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 Page 1 of 3 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 Page 2 of 3 PageID 332 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 Page 3 of 3 PageID 333 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