Exhibit 2 to the motion to dismiss: hearing notice of November 16, 2023 with the listed complaints; a third-party complaint and a patient-related report withheld and a complainant's name redacted on this copy¶

Bass v. TTUHSC, No. 5:25-cv-00244-H-BV (N.D. Tex.) · Dkt. 27-2 · 2026-01-21 · PDF

Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.

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TEXAS TECH UNIVERSITY
HEALTH SCIENCES CENTER."
School of Medicine

November 16, 2023

Kevin Bass, Ph.D.
Kevin.bass@ttuhsc.edu
Dr. Ebtesam Islam, M.D., Ph.D.
Ebtesam.islam@ttuhsc.edu

RE:

HEARING NOTICE
School of Medicine Student Conduct Board
Accused Student: Kev in B as s
Complainant: Dr. Ebtesam Islam

Dear Dr. Bass and Dr. Islam:
As Chair of this Student Conduct Board, and in accordance with Part II., Code of Professional
Conduct (Student Code), I, along with the other Student Conduct Board Members listed
below, are charged with hearing the Complaints filed against, and by, Dr. Bass in accordance
with the Consolidated Hearing Process. It is also my duty to inform you of the following as
required in Part II.F.4.b., Hearing Notice:
1. Date, time and place for the hearing
1. December 11, 2023
11. 8:00 a.m.
111.

TTU System Building, Regent's Committee Room #106

2. Names of the Student Conduct Board members hearing your case:
Dr. Felix Morales - Chair
Dr. Patti Patterson
Dr. Jennifer Mitchell
Ms. Michelle Onuoha
Mr. Joseph Silvaggio
3. Copy of the complaints are attached.
Both Dr. Bass and Dr. Islam may challenge, in writing, the impartiality of any member of the
Student Conduct Board (SOM Student Conduct Board) up to three (3) business day after
receiving this Hearing Notice by submitting their reasons for the challenge to the Student
Conduct Administrator, Dr. David Trotter. The challenging party shall with specificity, and
clarity, detail each reason for such challenge.

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The burden of proving the impartiality or inability of a Student Conduct Board
member to serve lies solely upon the challenging party. If the challenging party

establishes that the challenged members cannot serve with fairness and
objectivity, such member shall be removed and a substitute will be appointed by
the Student Conduct Administrator. If such member is removed, the Student
Conduct Administrator may choose to reschedule the meeting (Part II.F.4c.).
Please let me know if you have any questions regarding this hearing process.
Sincerely,

Felix G. Morales, M.D.
Associate Dean of Admissions
Professor of Family & Community Medicine

3601 4th Street STOP 6216 I Lubbock, Texas 79430-6216 I T 806.743.2297 I F 806.743.2725 I www.ttuhsc.edu/medicine/admissions

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COMPLAINTS

1. 8/1/2023: Complaint filed by Dr. Elisabeth Conser, as a Title IX Mandatory Reporter,

based upon information provided to her by

► Part II. D.5.c.;
"Behavior that disrupts the normal operation of the University, including, but not limited
to, a member of the University community; or conduct that otherwise interferes with or
creates a hostile or intimidating environment for a member of the University
community's academic pursuits or work environment. Such conduct does not necessarily
have to be in violation of the law to violate this section.

► Part 11.D.18.a.:
"Violation of any published University policies, rules, or regulations that govern student
or student organization behavior, including, but not limited to, applicable publications for
each TTUHSC School, such as student handbooks, catalogs, professional and ethical
standards, and course syllabus."
More specifically, SOM OP 40.03 Student Conduct Policy, Medical Student Honor Code,
in part:
"I will enter into professional relationships with my colleagues, teachers, and other health
care professionals in a manner that is respectful and reflective of the high standards and
expectations of my profession.
2. 9/18/2023: General Misconduct Complaint filed by Dr. Jennifer Wilson,

► Part 11.D.18.a.:
"Violation of any published University policies, rules, or regulations that govern student
or student organization behavior, including, but not limited to, applicable publications for
each TTUHSC School, such as student handbooks, catalogs, professional and ethical
standards, and course syllabus."
More specifically, SOM OP 40.03 Student Conduct Policy, Medical Student Honor Code,
in part:
"I will enter into professional relationships with my colleagues, teachers, and other health
care professionals in a manner that is respectful and reflective of the high standards and
expectations of my profession.

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3. 9/29/2023: General Misconduct filed by Dr. Jennifer Wilson,

► Part 11.18.a.:
"Violation of any published University policies, rules, or regulations that govern student
or student organization behavior, including, but not limited to, applicable publications for
each TTUHSC School, such as student handbooks, catalogs, professional and ethical
standards, and course syllabus."
More specifically, SOM OP 40.03 Student Conduct Policy, Medical Student Honor Code,
in part:
"I will enter into professional relationships with my colleagues, teachers, and other health

care professionals in a manner that is respectful and reflective of the high standards and
expectations of my profession.
4. 11/3/2023: "X" post reported to SOM Administration,

► Part 11.D.5.a.:
"Physical harm or threat of harm to any person."

► Part 11.D.5.c.:
"Behavior that disrupts the normal operation of the University, including, but not limited
to, a member of the University community; or conduct that otherwise interferes with or
creates a hostile or intimidating environment for a member of the University
community's academic pursuits or work environment. Such conduct does not necessarily
have to be in violation of the law to violate this section.

► Part 11.18.a.:
"Violation of any published University policies, rules, or regulations that govern student
or student organization behavior, including, but not limited to, applicable publications for
each TTUHSC School, such as student handbooks, catalogs, professional and ethical
standards, and course syllabus."
More specifically, SOM OP 40.03 Student Conduct Policy, Medical Student Honor Code,
in part:
"I will enter into professional relationships with my colleagues, teachers, and other health
care professionals in a manner that is respectful and reflective of the high standards and
expectations of my profession.

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School of Medicine Operating Policy 40.04
Student Promotions and Professional Conduct Committee (SPPCC)
Referrals to the SPPCC due to receiving "Below Expectations" in Professionalism for the
following Clerkships:
1. Psychiatry

Below Expectations

08/01/2023

2. Pediatrics

Below Expectations

09/18/2023

3. Pediatrics

Below Expectations

09/22/2023

4. Pediatrics

Below Expectations

09/22/2023

5. Pediatrics

Below Expectations

10/27/2023

Withheld: third-party complaint

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COMPLAINT #2

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Texas Tech University Health Sciences Center - Student Serv ices
General Misconduct/Grievance Report
Submitted on September 18, 2023 at 2:38:02 pm CDT
Nature
Urgency
Incident Date and Time
Incident Location

Misconduct
School of Medicine
2023-09-07 10:45 AM
Online

Reported by
Name:
Title:
Email:
Phone
Address:

Jennifer Wilson
Assistant Professor of Pediatrics and Covenant Pediatric Clerkship Director
jennifer.e.wilson@ttuhsc.edu
806-782-6480
[Authenticated as Wilson, Jennifer E]

Involved Parties
Kevin Bass ()
Alleged

kevin.bass@ttuhsc.edu

Jennifer Wilson ()
Victim

jennifer.e.wilson@ttuhsc.edu

Rachel Forbes ()
Victim

rachel.forbes@ttuhsc.edu

Shaughn Nunez ()
Victim

shaughn.m.nunez@ttuhsc.edu

Letha McGraw ()
Victim

letha.Mcgraw@ttuhsc.edu

Questions
CODE OF STUDENT/ PROFESSIONAL MISCONDUCT (Select all that apply)
Violation of Published University Policies, Rules, or Regulations, Other, Unsure
GENERAL GRIEVANCE (Select all that apply)

OTHER (If other was selected in sections above please describe)
TTUHSC Medical Student
Please provide a detailed description of the incident/concern using specific concise, objective language (i.e. who,
what, where, when, why, and how).
On 9/7/2023, Kevin Bass sent an email as a reply to Rachel Forbes pertaining to absences during his
pediatric rotation. Kevin missed two days in a row in addition to Labor Day holiday in 1 week. The dates
missed were 9/4, 9/6 and 9/7. Rachel was inquiring about the absences and makeup since the student did not
notify myself as the pediatric clerkship director or Rachel. In his email reply to Rachel, myself, Shaughn
Nunez and Letha McGraw he attached pictures of vomit and diarrhea to help justify his multiple sick days. To
not notify his clerkship director of the sick days and then to include pictures such as those at his level of
education is extremely unprofessional. I will attach the email below but will spare anyone having to see the
images. I can provide them upon request.
What remedy are you seeking for your complaint (e.g., reduction of grade for particular work and/or class, warning,
probation, suspension, dismissal, restitution, etc.)?
Probation, suspension or dismissal

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Attachments
reabsenceswilsonjennifere.pdf

Pending IR #00000488
Submitted from 170. 173. 78. 35. No routing rule matched. Routed to default recipient (Erin Justyna, Associate Provost for Student Affairs).

Withheld: patient-related report

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COMPLAINT
COMPLAINT #4
#4

Case 5:25-cv-00244-H-BV

Kevin
Bass
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Each zinc! every one of us is going to be
dead someday very, very soon.
Given this. why most people put so
rnuch stock into what other people think
about then, is completely beyond me.
These other people. too. are goin~ to be
dead very~ very soon.
5,377

I only c.u o v1h:1t my L-rn1ily think') of mo
love tho:~<: pPc•p';

A&ZMD

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