OBJECTION filed by Rajin Patel re: 9 MOTION to Dismiss (Bach, Jason)¶

Patel v. Texas Tech University et al, No. 5:17-cv-00174-C (N.D. Tex.) · Dkt. 19 · 2017-09-13 · PDF

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

Case 5:17-cv-00174-C

Document 19

Filed 09/13/17

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PageID 331

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
LUBBOCK DIVISION
RAJIN PATEL,
Plaintiff,

Civil Action No.: 5:17-CV-174-C

v.

(JURY REQUESTED)

TEXAS TECH UNIVERSITY; DUANE
JONES, individually and in his official capacity
as adjunct professor; WILLIAM PASEWARK,
individually and in his official capacity as TTU
Rawls College of Business Associate Dean of
Graduate Programs and Research; ROBERT
RICKETTS, individually and in his official
capacity as Area Coordinator in Accounting; and
BRITTANY TODD, individually and in her
official capacity as Associate Director of the
Office of Student Conduct;
Defendants.

PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
TO THE HONORABLE JUDGE SAMUEL RAY CUMMINGS:
Plaintiff Rajin Patel (“Plaintiff” or “Mr. Patel”), file this Opposition (the “Opposition”) to
Defendants’ Motion to Dismiss (the “Motion”), and would respectfully show as follows:
As explained in detail in the brief in support of this Opposition, which is filed
contemporaneously herewith, the Motion should be denied in its entirety because Plaintiff’s claims
are not barred by any immunities and they are well-pleaded in the Complaint.
///

Case 5:17-cv-00174-C

Document 19

Filed 09/13/17

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PRAYER
Plaintiff Rajin Patel respectfully requests that this Court deny Defendant’s Motion to
Dismiss in its entirety.
DATED this 13th day of September 2017.
THE BACH LAW GROUP, PLLC
By

/s/ Jason J. Bach
JASON J. BACH, ESQ.
Texas Bar No. 24071556
2802 Flintrock Trace, Suite 255
Austin, Texas 78738
Telephone: (702) 925-8787
Facsimile: (702) 925-8788
Attorney for Plaintiff

Case 5:17-cv-00174-C

Document 19

Filed 09/13/17

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CERTIFICATE OF SERVICE
I hereby certify that on the 13th day of September, 2017, a true and correct copy of the
foregoing pleading was served upon each party to this action via the Court’s electronic case filing
system, as follows:
Rola Daaboul, Esq.
Assistant Attorney General
General Litigation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Attorney for Defendants

By:

/s/ Jason J. Bach
Jason J. Bach