invoked legal authority to restrict Kevin's participation. Kevin's written objection defeats any argument that he acquiesced to the format. (¶66)

FERPA Doc 949 — Williams Drafted the Appeal Decision¶

Date: September 7, 2023 | Author: Williams

On the same day Kevin won his SPPCC appeal, Williams circulated an email titled "Draft for appeal decision." Williams administered the entire SPPCC process — received Kevin's appeal, briefed the appeal committee on procedures, and drafted the appellate decision. No independent review at any stage. (¶¶25, 55, 172(a))

FERPA Doc 199 — Title IX Forum-Shopping¶

Author: Title IX Coordinator Collins

"If she does not want to pursue a formal Title IX complaint, my plan is to turn it over to you for conduct adjudication."

When the Fernandes complaint could not proceed through Title IX — which would have given Kevin cross-examination rights and a trained impartial decision-maker under the 2020 regulations — the institution redirected it into the conduct process with fewer procedural protections. (¶102)

FERPA Doc 1186 — Cobbs and Conser Shut Down Investigator¶

"Both Cobbs and Conser shutdown Bates on pulling the other evals."

Defendants actively prevented the institution's own investigator from obtaining clerkship evaluations and interviewing Kevin, then relied on the resulting one-sided reports. (¶103)

VI. Post-Hearing and Aftermath¶

FERPA Doc 221 — Kevin Offered to Leave Voluntarily¶

Date: September 19, 2023 | Author: Kevin Bass

Six weeks before the tweet, Kevin expressed willingness to take a leave of absence. The institution ignored the offer. If safety were genuinely the concern, Kevin's own offer of physical separation would have addressed it. (¶114)

FERPA Doc 1510 — Final Appeal Designation¶

Vice Provost Kruse was "designated by the TTUHSC Provost" to conduct the final appeal under Handbook Part II.F.4.q. On January 11, 2024, Kruse rejected the appeal. (¶125)

FERPA Doc 0140 — Financial Aid: "W/D Folder" and Dismissal Template¶

Date: October 9, 2025 (Myers received) | Source: TTUHSC financial aid office

Kevin's financial aid file was stored in a "W/D folder for 23-24" — a routine withdrawal processing folder. The same folder contained a "DISMISSAL MEMO TEMPLATE," indicating TTUHSC maintained a standardized process for converting dismissals into withdrawal paperwork. Myers's office was still involved in the financial consequences nearly two years later. (¶149B)

Source and Method¶

All descriptions and quotations on this page are drawn from the Third Amended Complaint, a public federal court filing. "FERPA Doc ####" refers to Kevin Bass's internal identifier for records reviewed during the January 5--8, 2026 FERPA inspection of his education records at TTUHSC.

The underlying documents are education records protected by FERPA. Their contents are described here only to the extent already disclosed in the public complaint.

Court Filings — Download the complaint and response to motion to dismiss
Case Arc Timeline — Full chronology
Key Exhibits — Curated selection of important documents
The Story — Narrative overview