Motion to Dismiss for Failure to State a Claim, MOTION to Dismiss for Lack of Jurisdiction () filed by Barbara Cherry, Michael Evans, Texas Tech University Health¶
Pickett v. Texas Tech University Health Sciences Center (TTUHSC) et al, No. 5:20-cv-00232-H-BQ (N.D. Tex.) · Dkt. 11 · 2021-01-22 · PDF
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Case 5:20-cv-00232-H-BV Document 11 Filed 01/22/21 Page 1 of 2 PageID 41 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS LUBBOCK DIVISION AMY PICKETT, Plaintiff, v. TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER; BARBARA CHERRY, individually and in her official capacity as Department Chair of Leadership Studies; and MICHAEL EVANS, individually and in his official capacity as Dean of School of Nursing, Defendants. § § § § § § § § § § § § § Civil Action No. 5:20-CV-00232-H-BQ TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER, BARBARA CHERRY, & MICHAEL EVANS’S MOTION TO DISMISS PLAINTIFF’S ORIGINAL COMPLAINT Defendants Texas Tech University Health Sciences Center, Barbara Cherry, and Michael Evans in their official and individual capacities file this Motion to Dismiss pursuant to Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6). Defendants’ Brief in Support of Motion to Dismiss is filed concurrently herewith. Respectfully submitted, KEN PAXTON Attorney General of Texas BRENT WEBSTER First Assistant Attorney General GRANT DORFMAN Deputy First Assistant Attorney General Case 5:20-cv-00232-H-BV Document 11 Filed 01/22/21 Page 2 of 2 PageID 42 SHAWN COWLES Deputy Attorney General for Civil Litigation THOMAS A. ALBRIGHT Division Chief - General Litigation /s/ Francesca A. Di Troia FRANCESCA A. DI TROIA Texas Bar No. 24097596 Lead Counsel francesca.ditroia@oag.texas.gov Assistant Attorney General Office of the Attorney General General Litigation Division P.O. Box 12548 Austin, Texas 78711-2548 Tel: (512) 475-4651 Fax: (512) 320-0667 ATTORNEYS FOR DEFENDANTS TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER, DR. BARBARA CHERRY, and DR. MICHAEL EVANS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been served electronically through the Court’s Electronic Case File Notification on this the 22nd day of January 2021, to: Amy Pickett PO Box 543 Buffalo Gap, Texas 79508 apickett1010@yahoo.com PLAINTIFF, PRO SE /s/ Francesca A. Di Troia FRANCESCA A. DI TROIA