Objections to the Findings, Conclusions, and Recommendation on the request for a preliminary injunction (re Dkt. 7); medical information and correspondence with another university withheld, and one passage on p. 16 and diagnosis terms blacked out, on this copy¶
Bass v. TTUHSC, No. 5:25-cv-00244-H-BV (N.D. Tex.) · Dkt. 8 · 2025-12-08 · PDF
Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.
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FILED - USDC - NDTX - LU
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
5:25-CV-244
5:25-CV-244
LUBBOCK DIVISION
§
Plaintiff, §
§
v. § Civil Action No. 5:25-cv-00270-H
§
TEXAS TECH UNIVERSITY HEALTH §
SCIENCES CENTER, et al., §
§
Defendants. §
PLAINTIFF'S OBJECTIONS TO THE MAGISTRATE JUDGE'S
FINDINGS, CONCLUSIONS, AND RECOMMENDATION REGARDING
PRELIMINARY INJUNCTIVE RELIEF, AND BRIEF IN SUPPORT
(FED. R. CIV. P. 72 & 28 U.S.C. § 636(b)(1))
TO THE HONORABLE DISTRICT JUDGE HENDRIX:
Plaintiff Kevin N. Bass, Ph.D. ("Plaintiff"), proceeding pro se, respectfully submits these
objections to the Magistrate Judge's Findings, Conclusions, and Recommendation ("FCR")
recommending denial of preliminary injunctive relief. These objections are filed under Federal
Rule of Civil Procedure 72(b), 28 U.S.C. § 636(b)(1), and Local Civil Rule 72.2, and are
supported by the Verified Complaint, Plaintiff's unsworn declaration under 28 U.S.C. § 1746
("Bass Decl."), and Exhibits 1·7 and W.
I. INTRODUCTION AND OVERVIEW OF CLAIMS
1.
This case challenges an ongoing combination of state-created stigma and status change that
functions as a quasi-official declaration that Plaintiff is unsafe and unfit to participate in
medicine. TTUHSC has (a) dismissed Plaintiff from its M.D./Ph.D. program on alleged
"non-academic" grounds; (b) placed an "Administrative Dismissal Effective 01-11-2024" notation
on his official School of Medicine and Graduate School transcripts; and (c) used
emergency-removal, campus-ban, and threat-assessment paperwork·plus internal broadcasts
telling students they were "one student lighter" and to "check his Twitter"·to frame him as a
dangerous, sexually inappropriate student whose dismissal was justified by safety concerns.
2.
The Verified Complaint asserts six counts, all aimed at forward-looking relief:
1
KEVINN.BAS,Ph.D.,§
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* **Counts 1·2 (ADA / § 504).** TTUHSC allegedly misused ·direct threat· rhetoric while
denying effective-communication and process accommodations documented by Plaintiff's
neuropsychological evaluation and by TTUHSC's own disability-services policy.
* **Count 3 (procedural due process).** TTUHSC allegedly imposed an extreme status change
(emergency suspension, campus ban, and eventual dismissal) without meaningful
pre-deprivation conversation or transparent procedures.
* **Count 4 (stigma-plus / name-clearing).** TTUHSC's transcript notation, CTW/threat
paperwork, and related publications are alleged to satisfy the Fifth Circuit's seven-factor
·stigma-plus-infringement· test and to require a name-clearing hearing.
* **Counts 5·6 (First Amendment and ADA/§ 504 retaliation).** Plaintiff alleges that
controversial but protected Twitter commentary and internal grievances about discrimination
were used as a trigger for the ·threat· narrative, suspension, and dismissal.
3.
The FCR recommends denying preliminary injunctive relief primarily because (a) the
Magistrate Judge did not see proof of Rule 65(a)(1) notice, and (b) on the complaint-only record,
the harms were characterized as ·past· or purely reputational and therefore compensable by
damages. Plaintiff now offers a sworn declaration and
targeted exhibits that substantially change the record on irreparable harm and clarify how each
count supports narrow, forward-looking relief.
4.
Plaintiff is **not** presently asking the Court to order full reinstatement. The immediate
request is narrower: (1) interim relief to stop TTUHSC from further non-required dissemination
of the stigmatizing transcript notation and ·threat· narrative; and (2) an ADA-compliant, neutral
name-clearing hearing (and related transcript annotation) that addresses the continuing
stigma-plus injury at the heart of Counts 3·4, with accommodations necessary to vindicate
Counts 1·2 and guard against further retaliation under Counts 5·6.
5.
At a minimum, Plaintiff asks that the Court **not** adopt the FCR's irreparable-harm analysis
as law of the case. Instead, the Court should (a) recognize that service and notice defects are
now being cured; (b) hold that Plaintiff has plausibly alleged, and now evidences, ongoing,
non-compensable injuries tied to each count; and (c) preserve Plaintiff's ability to obtain
preliminary relief on a fuller, adversarial record after Defendants appear.
II. PROCEDURAL POSTURE AND SERVICE / NOTICE
6.
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Plaintiff filed his Verified Complaint and embedded Rule 65 section on November 6·7, 2025,
before Defendants had been served or appeared. The Magistrate Judge treated that embedded
section as an operative preliminary-injunction motion and ruled on the complaint-only
record.
7.
On the same day these Objections are filed, Plaintiff is **serving the summons, Verified
Complaint, and this Rule 65 briefing (including Exhibits 1·7 and W) on all named Defendants**
by methods permitted under Rule 4. Plaintiff will file proofs of service as soon as they are
available. He does **not** seek ex parte injunctive relief, and any temporary relief he ultimately
obtains would follow notice and an opportunity for Defendants to respond.
8.
This approach satisfies Rule 65(a)(1)'s notice requirement and cures the procedural concern
identified in cases where courts deny preliminary relief solely because the movant had not yet
provided notice or a certificate of service. Plaintiff respectfully requests that, to the extent the
Court denies interim relief at this stage, such denial be expressly **without prejudice** to a
renewed motion after service and a short adversarial schedule.
III. PRELIMINARY-INJUNCTION STANDARD (SHORT STATEMENT)
9.
The familiar four-factor test applies: Plaintiff must show (1) a substantial likelihood of success
on at least one claim; (2) a substantial threat of irreparable injury if preliminary relief is denied;
(3) that the threatened injury outweighs any harm to Defendants; and (4) that an injunction will
not disserve the public interest. An injury is irreparable if it "cannot be undone through
monetary remedies."
10.
Courts in this Circuit have repeatedly held that ongoing constitutional violations, loss of
unique educational or professional opportunities, and structural barriers to pursuing one's
chosen profession can constitute irreparable harm·particularly where the defendant is a
sovereign immune from damages. That principle is especially salient where, as here, a medical
student alleges a state-created stigma-plus condition that blocks access to the only pipeline into
his chosen profession.
IV. OBJECTION NO. 1 · RULE 65 NOTICE IS NOW BEING SATISFIED
11.
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The FCR correctly noted that Plaintiff had not yet proved notice to Defendants when the
Magistrate Judge ruled on the embedded Rule 65 request. But that defect is now being cured:
Plaintiff is contemporaneously serving the summons, Verified Complaint, this brief, and all
supporting exhibits via Rule 4. See supra ¶ 7.
12.
Because the purpose of Rule 65(a)(1) is to ensure that preliminary injunctions are not issued
without notice and an opportunity to be heard, not to bar relief forever based on a curable timing
issue, Plaintiff respectfully objects to any reading of the FCR that would preclude renewed
preliminary-injunction practice after service.
13.
Plaintiff therefore asks the Court to (a) treat the FCR·s Rule 65 notice discussion as limited to
the pre-service record, and (b) expressly state that Plaintiff may seek preliminary relief
again·on proper notice and with full adversarial briefing·if the Court concludes that immediate
relief is not appropriate at this juncture.
V. OBJECTION NO. 2 · THE FCR MISAPPREHENDS IRREPARABLE HARM AND THE SIX
COUNTS
A. Counts 3·4: Ongoing stigma-plus and denial of a name-clearing hearing
14.
Plaintiff·s declaration and exhibits now show a **continuing** stigma-plus condition:
a. **Transcript notation and republication.** TTUHSC·s official SOM transcript·most recently
issued on October 16, 2025·contains the notation ·Administrative Dismissal Effective
01-11-2024.· Every time TTUHSC, through Parchment, issues that transcript to a medical
school, residency, or fellowship program, it republishes a disciplinary dismissal label that
medical-education gatekeepers understand as a serious, non-academic infraction.
b. **Threat narrative, CTW, and broadcast emails.** TTUHSC·s emergency-removal and CTW
paperwork, plus internal broadcasts and residency/GME messaging, describe Plaintiff to
campus and hospital gatekeepers as someone who cannot be allowed on campus or in clinical
facilities because of ·threat· concerns and ·harassing· behavior.
c. **Public echo in the medical community.** Third-party physicians, residents, and students
now tell national audiences that Plaintiff was ·kicked out of medical school for sexual
harassment and threats of physical violence,· is ·only allowed on campus with a police escort,·
and was expelled after TTUHSC ·made flyers.· These posts explicitly tie their claims to
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TTUHSC's dismissal and threat-assessment actions, and some even boast "we are the reason
he was expelled."
15.
Plaintiff's October 19, 2025 email to TTUHSC (Exhibit 6) formally **invokes his liberty interest
and requests a name-clearing hearing and interim transcript relief**·including a neutral
transcript annotation, identification of prior transcript recipients, and a pause on non-required
dissemination of the stigmatizing narrative. He also requests ADA/§ 504 accommodations for
that hearing and an ongoing interactive process with Student Disability Services.
16.
TTUHSC has **not** scheduled such a hearing, has not identified a neutral presider, and has
not provided interim transcript relief despite follow-up emails asking for confirmation and a
schedule. Plaintiff remains ready and willing to participate in an ADA-compliant name-clearing
process.
17.
Under Fifth Circuit law, a stigma-plus claim arises where the government (1) makes
stigmatizing charges, (2) in connection with an altered legal status, (3) disseminates them to
third parties, and (4) refuses a requested name-clearing hearing. Texas courts applying similar
principles in the medical-education context have recognized that a disciplinary dismissal record
may render it "virtually impossible" for a student to gain admission elsewhere or enter the
profession, and have ordered new hearings as the appropriate remedy.
18.
Plaintiff's evidence fits that paradigm: the *""plus""* is not just loss of a single position; it is a
formal label on state-controlled transcripts and threat-assessment paperwork that state actors
continue to issue and rely on, combined with TTUHSC's refusal to provide the requested,
ADA-compliant name-clearing hearing. The injury is therefore **ongoing and constitutional**,
not a one-time reputational bruise.
19.
Because money damages years from now cannot erase the trail of official transcripts,
CTW/threat directives, and derivative online posts that will have already circulated through
residency programs, employers, and background checks, this stigma-plus injury is irreparable
absent forward-looking relief under Counts 3·4.
B. Counts 1·2: ADA / § 504 "direct threat" and effective-communication failures
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20.
Plaintiff's neuropsychological evaluation documents a combination of
and
conditions that substantially limit his ability to concentrate, think, and
communicate efficiently in time-pressured, adversarial settings. The evaluator recommended
standard accommodations such as extended or flexible time for complex questioning, scheduled
breaks, and options for written questions.
21.
TTUHSC received timely ADA notice. A December 8, 2023 email from Plaintiff's counsel
informed TTUHSC that a formal evaluation had been completed, that it identified significant
conditions, and that the report would be provided so decision-makers could
consider diagnosis and accommodations at the December 11, 2023 hearing.
22.
Yet the hearing officer: (a) treated ADA compliance as someone else's responsibility
("normally we go through Student Disability Services"); (b) limited "accommodations" to water,
snacks, and unscheduled breaks; (c) barred Plaintiff's counsel from directly questioning
witnesses, allowing only written questions through the presider; (d) withheld the
accommodations section of the evaluation from the Board; and (e) excluded the
neuropsychologist's testimony.
23.
These choices violated TTUHSC's own ADA policy, which describes the ADA and § 504 as
civil-rights statutes that obligate TTUHSC to make "adjustments and accommodations" and
"offer to persons with disabilities the opportunity to participate fully in all institutional programs
and activities," including high-stakes disciplinary processes.
24.
Plaintiff's October 19, 2025 name-clearing request explicitly asks TTUHSC to treat a future
hearing as part of an **ongoing ADA/§ 504 interactive process**, identifies specific
communication-related accommodations (equal time; scheduled breaks; neutral presider
managing turn-taking; option for written questions; real-time captioning if needed; and the ability
to consult notes), and states that SDS intake can proceed in parallel without delaying the
hearing.
25.
TTUHSC's refusal to provide *any* process that integrates those accommodations·while
continuing to operate its professionalism and threat-assessment systems in the same
way·creates an ongoing Title II / § 504 violation. Courts recognize that where a public entity's
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policies and practices deny disabled individuals meaningful access to official proceedings,
injunctive relief is an appropriate and often necessary remedy. The FCR·s suggestion that
Plaintiff·s injuries are purely retrospective does not account for the prospective, process-oriented
nature of Counts 1·2.
C. Counts 5·6: Retaliation and continuing chill of protected speech
26.
Exhibit W (meeting with Senior Associate Dean Simon Williams) shows that a key
decision-maker has ·never sensed threat or danger· from Plaintiff, characterizes the tweet at
issue as ·free speech,· and describes TTUHSC·s response (suspension and campus ban) as
·pretty extreme· and something he has seen only once before.
27.
Williams repeatedly tells Plaintiff that ·people shouldn·t overreact to your tweets,·
acknowledges that the tweet was ·misinterpreted,· and agrees that the institution·s response
links the tweet to generalized concerns rather than any concrete threat. Plaintiff, for his part,
explicitly disavows violence and anchors his conduct in ·big dreams· and long-term
goals.
28.
The same internal communications that fuel Count 4·s stigma-plus theory also support Counts
5·6: the ·we are one student lighter· check his Twitter· class email and related broadcasts
explicitly invite students and residents to view Plaintiff·s controversial speech as the cause of his
removal. Online posts catalogued in Exhibit 4 reiterate that narrative to thousands of viewers,
often in direct response to Plaintiff·s ongoing public commentary.
29.
In the First Amendment context, the Supreme Court has made clear that even short-lived loss
or chilling of protected speech can constitute irreparable injury. Here, Plaintiff alleges that
TTUHSC·s actions have already chilled his willingness to speak about public-health and
institutional issues, and that continued dissemination of the ·dangerous, sexually-misconducting
student· label will deter him from exercising his rights going forward.
30.
The FCR·s irreparable-harm analysis did not have the benefit of Exhibit W, the ADA
documentation, or the name-clearing correspondence. Those materials now show that the
·threat· narrative was internally recognized as an overreaction to speech, that TTUHSC
nonetheless imposed an exceptional sanction, and that it continues to leave the speech-linked
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stigma in place while denying Plaintiff any effective forum to contest it. That combination of
retaliation and ongoing chill is classically irreparable.
D. Aggregated, ongoing harm across all six counts
31.
Plaintiff's declaration explains how these strands combine: state-controlled transcripts with a
disciplinary dismissal notation; CTW and threat-assessment paperwork; a medical-community
rumor mill that repeatedly attributes "sexual misconduct" and "threats of violence" to Plaintiff;
and the loss of time-sensitive opportunities to transfer, obtain clinical experience, or secure
fellowships.
32.
For example, Plaintiff's correspondence with St. Matthew's University School of Medicine
(Exhibit 3) shows that as early as February 2024 he was trying to transfer, that SMUSOM
required an official TTUHSC transcript and Dean's letter, and that his dismissal notation had to
be provided as part of that process. Plaintiff attests that each new transcript order and each
new application cycle "renews the damage" and further constricts his career path.
33.
These injuries cannot be fully "unwound" at the end of the case with money. A delayed
damages remedy cannot reconstruct a lost medical-school transfer cycle, restore a missed
match season, or erase the accumulated effect of official transcripts and threat narratives that
have already been transmitted to programs and employers. The FCR's conclusion that
Plaintiff's harms are purely past and compensable underestimates both the structure of medical
training and the ongoing nature of the alleged violations.
VI. OBJECTION NO. 3 - THE FCR SHOULD NOT BE TREATED AS LAW OF THE CASE
34.
Given the limited record before the Magistrate Judge and the new evidence now presented
(Exhibits 1-7 and W), Plaintiff respectfully asks that the Court not adopt the FCR's
irreparable-harm reasoning as binding law of the case. Instead, the Court should clarify that:
a. the FCR's notice discussion addressed only the pre-service posture and does not bar
renewed preliminary-injunction practice after service;
b. Plaintiff has plausibly alleged, and now substantiated, ongoing, non-compensable harms tied
to each of the six counts; and
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c. any denial of interim relief at this time is **without prejudice** to a future, fully briefed motion
supported by live testimony or additional evidence as appropriate.
VII. REQUESTED RELIEF
35.
For these reasons, Plaintiff respectfully requests that the Court:
(a) **Sustain** these objections in part by declining to adopt the FCR's irreparable-harm
analysis as law of the case;
(b) Clarify that Plaintiff may pursue preliminary injunctive relief again after service and
adversarial briefing, and, if the Court finds it useful, treat these Objections (together with
Exhibits 1-7 and W) as a renewed motion for preliminary injunction on a more complete record;
(c) In connection with any renewed motion, consider granting **narrow, restorative relief**
tailored to the six counts, including:
· Interim transcript relief (a neutral notation in place of "Administrative Dismissal Effective
01-11-2024," no re-imposition without lawful process, and identification of prior transcript
recipients so that corrective notices can be issued if appropriate);
· A pause on non-required dissemination of stigmatizing statements to external third parties
(students, donors, media, clinical affiliates) pending a name-clearing hearing;
· An ADA/§ 504-compliant name-clearing hearing before a neutral presider, with the
accommodations and procedural safeguards outlined in Exhibit 6, and written findings suitable
for public release;
· Prospective relief to ensure that any future professionalism, threat-assessment, or disciplinary
processes involving Plaintiff are conducted in compliance with the ADA/§ 504 and the
Constitution, and that Plaintiff is not retaliated against for requesting accommodations or
seeking to clear his name.
36.
Plaintiff further requests all other relief to which he may be justly entitled, at law or in equity.
Respectfully submitted,
___
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Kevin Norris Bass, Ph.D.
Plaintiff, pro se
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**UNITED STATES DISTRICT COURT**
**NORTHERN DISTRICT OF TEXAS**
**LUBBOCK DIVISION**
**KEVIN N. BASS,**
Plaintiff,
v.
**TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER, et al.,**
Defendants.
Civil Action No. 5:25-cv-00270-H
---
### DECLARATION OF KEVIN NORRIS BASS
*(28 U.S.C. § 1746 - Unsworn Declaration)*
I, Kevin Norris Bass, declare under penalty of perjury that the following is true and
correct:
1. My name is Kevin Norris Bass. I am over 18 years of age, of sound mind, and compet
ent to make this declaration. I am the plaintiff in this action, and I have personal
knowledge of the facts stated here unless otherwise indicated.
2. I was enrolled in the M.D./Ph.D. program at Texas Tech University Health Sciences
Center ("TTUHSC"). I completed my Ph.D. in March 2023 and resumed clinical clerkships
in May 2023. In late 2023, TTUHSC imposed an emergency removal and campus ban and la
ter dismissed me from the School of Medicine.
3. This declaration describes the ongoing harms I continue to suffer from TTUHSC's ac
tions, including (a) the "Administrative Dismissal" notation on my official transcrip
ts, (b) the continuing effects of TTUHSC's "threat" and Criminal Trespass Warning pap
erwork, (c) online stigma tied to TTUHSC's actions, (d) lost transfer and training op
portunities, (e) financial pressures, and (f) disability-related issues and future pr
ocesses.
---
### A. Transcript notation and continuing republication
4. My official TTUHSC School of Medicine and Graduate School of Biomedical Sciences t
ranscripts now carry an "Administrative Dismissal Effective 01-11-2024" notation unde
r Spring 2024.
5. In my experience as a student and academic, that phrasing is understood in the med
ical-education context to mean a non-academic, disciplinary dismissal--not a neutral
academic withdrawal or leave.
6. TTUHSC uses an electronic system (Parchment) to issue official transcripts. I cann
ot alter the contents of those transcripts. Any medical school or residency program t
hat requires an official transcript receives exactly what TTUHSC provides.
7. On or about October 16, 2025, I requested an official School of Medicine transcrip
t through Parchment. The transcript I received contained the notation "Administrative
Dismissal Effective 01-11-2024." I am not aware of any official version of my TTUHSC
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transcript that does **not** include this dismissal notation.
8. In 2025, I began the process of applying to transfer to St. Matthew's University S
chool of Medicine ("SMUSOM"). SMUSOM required my official TTUHSC transcripts as part
of its admissions review. To move my application forward, I had no choice but to prov
ide the TTUHSC transcript bearing the "Administrative Dismissal" notation.
9. Each time TTUHSC, through Parchment, issues an official transcript containing this
language, TTUHSC republishes a stigmatizing, non-academic dismissal notation to thir
d parties who control access to my chosen profession.
---
### B. Threat narrative, CTW, and access restrictions
10. On November 4, 2023, TTUHSC imposed an "Emergency Removal/Interim Suspension" bas
ed on a social-media post and alleged "threat" concerns. That same morning, TTU campu
s police issued a Criminal Trespass Warning ("CTW") to me.
11. The CTW barred me from "ALL TEXAS TECH PROPERTY" for a period of one year unless
otherwise stated in writing by a Texas Tech Police Department official. While it was
in effect, I could not enter TTUHSC buildings or affiliated facilities without riskin
g arrest.
12. As part of the same response, TTUHSC officials circulated communications to multi
ple recipients--including personnel associated with TTUHSC clinical sites--directing
that I not be allowed into certain offices and that I not be badged into hospitals pe
nding further notice.
13. These emergency-removal, campus-ban, and CTW documents describe me as an ongoing
safety risk and connect that risk to alleged sexual-misconduct and threat behavior. T
o my knowledge, TTUHSC has never sent a corrective communication to those same recipi
ents stating that I am not a danger or that the threat assessment was mistaken or ove
rstated.
14. The formal one-year term of the CTW has expired. However, I have never received w
ritten confirmation that the underlying "threat" classification, CTW records, or "do
not badge" instructions have been removed or corrected in TTUHSC or affiliated-hospit
al security systems. I remain concerned that these records continue to affect how hos
pitals and training sites view me.
---
### C. Online stigma and reputational harm
15. I have had a public presence on social media for several years, including Twitter
/X, Bluesky, and other platforms, where I discuss medicine, science, and health polic
y.
16. After TTUHSC's emergency removal and dismissal, I began noticing an increasing nu
mber of public posts by physicians, residents, medical students, and others discussin
g me and my situation.
17. I have personally collected and archived many posts that describe me as, for exam
ple, "kicked out of medical school for sexual misconduct," "expelled for sexual haras
sment complaints and threats of violence," "posting mass-shooter-vibes threats," or "
only allowed on campus with a police escort," and that reference TTUHSC "making flyer
s" or "warning the hospitals."
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18. Several of these posts repeat distinctive internal phrases from TTUHSC's own docu
ments and communications--for example, references to a "medical committee vote to exp
el," an emergency removal based on "threats" and "harassing residents," and email ins
tructions not to allow me onto campus.
19. From my review of engagement statistics on these platforms, many of these posts h
ave tens of thousands of views; collectively, the set of posts I have tracked has bee
n seen hundreds of thousands of times and continues to be recirculated whenever my na
me appears in public discussions.
20. I have no practical way to force these third parties to retract or delete their p
osts. As long as TTUHSC maintains its dismissal notation and threat paperwork, those
posts are effectively backed by official university records and continue to damage my
reputation in the medical and scientific community.
---
### D. Lost transfer opportunities and training cycles
21. My primary professional goal now is to build a public-health technology company t
hat works in partnership with mainstream public-health and medical institutions--heal
th systems, academic medical centers, public-health agencies, and other organizations
that serve patients at scale.
22. To enter that space, I will repeatedly have to undergo institutional due-diligenc
e and vetting. Hospitals, universities, and public-health agencies typically require
background checks and academic records when they consider someone for a leadership, a
dvisory, or co-founder role, especially if that person will be working with data, pat
ients, or trainees under their brand.
23. In every one of those settings, TTUHSC's records are the first thing evaluators w
ill see: an "Administrative Dismissal Effective 01-11-2024" on my official SOM and GS
BS transcripts, coupled with emergency-removal, threat-assessment, and Criminal Tresp
ass Warning paperwork that frames me as a danger to campus and affiliated hospitals.
Those documents function as a quasi-official statement that I am unsafe and unfit to
be in clinical environments.
24. For a public-health technology startup that depends on trust and collaboration wi
th mainstream institutions, that kind of dismissal and threat narrative is close to d
isqualifying. It makes it much harder to secure pilot sites, institutional partners,
or advisory roles, and it gives risk-averse general counsel and compliance officers a
ready reason to say "no" before they ever reach the merits of the product.
25. I also want to preserve the option of returning to medical training in the future
if that becomes realistic and compatible with my startup work. Because TTUHSC has di
smissed me, my only realistic path to an M.D. would be through transfer or re-entry i
nto another medical program. As my interactions with St. Matthew's University School
of Medicine and other institutions already show, the TTUHSC dismissal notation and th
reat narrative severely undermine that possibility and will continue to do so as long
as they remain in place.
26. Even if I ultimately never re-enter formal training, the same record will follow
me into non-clinical roles that normally would be open to someone with my education-public-health research positions, faculty and advisory appointments, and leadership r
oles in collaborations between academia and industry. The combination of TTUHSC's tra
nscript notation and threat paperwork permanently alters how future partners and empl
oyers will view me, in ways that cannot be undone simply by awarding money damages la
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ter.
27. Based on my own experience in higher education, I believe the TTUHSC "Administrat
ive Dismissal" notation and threat narrative were significant negative factors in SMU
SOM's decision. A non-academic dismissal for alleged threats and sexual misconduct is
an extreme red flag in medical education. SMUSOM made clear that they considered my
application incomplete without the TTUHSC transcripts and only reached a final decisi
on after those transcripts were received.
28. Medical-school and residency admissions work on fixed, annual cycles. Because of
the TTUHSC dismissal and its continuing effects on my record, I have already missed a
t least one full transfer cycle and face the risk of missing others. Each missed cycl
e is gone forever and becomes another gap in my training history that makes re-entry
more difficult.
---
### E. Financial pressures
29. Following my dismissal, TTUHSC reversed financial-aid transactions that had been
planned for Spring 2024. On February 12, 2024, TTUHSC notified me that I owed a balan
ce of $24,316.56 for the Spring 2024 semester, which I did not attend, after the retu
rn of $3,524.00 from a Federal Direct Unsubsidized Loan and the cancellation of a $20
,118.11 scholarship.
30. At present, I owe approximately $250,000 in student loans from my combined gradua
te and medical education. While my medical education has been halted, those loans hav
e continued to accrue interest and capitalized charges.
31. Because of TTUHSC's dismissal notation and threat narrative, I have been unable t
o secure a position in another medical program that would allow me to continue progre
ssing toward a physician's income. Instead, I am attempting to support myself and my
family with non-physician work while servicing large debts originally incurred to bec
ome a doctor.
32. The longer I remain unable to re-enter medical training, the more the interest, f
ees, and opportunity cost accumulate. These financial harms are ongoing and are direc
tly tied to the obstacles created by TTUHSC's records and narrative.
---
### F. Disability, ADA/S [REDACTED] 504, and future processes
It also recommended specific academic and testing accommodations, such as:
* testing in a distraction-free environment;
* extra time (e.g., 1.5x) and additional breaks;
* permission to record and use visual aids; and
* clearer, more structured instructions and supports during complex tasks.
35. Through my attorney, I provided TTUHSC with this evaluation shortly before the De
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cember 11, 2023 Student Conduct Board hearing and requested accommodations for the he
aring consistent with the report, including modified questioning format and additiona
l time.
36. TTUHSC produced a heavily redacted version of the evaluation for the hearing, tre
ated parts of the report as "outside the scope," and did not meaningfully engage in a
n interactive process about the accommodations I needed for that high-stakes proceedi
ng.
37. During the December 11 hearing, I struggled to track rapid questioning and to org
anize my thoughts under the time limits imposed. The restrictions on my counsel's abi
lity to speak directly also made it harder for me to compensate for my processing and
communication limitations. I did my best to explain and respond, but I was often ove
rwhelmed and felt that I could not fully present my side of the story.
38. Because TTUHSC remains my record-holder and continues to publish the dismissal no
tation and threat narrative, I have sought an opportunity to clear my name in a proce
ss that accounts for my disabilities. On October 19, 2025, I sent TTUHSC a written re
quest for a name-clearing hearing and for neutral interim transcript language, copyin
g Student Disability Services and counsel. In that request, I expressly asked for an
ADA/S[REDACTED]504-compliant process, including appropriate accommodations.
39. As of the date of this declaration, TTUHSC has not scheduled a name-clearing hear
ing, has not offered any meaningful alternative forum for me to contest the allegatio
ns in public, and has not provided any interim changes to my transcripts beyond the e
xisting "Administrative Dismissal" notation. I have not been provided with an identif
ied ADA coordinator or a structured interactive process for discussing the accommodat
ions I would need in future proceedings.
40. I remain willing and ready to participate in a properly structured, ADA-compliant
hearing or process that would allow me to contest TTUHSC's accusations, address the
threat narrative, and work toward restoring my ability to pursue medical training.
---
### G. Aggregated, ongoing harm
41. TTUHSC's actions have created a continuing combination of stigma and status chang
e for me: (a) a formal, non-academic dismissal notation on my official transcripts; (
b) threat-assessment and CTW records disseminated to campus and hospital gatekeepers;
and (c) an external narrative, repeated by members of the medical community, that I
was expelled and banned from campus for threats and sexual misconduct.
42. These harms are not confined to the past. Each new transcript order, each backgro
und check that queries TTUHSC, and each application that forces me to disclose the di
smissal and "threat" story renews the damage to my reputation and professional prospe
cts.
43. Because of my age, the amount of training I have already completed, and the struc
tured nature of medical-school and residency cycles, additional delay has outsized co
nsequences. Lost clerkship opportunities, missed transfer cycles, and damaged reputat
ion cannot be fully repaired later, even if I were eventually to receive money damage
s.
44. For these reasons, I believe that the harms I am suffering from TTUHSC's ongoing
publications and refusal to provide a meaningful name-clearing opportunity are concre
te, continuing, and irreparable absent injunctive relief.
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---
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ________________, 2025, at _____________________________, Texas.
---
**Kevin Norris Bass**
---
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EXHIBIT · OFFICIAL TRANSCRIPT
Texas Tech University Health Sciences Center
School of Medicine
Note on Medical School Grading
This transcript is from a pass/fail curriculum. Texas Tech University Health Sciences Center
School of Medicine uses the following grade designations rather than traditional letter grades:
· HO · Honors
· HP · High Pass
· PA · Pass
Numeric GPA fields are not used in this grading system and display as 0.000 by default. This
does not indicate failing grades or poor academic performance.
Key Information on This Transcript:
· Administrative Status: Administrative Dismissal Effective 01-11-2024
· Total Credit Hours: As shown on transcript
(See following pages for official transcript)
Exhibit 2 - Page 1 of 6
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TRANSCRIPTS
Kevin Bass v. TTUHSC
Exhibit 2 - Page 2 of 6
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Document88 Filed
Filed 12/08/25
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DateIsued:16-OCT-2025HSCGraduateProfesionalOfcl
Page 19
19 of 86
Page
Recordof:KevinNorisBas
ASUBJNO.COURSETITLECREDGRDPTSRC InstitutionInformationcontinued: Fal2015-LBKMedandGSBSMSCI6106BasicMedicalSpanish0.00PA.00MSCI6107GPinMulstisysDisorders&Can6.00HO.00MSCI6108IntegratedNeurosciences9.00HO.00 HRSEHRSQHRSQPTSGPACurent15.0015.000.00.00.00Cumulative50.0050.000.00.00.00 Spring2016-LBKMedandGSBSMSCI6103SystemDisordeMrsSICI7.60104HSOys.t0e0mDisordersI5.00HP.00MSCI6109P3/DOCS25.00PA.00 AHRSEHRSQHRSQPTSGPACurent17.0017.000.00.00.00Cumulative67.0067.000.00.00.00 Fal2016-LBKMedandGSBSLeaveofAbsenceEfective07-01-2016 Fal2023LubockMedicineMOBG7101OB/GYNJRClerkship8.00PA.00MPED7101PediatricJRClerkship8.00FA.00MPSY7101PsychiatryJRClerkship8.00PA.00 AHRSEHRSQHRSQPTSGPACurent24.0016.000.00.00.00Cumulative91.0083.000.00.00.00 **********CONTINUEDONPAGE2**********
PageID 80
80
PageID
AmandaMcSwen AmandaMcSween,Registrar
TexasTechUniversityHealthSciencesCenter SSN:[REDACTED] AHRSEHRSQHRSQPTSGPA AHRSEHRSQHRSQPTSGPA
[CurentName:KevinNorisBas REDACTED] Colege:ScholofMedicine SUBJNO.COURSETITLECREDGRDPTSRC IPMD5101InterprofColabPractice0.00PA.00MSCI5101ClinicalyOrientedAnatomy9.00PA.00MSCI5102BiologyofCelsandTisues6.00HO.00 Curent15.0015.000.00.00.00Cumulative15.0015.000.00.00.00 MSCI5103Structure&FunctMajOrganSy6.00HO.00MSCI5104HostDefense8.00HO.00MSCI5106P3/DOCS16.00PA.00 Curent20.0020.000.00.00.00Cumulative35.0035.000.00.00.00 ********CONTINUEDONNEXTCOLUMN********
IsuedTo:KEVINBASS Fal2014Medicine-Lubock Spring2015Medicine-Lubock
ThistranscriptprocesedanddeliveredbyParchment
Exhibit 2 - Page 3 of 6
OfficeoftheRegistrar,Lubock,Texas79430
DateofBirth:[REDACTED]
Major:Medicine
P
r
o
g
r
a
m
:
M
e
d
i
c
i
n
e
Page:1 CourseLevel:Medicine CurentProgramDoctorofMedicine INSTITUTIONCREDIT:
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HSCGraduateProfesionalOfcl
TexasTechUniversityHealthSciencesCenter
OficeoftheRegistrar,Lubbock,Texas79430
SN:[REDACTED]DateofBirth:[REDACTED]DateIsued:16-OCT-2025Recordof:KevinNorisBasPage:2 SUBJNO.COURSETITLECREDGRDPTSRC ***********TRANSCRIPTTOTALS************ *************ENDOFTRANSCRIPT**************
AmandaMcSween AmandaMcSwen,Registrar
Copy of Transcript
Level:Medicine
EAdministrativeDismisalEfective01-1-2024 hrs:83.00QGPtAs-:H0rs.0:0.00GPA:0.00Ehrs:0.00GQPAts-H:r0s.:0.00GPA:0.00Ehrs:83.00QGPAts-:H0rs.:0.00GPA:0.00
InstitutionInformationcontinued: Spring2024LubockMedicine
INSTITUTION TRANSFER OVERAL
Exhibit 2 - Page 4 of 6
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Thu, Oct 16, 2025 at 9:28 PM
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Gmail - You've Received A Document: [REDACTED]
[REDACTED]
M Gmail
Kevin Bass [REDACTED]
You've Received A Document: [REDACTED]
1 message
Parchment <noreply@mail.parchment.com>
Reply-To: noreply@mail.parchment.com
To: Kevin Bass [REDACTED]
You've received a Transcript
Texas Tech University Health Sciences Center has sent you a
Transcript with the Parchment Delivery ID (DID) [REDACTED] on
behalf of Kevin Bass. This Transcript is available for you to
download for 30 days, so your prompt attention is requested. The
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The Parchment Team
Exhibit 2 - Page 5 of 6
[REDACTED]
1/2
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Exhibit 2 - Page 6 of 6
2/2
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
Withheld: correspondence with another university
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Exhibit 4
Third-Party Defamatory Publications
Social media posts containing false and defamatory statements about Plaintiff's
dismissal from medical school.
Bass v. Texas Tech University Health Sciences Center
Exhibit '4'
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-SelectedThird-PartyPublications
|:--|:--|:--|:--|:--|
|Date|AuthorHandle|ContentSnipet|ClaimTags|Category|
|2025-08-1|ryanmarino.bsky.social|StatesthatPlaintifhadsexual-harasmentcomplaintsandhadmadethreatsofviolencebeforebeing'kickedout'ofmedicalschool;framesdismisalasunrelatedto'woke'politics.|Alegessexualharasmentandthreatsofviolence;claimshewaskickedout.|Expulsion/Dismisal| |2025-09-07|ryanmarino.bsky.social|DescribesPlaintiffasunemployedandnotaphysicianbecausehewas'kickedoutofmedscholforsexualharasmentandthreatsofphysicalviolence,'whilehighlightinganHSaccountretwet.|Alegessexualharasmentandthreatsofphysicalviolence;sayshe'snotaphysician;citesofficialamplification.|Expulsion/Dismisal| |2025-08-28|panaccindex.bsky.social|StatesthatPlaintiffwasexpeledfrommedicalscholforsexualmisconductandlabelshima'eugenicistcrep.'|Alegesexpulsionforsexualmisconduct;labelshima'eugenicistcrep'.|Expulsion/Dismissal| |2024-09-19|mementomorty.bsky.social|SaysPlaintifwaskickedoutofmedicalschol,calinghima'right-winggrifting[expletive]'and'crepytofemalenurses.'|Sayshewaskickedout;calshimcrepytofemalenurses.|Expulsion/Dismisal| |2025-04-30|panacindex.bsky.social|Claimscredit·'weareveryhapy'·forgetingPlaintifexpeledfrommedschool.|Takescreditforgettinghimexpeledfrommedicalschool.|Expulsion/Dismissal| |2025-10-02|quackdetector.bsky.social|StatesthatPlaintifwas'kickedoutofmedicalschol2yearsago'andaccuseshimof'cosplayingdoctor.'|Sayshewaskickedout;accuseshimof'cosplayingdoctor'.|Expulsion/Dismisal| |2025-08-04|panacindex.bsky.social|Says'Iamthereason'Plaintifwasexpeledfrommedicalschol.|Claims'Iamthereasonhewasexpeled'frommedschol.|Expulsion/Dismisal| |2023-05-15|mcbazacophd.bsky.social|SpeculatesthatPlaintifwantstogethimselfkickedoutofmedicalschoolsohecan'cashout'oncontroversy.|Acuseshimoftryingtogetkickedouttocashout.|Expulsion/Dismisal| |2025-02-13|blikethechese.bsky.social|ImputesharasmentofnursesinresponsetoPlaintif'sposts.|Imputesharasmentofnurses.|Misconduct(Sex/Threats)| |2025-09-13|panacindex.bsky.social|Saysthatafterbeingexpeledforsexualmisconductandbeingquote-twetedbyHS,Plaintifisnow'postingphysicalthreats'onsocialmedia.|Alegesexpulsionforsexualmisconductandpostingphysicalthreats.|Misconduct(Sex/Threats)| |2024-02-04|zapit.bsky.social|CalsPlaintifa'notoriousdisinformationpedler'and'dismisedmedicalstudent,'claimshe'gotkickedoutofschol,'andasertsheisonlyallowedoncampuswithapoliceescortduetothreats,saying'thescholmadeflyers.'|Saysscholonlyallowscampusaceswithpoliceescortduetothreats.|Expulsion/Dismisal| |2025-10-02|fuqekgs.medsky.social|References'therumorwhyhewasexpeledfrommedschol'incontextofalegeddoxingatempt.|Rumorcontext:'NOTKevinBAS'·referencesexpulsionrumor.|Expulsion/Dismisal|
Exhibit4-Page2of17
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Exhibit 4A - Reddit Evidence (H-37)
Evidence Metadata
Evidence Id: H-37
Platform: Reddit
Subreddit: r/medicine
Thread Title: Kevin Bass Discussion Thread
Canonical Url: https://www.reddit.com/r/medicine/comments/...
Capture Date: 2025-12-01
Description: Reddit thread containing defamatory statements about Plaintiff's medical school dismissal.
Chain of Custody
Captured and preserved using ArchiveWeb.page and replayed via WACZ/PDF with SHA-256 hashing. Canonical URLs and
hash values are maintained in a manifest and authenticated in the Digital Evidence Custodian declaration. All timestamps in
this [illegible] re UTC.
Exhibit 4 - Page 5 of 17 [illegible]
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MY SUBREDDITS · | POPULAR - ALL - USERS | ASKREDDIT - PICS - FUNNY - MOVIES - WORLDNEWS - NEWS - TODAYILEARNED - N MORE » Want to join? Log in or sign up in seconds
Medical School COMMENTS
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· Shitpost He had so many opportunities to just stop tweeting.
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"opinions"tovalidatetheirviewpoints others"whichputtheschoolonhighalert. Hewasonrotationandgotpuled. ·slytherinOMSDO2pointsThanksforthelaugh.Nededit.
Edit-Ijustgeneralthraetswithhistoryofharaksingresident(s)andanadtening.themaboutitagain.Somaybenotthreatstothescholbut Thisguysoundsunhingedandwhoknowshowmanypeoplenowlistentohis Hewassayingsomethingtotheefectof,"everyonewildie,somesoonerthan Waitwasheactualyastudentthereorjustpretendingtobe? OmgIcan'timaginethisguybeingonarotationwithme Justimaginehowgreatyourevalswouldbewhentheycomparedyouto
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· Desmitty9 DO-PGY3 226 points
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Medical School
One of my buddies matched at a residency program at Texas Tech. He actually told
me they got a vague email about not letting this student onto campus because of
threats he made on Twitter to the school.
Exhibit4-Page6of17^[ilegible]
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Thanks for the laugh. Needed it.
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I'm just now reading about all this and giggling. Fuuuuuuck this guy and his
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Exhibit 4 - Page 7 of 17
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Ex. H-37 ·
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Desmitty9 DO-PGY3 226 points
One of my buddies matched at a residency program at Texas Tech. He actually told
me they got a vague email about not letting this student onto campus because of
threats he made on Twitter to the school.
Edit - I just asked them about it again. So maybe not threats to the school but
general threats with a history of harassing resident(s) and an attending.
Ex. H-37 ·
Exhibit 4 - Page 9 of 17 [illegible]
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Exhibit 4B - Bluesky Evidence (H-50 Set)
Evidence Metadata
Evidence Set: H-50 (Bluesky Posts)
Platform: Bluesky
Capture Date: 2025-12-01
Posts Count: 3 posts (B2, B3, B12, B13)
Chain of Custody
Captured and preserved using ArchiveWeb.page and replayed via WACZ/PDF with SHA-256 hashing. Canonical URLs and
hash values are maintained in a manifest and authenticated in the Digital Evidence Custodian declaration. All timestamps in
this
re UTC.
Posts in This Set
H-50-B2
Handle: panaccindex.bsky.social
Date: 2025-08-04
Categories: Expulsion/Dismissal, Taking Credit
Content (sanitized): Says 'I am the reason' Plaintiff was expelled from medical school.
H-50-B12
Handle: ryanmarino.bsky.social
Date: 2025-09-07
Categories: Sexual Harassment, Threats of Violence, Not a Physician
Content (sanitized): Asserts that Plaintiff was 'kicked out of med school for sexual harassment and threats
of physical violence' and is not a physician, while highlighting an HHS account retweet.
H-50-B13
Handle: ryanmarino.bsky.social
Date: 2025-08-11
Categories: Sexual Harassment, Threats of Violence, Expulsion
Content (sanitized): States that Plaintiff had sexual-harassment complaints and had made threats of
violence before being 'kicked out' of medical school; frames dismissal as unrelated to 'woke' politics.
Exhibit 4 - Page 10 of 17 [illegible]
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Platform: Bluesky
Type: Bluesky Publication (Post)
Author: Zappit (@zappit.bsky.social)
Posted: February 04, 2024 at 00:04:15 UTC
URL: https://bsky.app/profile/zappit.bsky.social/post/3kkkgez2w2t2j
Engagement: 3 likes
Categories: Threats/Violence, Professional Incompetence, Police/Security, Institutional Pressure
Content Preview:
"Wow. Notorious disinformation peddler and now dismissed medical student Kevin Bass is not
only got kicked out of school and likely blew up his own career, but he's only allowed to set
foot on campus with a police escort due to threats he's made online and in person. The school
made flyers!"
Source File:
File: H-50-B3_fullpage.png
Type: PNG
Generated: 2025-12-08 00:35:56
Draft Exhibits - Publication/Defamation Stigma Claims
Exhibit 4 - Page 12 of 17 [illegible]
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[illegible]
Zep it
@[ilegible]
Wow.NotoriousdisinformationpedlerandnowdismisedmedicalstudentKevinBasisnotonlygotkickedoutofscholandlikelyblewuphisowncarer,buthe'sonlyalowedtosetfotoncampuswithapoliceescortduetothreatshe'smadeonlineandinperson.Thescholmadeflyers! [REDACTED] Exhibit4-Page13of17
[ilegible]
Case5:25-cv-00244-H-BV
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Filed12/08/25
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Platform: Bluesky
Type: Bluesky Publication (Post)
Author: Ryan Marino, MD (@ryanmarino.bsky.social)
Posted: September 07, 2025 at 06:10:19 UTC
URL: https://bsky.app/profile/ryanmarino.bsky.social/post/3ly7zqj7xvs2z
Engagement: 294 likes, 67 reposts
Categories: Threats/Violence, Sexual Misconduct, Professional Incompetence, Institutional Pressure
Content Preview:
"Here's our official Health & Human Services account retweeting an unemployed perverted
loser, who is not a physician because he was kicked out of med school for sexual harassment
and threats of physical violence, while he makes fun of a woman for the way she talks about
her own, very real, expertise"
Source File:
File: H-50-B12_fullpage.png
Type: PNG
Generated: 2025-12-08 00:35:56
Draft Exhibits - Publication/Defamation Stigma Claims
Exhibit 4 - Page 14 of 17
Case5:25-cv-00244-H-BV
5:25-cv-00244-H-BVDocument
Document
Filed12/08/25
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PageID106
106
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H[illegible] [ilegible] ere'souroficialHealth&HumanServicesacountretwetinganunemployedpervertedloser,whoisnotaphysicianbecausehewaskickedoutofmedscholforsexualharasmentandthreatsofphysicalviolence,whilehemakesfunofawomanforthewayshetalksaboutherown,veryreal,expertise KevinBasPhDMS talkingandlaughingabouthowshemadepolicydecisionsduring
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Exhibit4-Page15of17
Case 5:25-cv-00244-H-BV
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Filed 12/08/25
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of 86
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107
Platform: Bluesky
Type: Bluesky Publication (Quote Post)
Author: Ryan Marino, MD (@ryanmarino.bsky.social)
Posted: August 11, 2025 at 04:27:46 UTC
URL: https://bsky.app/profile/ryanmarino.bsky.social/post/3lw3xgbeaac2y
Engagement: 588 likes, 119 reposts
Categories: Threats/Violence, Sexual Misconduct, Professional Incompetence, Institutional Pressure
Content Preview:
"It's always the same story when they blame "woke." Kevin Bass received sexual harassment
complaints and had made threats of violence before he was kicked out of medical school. It
wasn't anything to do with his right-wing science denialism or his underlying scientific illiteracy
and pick-me behavior"
Source File:
File: H-50-B13_fullpage.png
Type: PNG
Generated: 2025-12-08 00:35:58
Draft Exhibits - Publication/Defamation Stigma Claims
Exhibit 4 - Page 16 of 17
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I[ilegible] t'salwaysthesamestorywhentheyblame"woke."KevinBassreceivedsexualharassmentcomplaintsandhadmadethreatsofviolencebeforehewaskickedoutofmedicalschol.Itwasn'tanythingtodowithhisright-wingsciencedenialismorhisunderlyingscientificiliteracyandpick-mebehavior.[illegible] Exhibit4-Page17of17
TARGETEXHIBIT
RyanMarino,MD [ilegible]
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Exhibit F
Exhibit F - Publication Crosswalk
Mapping of internal TTUHSC communications to external public statements, providing
evidence that officials leaked stigmatizing information.
(See following pages)
E
F
| --- | --- | --- | --- | --- |
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Exhibit F - Publication Crosswalk - Data Table
| Internal Source Date | Internal Phrase (exact quote) | External Appearance (where/when+URL) | Access-limited Insiders | Why Officials Are the Source |
|2023-12-27|"BoardunanimouslyrecommendsaNon-AcademicDismisalofDr.Bas forviolatingtheCodeofConduct,inaccordancewithPartII.G.2.g.Inad ition,theBoardunanimouslyrecom endsDr.Bas bede .. |Discordpostby@ModelAyshaMirzaon2024-01-0110:20AM:'wedidit,KevinBas'medicalcom itte votedtoexpelhim."PreservedasDiscord_ModelAyshaMirza_2024-01-01_Medical_Commite _Vote_to_Exp..|StudentConductBoard;InterimDean(SOM);StudentConductAdministrator;Dean'sdesigne s;OficeofGeneralCounsel;limitedSOMadministration.|Thedismisalrecom endationwasnon-publicandcirculatedtoasmalgroupon12/27/23.Within5days,apublicpostrepeatedthedistinctiveproceduralphrasing('medicalcom ite votedtoexpel..|
|2023-12-27|"BasedoninputfromtheThreatAssesmentTeam,SimonWilliams,PhD,SeniorAssociateDeanforAcademicAfairs,determinedthatDr.Bas'sbehaviorjustifiedhisemergencyremovalfromtheT UHSC..|Red it(r/medicalscho l)com ent:"abud yatTexasTechresidencyreceivedavagueemailaboutnotletingthestudentontocampusduetothreatsmadeonTwiter;uponfolow-up,clarifiedasgene..|ThreatAssessmentTeam;SeniorAssociateDean;Security/Police;StudentConductAdministrator;Dean'sOfice;GMEleadership;OficeofGeneralCounsel.|'Emergencyremoval'andThreatAssessmentTeaminvolvementareinsider-onlyterms.Thepubliccommentdescribesaresidency-wide'donotletontocampus'email,matchingthenon-publiccampus-restr..|
|2023-12-27|"Dr.Bas isallegedtohaveengagedinunprofes ionalconductduringhisPsychiatryclerkshife lingstowardsResidentA,aresidentinPsychiat|Red it(r/medicalscho l)com ent:"generalthreatswithahistoryofharas ingresident(s)andanattending."|PsychiatryClerkshipleadership;StudentConductAdministrator;StudentConductBoard;Dean'sOfice;OGC;interviewe sintheconductproces .|TheinternalalegationreferencesrepeatedcontactwithaPsychiatryresident;apublicpostechoes'harassingresidentsandanatending'shortlythereafter.Overlapinactorsandconduct,combin..|
|2024-01-0707:46(emailheaderlocaltime)|"weareonestudentlighterthanlastweek...ifanyonehasanyfurtherquestions,justcheckhisTwiter;Iamsurehewilupdateeveryone."(Mas broadcastfromAsistantViceDean,StudentAfai..|OficialStudentAfairsbroadcastemailitselfsentto'Classof2025Lub ockCOV'and'Clas of2024Lub ockCOV',c 'Jen iferWilson'.PreservedasExhibit_G_Forbes_Email_VACATION_and_other_stu..|AsistantViceDean,StudentAfairs(sender);StudentAfairslistowners;Clas lists;Pediatricsleadership(c).|Directoficialdisemination:StudentAfairsbroadcastthedismisalstatustotwoclas listsanddirectedrecipientstoPlaintif'sTwiter;systemshowsarecalrequest.Confirmsinstitutiona..|
Exhibit F ge 1 of 8
Case5:25-cv-00244-H-BV
5:25-cv-00244-H-BVDocument
Document
Filed12/08/25
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of 86
86 PageID
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50 of
PageID111
111
Exhibit F Crosswalk (Card Format, Clean)
Rows: 6 | Columns: 5
One row per page with wrapped text and generous spacing.
Continuation pages are added automatically for long rows.
Exhibit F | Page 2 of 8
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112
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Row 1 of 6
Internal Source Date:
2023-12-27
Internal Phrase (exact quote):
"Board unanimously recommends a Non-Academic Dismissal of Dr. Bass for violating the Code of Conduct, in accordance
with Part II.G.2.g. In addition, the Board unanimously recommends Dr. Bass be deemed unfit to continue the study of
medicine pursuant to Section 10 of the SOM OP 40.04 and dismissed from the SOM." (Determination Excerpts)
External Appearance (where/when+URL):
Discord post by @ModelAyshaMirza on 2024-01-01 10:20 AM: "we did it, Kevin Bass' medical committee voted to expel
him." Preserved as Discord_ModelAyshaMirza_2024-01-01_Medical_Committee_Vote_to_Expel.png/pdf.
Access-limited Insiders:
Student Conduct Board; Interim Dean (SOM); Student Conduct Administrator; Dean's designees; Office of General
Counsel; limited SOM administration.
Why Officials Are the Source (timing/unique language):
The dismissal recommendation was non-public and circulated to a small group on 12/27/23. Within 5 days, a public post
repeated the distinctive procedural phrasing ('medical committee voted to expel'), which mirrors the internal action and
would be known only to that limited circle at that time.
Exhibit F, Page 3 of 8
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Row 2 of 6
Internal Source Date:
2023-12-27
Internal Phrase (exact quote):
·BasedoninputfromtheThreatAsessmentTeam,SimonWiliams,PhD,SeniorAssociateDeanforAcademicAfairs,determinedthatDr.Bass'sbehaviorjustifiedhisemergencyremovalfromtheT UHSCcampusundertheCodeofConductbecause'thephysicaloremotionalwell-beingofastudentorothermembersoftheUniversitycom unitycouldbeendangeredorthepresenceofthestudentcouldsignificantlydisruptthenormaloperationsoftheuniversity.'·(DeterminationExcerpts)
External Appearance (where/when+URL):
Reddit (r/medicalscho l) comment: ·a bud y at Texas Tech residency received a vague email about not let ing the student onto campus due to threats made on Twit er; upon fol ow-up, clarified as general threats with a history of haras ing resident(s) and an at ending.·
Access-limited Insiders:
Threat Assessment Team; Senior Associate Dean; Security/Police; Student Conduct Administrator; Dean's Office; GME leadership; Office of General Counsel.
Why Officials Are the Source (timing/unique language):
·Emergency removal· and Threat Assessment Team involvement are insider-only terms. The public comment describes a residency-wide 'do not let onto campus' email, matching the non-public campus-restriction rationale and audience.
Exhibit F ge 4 of 6
Reddit (r/medicalschool) comment: "general threats with a history of harassing resident(s) and an attending."
Case
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53 of
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114
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Filed12/08/25
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Row 3 of 6
Internal Source Date:
2023-12-27
Internal Phrase (exact quote):
"Dr.Bassisalegedtohaveengagedinunprofes ionalconductduringhisPsychiatryclerkshipbyexpres ingromanticfe lingstowardsResidentA,whileDr.Bas andResidentAwereworkingtogetherandthenrefusingtorespectResidentA'slackofinterestbyrepeatedlycontactingResidentA."
External Appearance (where/when+URL):
Access-limited Insiders:
Psychiatry Clerkship leadership; Student Conduct Administrator; Student Conduct Board; Dean's Office; OGC; interviewees in the conduct process.
Why Officials Are the Source (timing/unique language):
The internal allegation references repeated contact with a Psychiatry resident; a public post echoes 'haras ing residents and an attending' shortly thereafter. Overlap in actors and conduct, combined with limited ac es , supports inference to of icials.
Exhibit F Page 5 of 8
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Filed12/08/25
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Row 4 of 6
Internal Source Date:
2024-01-07 07:46 (email header local time)
Internal Phrase (exact quote):
·we are one student lighter than last week · if anyone has any further questions, just check his Twitter; I am sure he will
update everyone.· (Mass broadcast from Assistant Vice Dean, Student Affairs, subject ·VACATION and other stuff·; recall
requested.)
External Appearance (where/when+URL):
Official Student Affairs broadcast email itself sent to 'Class of 2025 Lubbock COV' and 'Class of 2024 Lubbock COV', cc
'Jennifer Wilson'. Preserved as Exhibit_G_Forbes_Email_VACATION_and_other_stuff_Combined_v2.pdf.
Access-limited Insiders:
Assistant Vice Dean, Student Affairs (sender); Student Affairs list owners; Class lists; Pediatrics leadership (cc).
Why Officials Are the Source (timing/unique language):
Direct official dissemination: Student Affairs broadcast the dismissal status to two class lists and directed recipients to
Plaintiff·s Twitter; system shows a recall request. Confirms institutional publication and supports injunctive relief.
Exhibit E ge 6 of 8
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116
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Exhibit G
Exhibit G - January 7, 2024 Forbes Email (VACATION and
other stuff)
Class-wide broadcast from Assistant Vice Dean stating 'we are one student
lighter' and directing recipients to 'check his Twitter.'
(See following pages)
E G
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Forbes, Rachel would like to recall the message, "VACATION and other stuff".
Forbes, Rachel
Reply all
Sun 1/7/2024 7:46 AM
To Class of 2025 Lubbock COV; Class of 2024 Lubbock COV
Cc Wilson, Jennifer E
Action Items
Good Morning,
As many of you know, I am heading out on a much-needed vacation, but I realized that I had not updated many of you
on a few things, so here are all the things.
First, I am sure everyone is aware by now, but we are one student lighter than last week, and I hope we can all
breathe a sigh of relief. Obviously, this has been trying on us all, and I want to thank everyone who stopped by, texted,
and called to check in on me·I can honestly say that this past year has been the most difficult of my career thus far (I
sure hope I do not have another year like that again). If anyone has any further questions, just check his Twitter; I am
sure he will update everyone.
Second, as of December 1st, Dr. Nunez is no longer the Assistant Vice Dean on our campus. While I appreciated his
tenure, I am extremely excited to announce Dr. Jennifer Wilson has replaced him!! She has already been digging in
and I know she will be a huge asset to me and each of you. Her office hours will vary until she transitions out of the
million shifts she covers at the hospital but she is always available via cell or email. She will remain as the Pediatrics
Clerkship Director, and she is a City of Lubbock Councilwoman, so she is very busy but very organized. Please
congratulate her and exciting things to come!
MS3's
I trust everyone is overwhelmed with figuring out your MS4 schedule and what you want to do with your life·take a
deep breath and hang on. It will only get rougher, BUT you know we are walking this together! If you have not signed
up to have your meeting with Christina or me, then you need to ASAP. I know many of you are still undecided on your
career path, but that is OK. Listen to Christina; she has done a few rodeos and will provide you with guidance on how
to move forward if you are unsure. I will see each of you when I get back.
MS4's
I know many of you are either finished or finishing your residency interviews·YAY! We have a meeting scheduled
delivered via Dr Cobbs and I usually have a small one for just us; I have not scheduled that yet but I will soon If
Mint
0:33
58%
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<
All
Inboxes
Siri Found a Contact
Forbes Rachel Add
rachel.forbes@ttuhsc.edu
FR Forbes Rachel Sunday
To: Class, Class Cc: Jennifer >
VACATION and other stuff
Good Morning,
As many of you know, I am heading out on a
much-needed vacation, but I realized that I had
not updated many of you on a few things, so
here are all the things.
First, I am sure everyone is aware by now, but
we are one student lighter than last week, and I
hope we can all breathe a sigh of relief.
Obviously, this has been trying on us all, and I
want to thank everyone who stopped by, texted,
and called to check in on me·I can honestly say
that this past year has been the most difficult of
my career thus far (I sure hope I do not have
another year like that again). If anyone has any
further questions, just check his Twitter; I am
sure he will update everyone.
Exhibit C - Page 2 of 4
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< All Inboxes VACATION an... · ·
Second, as of December 1··, Dr. Nunez is no
longer the Assistant Vice Dean on our campus.
While I appreciated his tenure, I am extremely
excited to announce Dr. Jennifer Wilson has
replaced him!! She has already been digging in
and I know she will be a huge asset to me and
each of you. Her office hours will vary until she
transitions out of the million shifts she covers at
the hospital but she is always available via cell or
email. She will remain as the Pediatrics
Clerkship Director, and she is a City of Lubbock
Councilwoman, so she is very busy but very
organized. Please congratulate her and exciting
things to come!
MS3's
I trust everyone is overwhelmed with figuring out
your MS4 schedule and what you want to do with
your life·take a deep breath and hang on. It will
only get rougher, BUT you know we are walking
this together! If you have not signed up to have
your meeting with Christina or me, then you need
to ASAP. I know many of you are still undecided
on your career path, but that is OK. Listen to
Christina; she has done a few rodeos and will
provide you with guidance on how to move
forward if you are unsure. I will see each of you
when I get back.
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Exhibit 5
ADA / Section 504 Documentation
Neuropsychological evaluation summary, ADA notice to TTUHSC, and disability
accommodation policies.
Bass v. Texas Tech University Health Sciences Center
Exhibit '5' [illegible]
Withheld: medical information
Withheld: medical information
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- ADA Notice & Hearing Quotes (D-1, D-2)
· Hearing Statements (ADA/§504 & SDS Process)
Source: Notes + firsthand recollection of statements made during the hearing on December 11, 2023. I do not
possess the official audio or transcript. If and when the University produces the official record, I will conform
page/line or timestamps.
Purpose: Show (i) ADA routing to SDS; (ii) redaction of disability evidence; (iii) exclusion of a disability witness;
(iv) limits on questioning (written-only via presider); and (v) statements by University-affiliated personnel. These
points support my requested guardrails (neutral presider, 7-day exchanges, time parity, recording) and
admission of disability evidence (unredacted evaluation under protective order; neuropsychologist testimony).
SDS is the official ADA channel
I recall the Chair stated: "Our process is normally to go through Student Disability Services; that office makes
these decisions."
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
ADA request "no attachment" comment
I recall the Chair stated: "I have not seen that... you emailed me an email that does not have an attachment."
[Notice: SDS received the evaluation on Friday (Ex. D-1).]
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
Breaks/snacks offered; no communication/process accommodations
I recall the Chair stated: "We have water in the room... there are snacks... if you need any breaks, please ask."
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
No active attorney questioning (written questions only)
I recall the Chair stated: "Advisors cannot ask questions of witnesses directly... you may provide questions in
writing to me." [See Hearing Rules (Ex. D-3).]
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
Neuropsych evaluation withheld/redacted
I recall the Chair stated: "A redacted portion of the healthcare provider's document will be provided to the panel
before deliberations." [See also Determination excerpts (Ex. B).]
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
Neuropsychologist testimony excluded
I recall the Chair ruled: "I'm not going to allow that testimony."
Speaker: Hearing Officer/Chair
Session: Day 1 · Morning
Exhibit 5 - Page 4 of 12
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Context · Statements by University-affiliated personnel
I recall the Professionalism Coach said: ·[Psychologist] you are probabl
; you lack political
intelligence about how your behaviors and words impact others.·
Speaker: Professionalism Coach
Session: Day 1 · Afternoon
Authentication request: If any wording is disputed, please produce the official audio/stenographic record or
written transcript within 3 business days, and I will conform page/line.
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- Student Disability Services Policy &
Technical Standards
TTUHSC policies governing ADA/Section 504 accommodations and medical school
technical standards.
Only those pages directly addressing ADA/§504 accommodations and technical-standards
expectations are included here.
(See following pages)
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TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER
Operating Policy and Procedure
HSC OP: 77.14, Establishing Reasonable Accommodations for Students with Disabilities
PURPOSE: The purpose of this Health Sciences Center Operating Policy and Procedure (HSC OP) is to outline the procedures for establishing reasonable accommodation for students with disabilities.
REVIEW:ThisHSCOPwil bereviewedbyNovember1ofeven-numberedyears(ENY)bytheOficeofGeneralCounselandtheDirectorofStudentDisabilityServices,withrecom endationsforrevisionforwardedtotheAs ociateProvostforStudentAfairsbyDecember1.
POLICY/PROCEDURE:
1. Background
a.TheAmericanswithDisabilitiesAct(ADA)of190(42U.S.C.§12101etseq.,asamended)mandatesequaloportunitiesforpersonswithdisabilitiesinallpublicfacilities,programs,activities,services,andbenefitsderivedfromthem.TitleV,Section504oftheRehabilitationActof1973(29U.S.C.§794etseq.),asamended,mandatesequaloportunityforqualifiedpersonswithdisabilitiesinalprograms,activities,andservicesofrecipientsoffederalfinancialasistance.BothADAandSection504oftheRehabilitationActarecivilrightsstatutesthatprohibitdiscriminationonthebasisofdisability,ifaplicable,obligatecolegesanduniversitiestomakecertainadjustmentsandacomodationsandoffertopersonswithdisabilitiestheoportunitytoparticipatefulyinalinstitutionalprogramsandactivities.TexasTechUniversityHealthSciencesCenter(TTUHSC)adherestotheselawsandregulationsaswelastheTexasComisiononHumanRightsAct.
2. Faculty Notice
a. Faculty members are encouraged to insert the following statement into each course syllabus:
Anystudentwho,becauseofadisability,mayrequirespecialarangementsinordertometcourserequirementsshouldpresentaLeterofAcomodationfromStudentDisabilityServicestothecourseinstructor(orprogramdirector).PleasenotethatinstructorsarenotalowedtoprovideclasroomacomodationtoastudentwithoutapropriateverificationfromStudentDisabilityServices.Foradditionalinformation,pleasecontactlityServicesinAcademicClasromBuilding2C400(Lubock),bytelephone[redactedphone],orbyemaildisabilityservices@tuhsc.edu.
3. Eligibility and Procedures for Establishing Reasonable Accommodations
a. A student must register with Student Disability Services and file appropriate documentation in order to be eligible for any disability benefits and services described in this operating policy.
b. The university-approved mechanism for establishing reasonable accommodation is writ en notification in the form of a Let er of Accommodation (LOA) from the Student Disability Services.
TheLOAindicatestofacultythatthestudenthasprovidedprofoftheirdisabilityandthattheacommodationnotedisconsideredapropriateandreasonable.AcommodationsareconsideredreasonableaspairedwiththeesentialfunctionsineachprogramandstudentsshouldbeawareofthespecificnatureofthecuriculumwithinthevariousscholsatTUHSC.Nofurtherprofofdisabilityshouldberequiredofthestudent.StudentspresentingotherkindsofverificationshouldbereferedtotheStudentDisabilityServicesfortheapropriateidentification.
HSC OP 77.14
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No requirement exists that accommodation be made prior to completion of the approved university
process. Classroom accommodations should be implemented within 1 week (5 business days) of
the student and faculty discussing implementation.
c. A list of service providers that conduct assessments, render diagnoses, and make
recommendations for accommodations for students can be found on the Student Disability
Services website or requested from the staff. Student Disability Services at TTUHSC does not
endorse any particular service provider. Addresses and phone numbers are subject to change.
Before selecting a qualified professional, ask what their
have working with adults with learning disabilities and/or
have worked with Student Disability Services at TTUHS
ience they
and if they
y want to
provide them the Documentation Guidelines found on the Student Disability Services website.
After the assessment has been completed, request a written copy as well as make an
appointment to discuss the results and recommendations with the professional. Be sure to
request additional resources if needed, and always keep a personal copy for your records.
In order to obtain accommodations at TTUHSC, a copy of the report (documentation) along with
an application, should be provided to the Student Disability Services. Please allow up to two
weeks to process a complete file.
d. Faculty members are not required to provide accommodation for a student's disability needs
unless the student provides a Letter of Accommodation from Student Disability Services. Ideally,
Letters of Accommodation should be presented to instructors at the beginning of the semester;
however, Letters of Accommodation may be submitted at any point during a semester. If an LOA
is presented after a semester begins, the accommodation applies only from the date the LOA is
presented to the faculty member. If the accommodation(s) are not implemented within 1 week (5
business days), the student shall immediately contact the Student Disability Services.
e. Student Rights and Responsibilities is a document discussed with each student during the initial
intake meeting. The Rights and Responsibilities document details the student's right to choose to
use accommodations, the right to request adjustments at any time, and the right to have
accommodations provided to them free of charge. This document also outlines the student's
responsibility to follow the Code of Conduct regardless of disability, the responsibility to discuss
accommodations with faculty in order to implement said accommodations, the responsibility to
report any issues with accommodations back to Student Disability Services during the semester in
which the issue arises, and the responsibility to request a Letter of Accommodation for each
semester enrolled.
f. Student Disability Services will maintain the confidentiality of all medical and ADA information
concerning students. These records will be kept separate from personnel files and student
educational records, and will be accessible only to authorized personnel.
g. Temporary accommodations are extended to students with temporary disabilities only for the
duration of their functional limitations associated with their disability.
The eligibility process is the same for a temporary disability as it is for a permanent disability. After
reviewing documentation, Student Disability Services will determine appropriate accommodations
dependent on temporary limitations the student has in the academic setting. Student Disability
Services may also grant temporary services to a student who is working to obtain relevant
documentation. Student Disability Services will review their file at the end of each semester in
order to seek appropriate documentation or to substantiate further need for services.
4. Appeals Process for Denial of Services or Accommodations
Students who are denied services or denied a specific accommodation request by Student Disability
Services may appeal the decision to the Associate Provost for Student Affairs. The decision of the
Associate Provost for Student Affairs is the final ruling.
5. Right to Change Policy
TTUHSC reserves the right to interpret, change, modify, amend or rescind this policy in whole or in part at
any time without the consent of employees, faculty or students.
HSC OP 77.14
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TEXAS TECH UNIVERSITY
HEALTH SCIENCES CENTER·
School of Medicine
Operating Policy and Procedure
SOM OP: 40.11 Technical Standards for Admission, Retention, and Graduation
PURPOSE: The purpose of this School of Medicine (SOM) Operating Policy is to explain the
nonacademic standards of the SOM.
REVIEW: This SOM Operating Policy will be reviewed each odd-numbered fiscal year by the
Curriculum and Educational Policy Committee. Revisions will be forwarded to the
Office of the Dean for approval and publication.
POLICY/PROCEDURE:
1. General. The School of Medicine faculty has developed minimum standards for entry into and
progression through the medical curriculum. These standards provide guidance to achieve the
Doctor of Medicine degree in preparation for licensure as a practicing physician and for
postgraduate training. Throughout the medical education process, patient safety is of primary
consideration.
LCME Element 10.5: Technical Standards
A medical school develops and publishes technical standards for the admission, retention, and
graduation of applicants or medical students in accordance with legal requirements.
2. Definition:
· The term technical standards refers to all nonacademic requirements a medical school
applicant or enrolled medical student must possess or be able to acquire, with or without
reasonable accommodation, in order to be admitted to, be retained in, and graduate from
any SOM program.
· The term student refers to all medical school applicants or enrolled medical students of any
SOM program.
3. Technical Standards:
a. As a component of the Texas Tech University Health Sciences Center (TTUHSC), the SOM
is committed to equal educational opportunity and nondiscrimination consistent with
HSC OP 77.14.
b. Because graduation with an M.D. degree signifies the recipient is a physician prepared for
entry into the practice of medicine within the U.S. graduate medical education and licensure
framework, students in any of the SOM M.D. degree programs are expected to acquire a
broad foundation of medical knowledge and skills that generally supports and facilitates this
progression. According to the LCME, technical standards for admission, retention, and
graduation of applicants or medical students are 1) essential academic and non-academic
abilities, attributes, and characteristics in the areas of intellectual-conceptual, integrative, and
quantitative abilities; 2) observational skills; 3) physical abilities; 4) motor functioning; 5)
emotional stability; 6) behavioral and social skills; and 7) ethics and professionalism that a
medical school applicant or enrolled medical student must possess or be able to acquire, with
or without reasonable accommodation, in order to be admitted to, be retained in, and
graduate from that school's medical educational program (Element 10.5). In addition, as
students interact with patients throughout their medical education program, the SOM has an
ethical responsibility for the safety of the patients with whom students and graduates will
come in contact. Patient safety and well-being are, therefore, major factors in establishing
SOM OP 40.11
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nonacademic requirements for admission, promotion, and graduation. As such, all students
must meet or acquire certain technical standards with or without reasonable accommodations
(Standard 10: Medical Student Selection, Assignment, and Progress; LCME, April 2022):
· Observational skills: A student must be able to demonstrate functional use of sensory
systems, including vision, hearing, touch, and smell to be able to obtain a medical
history and perform a complete physical examination in order to integrate findings
based on these observations and to develop an appropriate diagnostic and treatment
plan.
· Communication: Students should be able to communicate with patients, their
families, colleagues, and all members of the health care team in order to elicit
information, to detect changes in mood and activity, and to establish a therapeutic
relationship. Students should be able to communicate via English effectively and
sensitively with patients and all members of the health care team both in person and
in writing.
· Intellectual-conceptual, integrative, and quantitative abilities: A student must be able
to problem-solve effectively and rapidly, learn, reason, calculate, formulate and test
hypotheses, memorize, process, analyze, rapidly integrate and synthesize
information and apply information in an environment of high stress and distraction. A
student must be able to make critical judgments based on evidence and experience.
· Examination, Diagnostic, and Procedural Skills: Candidates must possess the
capacity to perform all medical and diagnostic procedures considered essential for
the area of practice, including physical examinations and diagnostic maneuvers.
They must be able to respond to emergent or urgent situations in a timely manner
and provide general and emergency care. They must adhere to universal precaution
measures and meet safety standards applicable to inpatient and outpatient settings
and other clinical activities.
· Behavioral and social skills: Students should possess the emotional health required
for full utilization of their intellectual abilities, the exercise of good judgement, the
prompt completion of all responsibility's attendant to the diagnosis and care of
patients, and the development of mature, sensitive, and effective relationships with
patients, fellow students, faculty and staff. Students should be able to tolerate
physically taxing workloads and to function effectively under stress. They should be
able to adapt to changing environments, to display flexibility, and to learn to function
in the face of uncertainties inherent in the clinical problems of many patients.
Compassion, integrity, concern for others, interpersonal skills, professionalism,
interest, and motivation are all personal qualities that are expected during the
education processes.
· Ethics and professionalism: A student must exercise professional judgment and
promptly complete all responsibilities attendant to their academic work, teamwork,
and patient care. A student must respond appropriately and professionally under
stressful situations, and maintain safe practice and sound clinical judgement. A
student must accept formative feedback from others, and take personal responsibility
for making appropriate positive changes. A student must demonstrate compassion
and respect for human dignity and rights and safeguard patient confidences and
privacy in accordance with HIPAA. A student should disseminate medical information
that provides benefit to the patient first, without allowing competing considerations,
beliefs or interests to take precedence.
4. Acceptance of Technical Standards
a. If a candidate accepts an offer of admission, the candidate must then sign a form
acknowledging that they have read this policy and that they are aware that the program's
technical standards must be met with or without reasonable accommodation.
SOM OP 40.11
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b. All students must re-confirm their understanding of the expectations of this policy prior to
beginning clinical rotations in Phase 2 of the curriculum.
5. Requests for Accommodations
a. Requests for accommodation(s) must be submitted to the TTUHSC Student Disability
Services. Requests for accommodations may be submitted at any point during a semester,
including requests by students related to disabilities identified and/or acquired following
matriculation. Requests are otherwise evaluated and managed according to HSC OP 77.14.
b. Requests for accommodation by external organizations (such as, but not limited to, the
National Board of Medical Examiners) for any exams or assessments administered under
their auspices are independent and additional processes for which the school is not
responsible. Such requests, and any related expenses, are the responsibility of the student,
and the TTUHSC Student Disability Services will support the student in the process.
SOM OP 40.11
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Technical Standards for Admission, Retention, and Graduation
I certify that I have read and that I understand the Technical Standards for Admission, Retention, and
Graduation.
I understand that I can meet the standards with or without reasonable accommodation.
I understand that I can request in writing any desired accommodation in order to meet these standards,
including accommodation for a physical or mental impairment that substantially limits one or more
major life activities, and must follow any specified procedures for evaluation in order to be considered
for and receive accommodation (Student Disability Services).
I understand that while requests for accommodations may be submitted at any point during a semester,
including requests related to disabilities identified and/or acquired following matriculation, they must
be submitted in a timely manner to allow time to adequately coordinate accommodation services.
Signature
Printed Name
Date
This form will be completed online
SOM OP 40.11
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Exhibit 6
Name-Clearing Evidence
Documentation supporting Plaintiff's request for a name-clearing hearing.
Bass v. Texas Tech University Health Sciences Center
Case No. 5:25-cv-00028-H
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10/29/25, 1:26 PM Gmail - Request for Name-Clearing Hearing, Interim Transcript Relief, ADA/Section 504 Accommodations, and Preservation
Gmail Kevin Bass <kbassphiladelphia@gmail.com>
reputation,training,andcareer. adresesthepublicstatements. broad,stigmatizingdisemination.
ExhibitF,Rows5·6andpreservedscrenshots).
Request for Name-Clearing Hearing, Interim Transcript Relief, ADA/Section 504
Accommodations, and Preservation
WSomealegationswereairedduringinternalprocedingsandthenrepeatedpublicly,evenwhennotreflectedinafinaldecisionleter.Thesestatementsarefalseandcontinuetocauseongoingharmtomy hyaseparatename-clearinghearingisrequired.Theearlierstudent-conductprocedingdidnotprovideameaningfuloportunitytoclearmynameregardingthestigmatizingstatementslaterdiseminated:acomodationsweretreatedas"outsidethescope"despiteADAnoticetoSDS,keydefensewitneseswerenotpermited,andcros-examinationwascurtailed(Ex.B;Ex.D-1/D-2).Inparticular,thehearingoficeradmitedmyneuropsychologicalevaluationbutredactedtheacomodationssectionasnotwithintheBoard'sscope,andtheBoardstatedthediagnosiswasnotabasisforretroactiveleniencyandclaimeditwasnotdiscloseduntilthemorningofthehearing·contrarytomyDecember8,2023ADAnotice(Ex.B;Ex.D-1).Aname-clearinghearingisdistinctandnarowly Publicrepetitionunderscoresurgency.Withindaysofthenon-publicomiteaction,twopublic/oficialpublicationscirculated:(i)onJanuary1,2024,apublicpoststatedthatmymedicalcomitevotedtoexpelme(seExhibitF,Row1),and(i)onJanuary7,2024at7:46a.m.,theAsistantViceDeanforStudentAfairssentaclass-widebroadcaststating"weareonestudentlighterthanlastwek"andinstructingrecipientsto"checkhisTwiter"forupdates;thesystemshowsarecalrequestforthatmesage(ExhibitG).Inthesameperiod,ExhibitF(Rows2·4)documentsresidency/GMEmesagingthatdescribedcampus-acesrestrictions(e.g.,donotlet[student]ontocampus,"BOLO,"sitebans,"rotationpuled")andinsiderphrasingabout"harasingresident(s)andanatending,"confirming Continuedreuse.Publicreuseofinsiderphrasing·includingAugust2025postsrepeating"sexualharasmentcomplaints,""threatsofviolence,"and"sexualmisconduct"·continuesasofOctober2025(see Practical,ongoingharm.Iampresentlypursuingprofesionalandfundingoportunitieswherereputationandoficialacademicrecords
Kevin Bass <kbassphiladelphia@gmail.com> Sun, Oct 19, 2025 at 2:35 AM
Reply-To: kbassphiladelphia@gmail.com
To: registrar@ttuhsc.edu, disabilityservices@ttuhsc.edu, eric.bentley@ttu.edu, John.DeToledo@ttuhsc.edu,
somosa@ttuhsc.edu, LubbockGME@ttuhsc.edu
Cc: rachel.forbes@ttuhsc.edu, lauren.cobbs@ttuhsc.edu
Bcc: [personal recipient] , Kevin Bass <kbassphiladelphia@gmail.com>
Please reply 'Received'.
Dear Officials,
I request a NAME-CLEARING HEARING to address stigmatizing statements
the University made and disseminated in connection with my dismissal.
Exhibit 6 - Page 3 of 9
Gmail web view URL (omitted from public filing).
transcripts or equivalent educational documentation. Because my TTUHSC
records currently reflect a dismissal notation and the circumstances
are public, this impairs my ability to secure such opportunities and
constitutes ongoing, concrete harm. For example, in April 2024 I was
required to transmit an unofficial transcript that displayed a
dismissal notation in an application process (Exhibits C-4 and C-5;
and H-1/H-2/H-3). The need for immediate transcript relief (clean
transcript/no re-imposition and corrective notices) is therefore
10/29/25, 1:26 PM Gmail - Request for Name-Clearing Hearing, Interim Transcript Relief, ADA/Section 504 Accommodations, and Preservation
continuing and non-speculative.
REQUEST
Please confirm by Tuesday, October 21, 2025, 5:00 p.m. Central Time
(CT) that you will convene a name-clearing hearing within 14 days with
these minimum features:
Neutral presider. Independent and not previously involved.
Seven-day advance notice of the specific statements and evidence to be
addressed; the University's notice will identify each challenged
statement verbatim, the speaker, date/time, audience/channel (e.g.,
class broadcast, listserv, media), and the documents the University
will rely on.
Mutual, simultaneous exchange of exhibits and witness lists (with
brief summaries) seven (7) days in advance; no undisclosed evidence
absent good cause and presider approval.
Time parity and order. Equal total time for each side; scheduled
breaks; no stacking many hours of adverse witnesses before my
presentation; a neutral presider will manage turn-taking and questions
(live questioning or written questions via the presider).
Complete record. Either the University provides audio or a court
reporter; or I may retain a certified court reporter at my expense.
Written findings issued within seven (7) days and suitable for public
release with necessary redactions.
No retaliation for requesting or participating in the hearing.
Confidentiality and privacy. I agree to reasonable confidentiality
protections for third-party PII/PHI and to redactions required by
FERPA/health privacy. I will not agree to any restriction that
prevents me from sharing my own statements, my redacted exhibits, the
final written findings, or submitting the record to a
court/regulator/law-enforcement. If broader confidentiality is needed,
please propose a narrow protective order with those carve-outs. No NDA
or release of claims will be required as a condition of receiving the
hearing.
One-time extension (conditions; no tolling). If you need a brief
extension, I can agree to a one-time extension of the response
deadline to Friday, October 31, 2025 at 5:00 p.m. CT, only if by the
current deadline (Tuesday, October 21, 2025) you confirm in writing:
(i) the neutral presider (not previously involved); (ii) a hearing
date to occur between November 4?11, 2025; (iii) mutual, simultaneous
7-day advance exchanges; (iv) time parity with scheduled breaks and no
stacking; (v) a complete record (University audio or a court reporter,
or I may retain a reporter at my expense); and (vi) the interim
transcript relief below. This extension does not waive, toll, or
extend any statute of limitations or other rights; I expressly reserve
the right to file suit on or before Tuesday, November 4, 2025.
Exhibit 6 - Page 4 of 9
Gmail web view URL (omitted from public filing).
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of the stigmatizing statements to third parties (including students,
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10/29/25, 1:26 PM Gmail - Request for Name-Clearing Hearing, Interim Transcript Relief, ADA/Section 504 Accommodations, and Preservation
(a) Transcript relief. Issue an official transcript without any
disciplinary notation/hold and confirm in writing: no re-imposition
absent lawful process; production of the audit log of notation history
(codes; applied/removed dates); and the list of prior recipients of
any transcript reflecting a notation/hold so that corrective
transcripts or notices can be issued after the hearing if appropriate.
(b) Dissemination pause. Refrain from any non-required dissemination
donors, media, and external programs) until the hearing is complete
and written findings are issued; provide advance notice of any legally
required disclosure.
(c) Recipient identification. Identify recipients who previously
received any transcript containing a notation/hold, and (after the
hearing) cooperate in issuing corrective notices where appropriate.
ADA / SECTION 504
It recommended
standard accommodations (e.g., equal time, scheduled breaks, written
questions). (See Exhibit A: functional-limitations and recommendations
excerpt.) The University already has the full evaluation.
Requested accommodations for the hearing: equal presentation time;
scheduled breaks for 10 minutes every 30 minutes; neutral presider
managing turn-taking; seven-day exhibit/witness exchange; ability to
submit written questions; real-time captioning (CART) if needed;
permission to consult notes; no stacking many hours of adverse
witnesses before my presentation; and an option to participate
remotely if required.
SDS parallel process. Any SDS intake or updated evaluation may proceed
in parallel and will not delay the hearing.
PRESERVATION
Please take immediate steps to preserve all potentially relevant
information, including: (i) Residency/GME broadcasts and listserv
messages; (ii) Security/Police or Threat Assessment Team
communications (including any BOLO, no-trespass, or campus-access
restrictions); (iii) Rotation/site communications (including Covenant
Health communications); (iv) Student Affairs mass broadcasts to
classes, including the message titled "VACATION and other stuff" sent
on 2024-01-07 at 7:46 a.m., its drafts and approvals, the distribution
lists used, and any recall/replace logs or metadata; (v) Registrar
transcript/notation audit logs and policies; and (vi) any
communications to third parties (programs, hospitals, donors, media)
that convey stigmatizing statements about me.
IDENTIFICATION (non-discovery; for planning)
(1) Identify the official (name/title) who can schedule/order the
hearing; (2) provide the transcript/notation history (codes;
applied/removed dates); and (3) provide a list of recipients who
previously received transcripts reflecting a notation/hold.
Please confirm receipt and provide a written response by Tuesday,
October 21, 2025, 5:00 p.m. CT so that a hearing can be scheduled
promptly. This request is made without waiving any rights, claims, or
defenses. I remain willing to cooperate in good faith to finalize
procedures and accommodations that ensure an effective opportunity to
Exhibit 6 - Page 5 of 9 [illegible]
Gmail web view URL (omitted from public filing).
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Sincerely,
Kevin Bass
[redacted phone]
17 attachments
Exhibit_A_Excerpt_Dx_Functional_Accommodations.txt
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Exhibit_B_Excerpt_Rules_Time_Scope.txt
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Exhibit_C-2_Transcript_2025-10-16.pdf
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Exhibit_C-3_Transcript_Portal_Status_2025-10-16.pdf
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Exhibit_D-1_Americans_with_Disabilities_Act_Notice_Email_2023-12-08.pdf
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Exhibit_D-2_Hearing_Quotes.txt
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Exhibit_E_Student_Disability_Services_Policy.pdf
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Exhibit_E_Technical_Standards.pdf
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Exhibit_F_Crosswalk_Publication_Proof_FINAL_v3.csv
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Exhibit_G_Forbes_Email_VACATION_and_other_stuff_Combined_v2.pdf
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Exhibit_C-4_SOM_Transcript_Admin_Dismissal_2024-01-11.pdf
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Exhibit_C-5_GSBS_Transcript_Issued_2024-04-12.pdf
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Exhibit_H-1_SMUSOM_Admission_Requirements_Transcript_Requirement.pdf
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Exhibit_H-2_SMUSOM_We_Can_Use_Unofficial_Transcripts_2024-04-11 - Copy.pdf
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Exhibit_H-3_SMUSOM_Email_Transcripts_Received_2024-04-12.pdf
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Exhibit_F_Crosswalk_CardFormat_v2.pdf
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Exhibit 6 - Page 6 of 9
Gmail web view URL (omitted from public filing).
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10/29/25, 1:26 PM Gmail - Receipt confirmation · Name-Clearing Hearing Request (Oct 19, 2025)
Gmail Kevin Bass <kbassphiladelphia@gmail.com>
Receipt confirmation · Name-Clearing Hearing Request (Oct 19, 2025)
Kevin Bass <kbassphiladelphia@gmail.com> Mon, Oct 20, 2025 at 8:00 AM
Reply-To: kbassphiladelphia@gmail.com
To: eric.bentley@ttu.edu, registrar@ttuhsc.edu, somosa@ttuhsc.edu
Requestandidentifytheoficialwhowillscheduleandmanagethe
Bcc: disabilityservices@ttuhsc.edu
Hello,
Please confirm receipt of my Oct 19, 2025 Name-Clearing Hearing
hearing procedure.
Kindly provide the next step and a timeline. I preserve all rights.
Thank you,
Kevin Bass PhD MS
Phone: [redacted phone]
Exhibit 6 - Page 7 of 9 [illegible]
Gmail web view URL (omitted from public filing).
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10/29/25, 1:26 PM Gmail - Receipt & Scheduling Contact · Name-Clearing Hearing (Kevin Bass)
Gmail Kevin Bass <kbassphiladelphia@gmail.com>
Receipt & Scheduling Contact · Name-Clearing Hearing (Kevin Bass)
Kevin Bass <kbassphiladelphia@gmail.com> Mon, Oct 20, 2025 at 8:00 AM
Reply-To: kbassphiladelphia@gmail.com
To: registrar@ttuhsc.edu, disabilityservices@ttuhsc.edu, eric.bentley@ttu.edu, somosa@ttuhsc.edu,
LubbockGME@ttuhsc.edu
Hello all. Please confirm receipt of my Oct 19 request and identify
the official who can schedule the name-clearing hearing and finalize
procedures (including ADA accommodations) by Tue, Oct 21, 2025, 5:00
p.m. CT. Thank you. Kevin
Exhibit 6 - Page 8 of 9
Gmail web view URL (omitted from public filing).
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10/29/25, 1:27 PM Gmail - Name-Clearing Hearing · 10/21/2025 deadline lapsed; schedule now
M Gmail Kevin Bass <kbassphiladelphia@gmail.com>
Name-Clearing Hearing · 10/21/2025 deadline lapsed; schedule now
Kevin Bass <kbassphiladelphia@gmail.com> Wed, Oct 22, 2025 at 8:00 AM
Reply-To: kbassphiladelphia@gmail.com
To: registrar@ttuhsc.edu
Cc: eric.bentley@ttu.edu, disabilityservices@ttuhsc.edu
Note: This follows my 10/21/2025 5:00 p.m. CT deadline, which passed
without confirmation.
On Oct 19, 2025 I requested a name-clearing hearing and set a response
deadline of Tue, Oct 21, 2025 at 5:00 p.m. CT to confirm you would
convene the hearing within 14 days (by Nov 4, 2025). That deadline has
passed without confirmation.
Please identify the scheduling official and provide a proposed
date/time for the hearing by 12:00 p.m. CT on Wed, Oct 22, 2025. If
you contend I do not qualify for a name-clearing hearing, please state
the reasons and controlling authority in writing by that same time.
The ADA/§504 interactive process I opened with SDS remains active.
This notice is without waiver of rights.
Kevin Bass PhD MS
Phone: [redacted phone]
Exhibit 6 - Page 9 of 9 [illegible]
Gmail web view URL (omitted from public filing).
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EXHIBIT W November 5, 2023 Meeting with Dr. Simon Williams (Transcript Excerpts) Bass v. Texas
Tech University Health Sciences Center, et al., Civil Action No. 5:25-cv-00270-H (N.D. Tex. Lubbock Division)
Source and format. These are selected verbatim excerpts from an approximately two-hour recorded
meeting on or about November 5, 2023, between Plaintiff Kevin N. Bass ("Bass") and Dr. Simon
Williams ("Williams"), Senior Associate Dean at TTUHSC School of Medicine (source audio file:
Audio_11_05_2023_11_41_40).
The transcript refers to "Speaker A" (Williams) and "Speaker B" (Bass); for clarity, this Exhibit uses
"Williams" and "Bass." Brackets and ellipses reflect only minor, non-substantive edits for readability.
Time stamps in square brackets show the approximate position in the audio file. Citations in the
briefing use the short form "Dean Meeting Tr. [timestamp] (Speaker)."
From Plaintiff's perspective, these excerpts are especially relevant to:
Count 4 (stigma-plus / name-clearing): alleged false "threat/dangerousness" narrative tied to an
extreme status change and continuing publication.
Counts 5-6 (First Amendment and ADA/§ 504 retaliation): institutional reaction to Bass's Twitter
speech and grievances; grievance + tweet · discipline pattern.
Count 3 (procedural due process): lack of pre-deprivation conversation, opaque professionalism
process.
Counts 1-2 (ADA/§ 504 "direct threat" and effective-communication): admissions that Bass is not
dangerous and statements about risk and process.
I. Williams States He Has Never Perceived Bass as a Threat or Danger
Transcript excerpt [01:48:59-01:49:19] - Bass and Williams
Bass: "Can I say Dr. Williams seems to believe that I'm not homicidal?"
Williams: "I... I have said that. I don't think you are. I don't think there's-- I've never sensed threat or
danger or anything like that, but I think that that is not universal."
Relevance. A senior decision-maker expressly states that he has "never sensed threat or danger"
from Bass, despite the emergency suspension, campus ban, and Criminal Trespass Warning. This
supports falsity/exaggeration of the "dangerous student" narrative (Count 4) and undercuts any
"direct threat" theory under ADA/§ 504 (Counts 1-2).
II. Tweet Characterized as Free Speech; Misinterpretation and Overreaction
Transcript excerpt [00:35:39-00:36:07] - Williams
"And you know, free speech is free speech. We've actually had [meetings] with the lawyers about
[that]... when you're in a position that's such a trusted position in society."
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Transcript excerpt [01:05:47-01:05:55] - Williams
"Why is it that that tweet, which is free speech, absolutely, but [the perceived risk] is just such an
incredibly high level that this is the response?"
Transcript excerpt [00:53:15-00:53:32] - Williams and Bass
Williams: "I mean, I think all you can do [in the appeal] is say that your perception is: that was
misinterpreted, that was not what you meant... People shouldn't overreact to your tweets."
Bass: "That's 100% the truth."
Transcript excerpt [00:30:41-00:31:00] - Bass
"This is not a threat and I don't think that would stand up as a threat... That's not a threat on Twitter."
Relevance. Williams repeatedly calls the tweet "free speech" and says it was "misinterpreted" and
that "people shouldn't overreact" to Bass's tweets. Bass denies that the tweet was a threat. Together,
these excerpts support the position that the tweet was protected speech, not a true threat, and that
TTUHSC's response was an overreaction (Count 4; First Amendment and ADA/§ 504 retaliation,
Counts 5-6).
III. Extreme and Rare Sanction: Suspension and Campus Ban
Transcript excerpt [00:03:22-00:03:36] - Williams
"So you tweeted a couple of days ago a tweet which said something like, 'We're all going to be [dead]
very, very soon.'... That tweet itself created a huge amount of concern... That combined with,
honestly, with everything else that's going on, raised the concern level to the level it is right now that
the decision was made to suspend, put you on suspension and not allow you to come on campus."
Transcript excerpt [01:05:17-01:05:35] - Williams
"This is a pretty extreme response. I can only think of this happening once before in all the years I've
been in the School of Medicine, and for a group of people to say, yeah, this person should not come
on campus, that means there's a lot of high level of concern."
Relevance. Williams links the emergency suspension and campus ban directly to the contested tweet
plus generalized "concern" and calls the response "pretty extreme," occurring only "once before" in
his tenure. This shows an exceptional status change (suspension plus campus ban) attached to the
threat label--supporting the "plus" element of stigma-plus (Count 4) and the irreparable-harm
argument.
IV. Perception-Driven "Threat" Narrative in "Today's Environment"
Transcript excerpt [00:02:56; 00:03:14] - Williams
"It [the tweet]... created a huge amount of concern..."
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"As you can imagine, in today's environment, people are very sensitive about that kind of [thing]."
Transcript excerpt [01:01:23-01:01:27] - Williams
"Lots of people expressed concern because they... shared it with each other... Multiple independent
people saying, 'whoa, what's going on here?'"
Transcript excerpt [00:33:06] - Williams
"The danger of social media is no one knows the context, so everyone interprets it the way that they
need to."
Relevance. Williams frames the situation as one of heightened sensitivity and subjective perception
"in today's environment," not as a response to any concrete violent act. He notes that people shared
the tweet and interpreted it without context. This supports the argument that the "threat" label is
driven by others' interpretation, not by actual dangerous conduct (Count 4), and sets up the role of
social-media overreaction in the retaliation narrative (Counts 5-6).
V. Retaliation Narrative: Grievances and Tweets Treated as "Threatening"
Transcript excerpt [00:49:03-00:49:15] - Williams
"Basically [the appeal record is] going to be that tweet and all the other documents that... for example,
complaints that you have submitted against other people, which very quickly turn into a burgeoning
sense of people feeling threatened."
Transcript excerpt [00:49:48] - Bass
"Whenever I make a grievance and then I make a tweet and then they're like, oh, that tweet's
threatening me, therefore we're gonna, like, get him. I feel threatened also. I feel like they're again
doing the same thing, like they're using the disciplinary process to try to, like, harass me... If I was
going to be uncharitable, I could say, well, they're just, like, looking for that tweet. They found that
tweet. They're like, yes, we've got it now. We can get Kevin out of the curriculum."
Transcript excerpt [00:50:13-00:51:23] - Bass and Williams
Bass: "If we want to talk about, like, interpreting other people negatively... there's different ways you
can interpret that, [and it] really determines how we respond to what they're doing. I could say, if I was
going to be uncharitable, I could say, well, they're just, like, looking for that tweet. They found that
tweet. They're like, 'yes, we've got it now. We can get Kevin out of the curriculum.' And then... we can
keep punishing him because we don't like him.
Or they have such a negative thought about me... They're not willing to be charitable towards me.
They're just like, this guy, he's an asshole, he's, like, threatening people now. Like, of course, this is
just typical for Kevin Bass..."
Williams: "I mean, I don't think anyone's doing that, but that's certainly an argument... All I can say is
that I don't think that happens very often, but this is such an unusual situation. You... you... I mean,
you are a personality. You've chosen to be that. And therefore--not that you have to take the
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consequences, but the possibility that you are misinterpreted as you feel it or interpreted by someone
else is going to be much [greater]."
Transcript excerpt [approx. 00:30:26-00:31:25] - Bass
"Other things on Twitter... my impression... when things were intense with me and Rachel, I saw
Trotter... he had [my] Twitter [up]... I know that Twitter is not, apparently, off limits..."
Relevance. Williams confirms that Bass's complaints and grievances are part of the record and "very
quickly" generate "a burgeoning sense of people feeling threatened," while Bass contemporaneously
describes a pattern of protected grievances and speech leading to discipline. Williams acknowledges
this is "certainly an argument" and explains that, because Bass has "chosen" to be a public
"personality," the risk of being misinterpreted is much greater. These passages support the retaliation
narrative (Counts 5-6) and reinforce that the "threat" story rests on misinterpretations of Bass's public
persona and grievances, not genuine dangerousness (Count 4).
VI. Lack of Pre-Deprivation Conversation and Process Opacity
Transcript excerpt [01:10:13-01:11:29] - Bass and Williams
Bass: "Why didn't you guys talk to me about this before? Before doing this?"
Williams: "That's just not the way the process works. So I was in Seattle."
Bass: "Rachel said I physically threatened her once and then Trotter brought me in to talk to me
about it. So why didn't we do that?"
Williams: "This was considered to be more severe."
Transcript excerpt [00:09:18-00:10:18] - Bass
"From my point of view... this process has not seemed very transparent to me at all, to a degree that
is very unnerving to me. We have had the first SPPCC meeting. We did the appeal, it was overturned
on the basis of no specific complaint. But then they still wanted to hold on to [other issues]... Then the
question becomes, okay, so then what do they know? What is the issue? How do they see things?
And I have no idea... Nobody ever communicated that to me... Everything was super unclear."
Transcript excerpt [00:29:05-00:29:07] - Bass
"The institution kept telling [me]... for that first letter that I got back from the first SPPCC, I remember
[it saying I wasn't] a good role model on the team and stuff. I was like, what is this talking about?"
Relevance. Bass asks why no one spoke to him before imposing the suspension and campus ban.
Williams's answers focus on "the process" and his travel ("I was in Seattle") and on the situation
being "considered... more severe," rather than on any concrete imminent danger. Bass describes the
professionalism process as opaque and confusing in real time. These excerpts support
procedural-due-process (Count 3) and ADA effective-communication theories (Counts 1-2), and
underscore the absence of any meaningful pre-deprivation or name-clearing opportunity (Count 4).
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VII. Bass's Non-Threat Explanation of the Tweet (Mortality, Not Violence)
Transcript excerpt [01:09:24-01:10:09] - Bass and Williams
Bass: "Can I also explain what that tweet is about? Because it's really about that-- about leaving
something behind. All this stuff, it's really about that."
Williams: "When I read it the first time... I was like, 'someday.' Okay, we're all going to die someday,
really. But then it said 'very, very soon.'"
Bass: "We are going to die... I was being provocative in that way, but I wasn't trying to [threaten
anyone]. The context is different."
Relevance. Bass offers a non-threat explanation for the tweet--mortality and legacy--and Williams
acknowledges that it reads as "we're all going to die someday," with the "very, very soon" language
being what unsettled others. This is precisely the alternative narrative Bass seeks to present in a
name-clearing process (Count 4).
VIII. Anti-Violence Values and Long-Term Goals (No "Direct Threat")
Transcript excerpt [01:50:01-01:51:03] - Bass and Williams
Bass: "I feel like violence is something that desperate people do, you know, someone who feels like
there is no hope. And that's not my situation... I would only hurt myself. I have big dreams, huge
dreams. If I truly believe in those dreams, violence doesn't make any sense... Even if medicine was
taken away from me, that'd be horrific... but I still have goals I'd fight for. I wouldn't give that away to
just get some petty revenge right now."
Williams: "I mean, again, I have never felt that [you were going to be violent]."
Relevance. Bass explicitly disavows violence and anchors his reasoning in his "big dreams" and
long-term goals. Williams reiterates that he has never felt Bass would be violent. This is powerful
evidence against any claim that Bass posed a genuine safety threat (Counts 1-2) and supports
falsity/exaggeration in the stigma-plus claim (Count 4).
IX. Educational and Professional Stakes; Willingness to Change Behavior
Transcript excerpt [00:05:33-00:07:27] - Bass
"You don't see that I want to be a doctor...?... Second thing is like I do want to be a doctor."
Transcript excerpt [00:34:13-00:34:34; 00:38:03; 00:53:32] - Bass
"I will treat my Twitter like I'm in the clinic, at least as far as controversial things... And I don't do that
in the clinic ever. Again, if they ask me to mask in the clinic, I mask... I don't argue about it."
"No, I got you. And I think I've... gotten much better about that, actually. If you look at my Twitter..."
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"No, they [people] shouldn't [overreact], but I also should do better. I agree... And there will not be this
problem again."
Transcript excerpt [approx. 01:16:16-01:17:02] - Williams
"Your argument here should be... one, why is this not a high-risk situation; and number two, why you
feel that you need to be able to demonstrate improved performance. And if you are unable to be in
the clinic, in the clinical environment, you feel that basically it will prevent you from being able to do
that."
Relevance. Bass emphasizes his desire to be a doctor, his willingness to comply with clinical rules,
and his commitment to treat his Twitter like a clinical environment. Williams acknowledges that Bass
needs clinical access to demonstrate "improved performance" and lower perceived risk. These
statements support irreparable-harm arguments (loss of unique training opportunities),
balance-of-equities and public-interest factors, and the feasibility of narrow, forward-looking injunctive
relief (Counts 1-2, 4-6).
X. Williams's Acknowledgment of His Power and the Seriousness of the Action
Transcript excerpt [01:48:13] - Williams
"You're right. I am in a position of power."
Transcript excerpt [01:54:00] - Williams
"It's important for me that I do this. In fact, that's why I [came back from] Seattle a day early. Because
I needed to be here today."
Transcript excerpt [01:54:16-01:54:21] - Williams
"I want you to know that because I never felt... [negative things about you]. I've always enjoyed my
interactions with you... I wish other people could see it that way, but apparently that's [not the case]."
Relevance. Williams recognizes his institutional "position of power" over Bass and the seriousness of
what was done (enough to change travel plans), while also affirming that he has "always enjoyed"
interacting with Bass and does not share the fear attributed to "other people." This contrast between
internal assessment and the public "dangerous student" narrative further supports
falsity/exaggeration (Count 4) and the need for a formal name-clearing opportunity.
XI. Hearing Testimony: No Lockdown and "No Threat of Destruction"
Hearing transcript excerpt - Bass cross-examining Threat-Assessment Representative
Bass: "How many other times has the university been placed on lockdown based on a non-specific
post like this which makes no threats against anyone?"
Threat-Assessment Representative: "[T]here was no university was not placed on lockdown..."
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Bass: "What was the threat to destruction? What was the threat of destruction ... expressed in this
[post]?"
Threat-Assessment Representative: "Post? None. Nothing."
Relevance. In the formal disciplinary hearing, the threat-assessment representative admits under
questioning that (1) the university was not placed on lockdown in response to Bass's tweet and (2)
when asked "what was the threat to destruction" expressed in the post, he answers "Post? None.
Nothing." This undercuts any claim that the tweet posed an actual "threat of destruction" or met a
"direct threat" standard, and supports Bass's argument that TTUHSC overreacted to protected
speech rather than a genuine threat (Counts 2 and 4, and indirectly 5-6).
XII. Hearing Testimony: Prior Case Was Secret; Bass's Case "Escalated into Public Domain"
Hearing transcript excerpt - Threat-Assessment Representative comparing cases
Threat-Assessment Representative: "...[In a prior case] it actually turned out in the student's favor.
And no one knew. Even within the student body, nobody [knew]."
Threat-Assessment Representative: "In this particular instance ... it was not handled privately...
instead it was escalated into public domain."
Relevance. TTUHSC's own threat-assessment witness concedes that in another serious student
case, the matter "turned out in the student's favor" and "no one knew... even within the student body,
nobody" knew about it. By contrast, in Bass's case, he admits it "was not handled privately" and was
"escalated into public domain." This is direct evidence of publication and institutional stigma:
TTUHSC chose to handle Bass's alleged "threat" differently from comparable matters, allowing it to
become widely known among students. That goes straight to Count 4 (stigma-plus / name-clearing)
and to the existence of ongoing reputational harm, not merely past injury.
XIII. Hearing Testimony (Dr. Erwin): Disability Context and Non-Threat Interpretation of the Tweet
Hearing transcript excerpt - Dr. Erwin (professionalism coach) testifying about Bass
Erwin: "[V]ery, very soon can mean 70 years in the big scheme of things..."
Erwin: "You're talking on a very philosophical level... You got very philosophical on everything."
Erwin: "I completely understand how that language that you have in that tweet would strike other
people as very, very concerning."
Relevance. A TTUHSC professionalism coach who worked closely with Dr. Bass told the hearing
panel that his communication style is "very philosophical," that he "got very philosophical on
everything," and that she did not interpret his tweet as a threat from him, even though she understood
how the language might strike others as "very, very [concerning]." This testimony:
Reinforces that the tweet was understood by someone who knew Dr. Bass as philosophical rhetoric,
not as a concrete threat;
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Frames the conflict as a problem of others' perception of his language, rather than any intent by Dr.
Bass to threaten; and
Supports Dr. Bass's position that TTUHSC's "threat" narrative reflects a misinterpretation of his
speech, rather than an objective finding of dangerousness.