COMPLAINT WITH JURY DEMAND against All Defendants filed by Alan Lucas.¶
Lucas v. Texas Tech University Health Sciences Center (TTUHSC), No. 5:25-cv-00251 (N.D. Tex.) · Dkt. 1 · 2025-11-12 · PDF
Text extracted from the PDF; scanned pages were read by OCR. The PDF is the authoritative copy.
Case Document 1 Filed 11/12/251Page 1 of 6 PageID 1 Case5:25-cv-00251-H 5:25-cv-00251-H Document Filed 11/12/25 Page 1 of 6 PageID 1 United States District Court Northern District of Texas NOV 12 2025 AM8:08 FILED - USDC - NDTX - LU Lubbock Division Alan Lucas * 5-25CV-251-H versus * Civil Action: Texas Tech University * Health Sciences Center * Comes now, Alan Lucas, plaintiff in the above- respectfully show the following: styled cause, pursuant to 28 U.S.C. § 1331, and would 1. Parties Alan Lucas, plaintiff 8602 Peach Avenue Lubbock, Texas 79404-7777 Texas Tech University Health Sciences Center, defendant P.O. Box 989728 West Sacramento, California 95798-9728 11. Background Texas Tech University Health Sciences Center, (TTUHSC), defendant, is, and has been, the sole Case Document 1 Filed 11/12/25 PageID 2 Case5:25-cv-00251-H 5:25-cv-00251-H Document 1 Page Filed2 of 6 11/12/25 Page 2 of 6 healthcare provider for the plaintiff in this cause and maintains all of his medical records with personal identity information. III. Facts Of The Case Between September 17, 2024, and September 29, 2024, TTHSC, through negligence, had a cybersecurity event by unknowns which resulted in the removal and disclosure of plaintiff's name, date of birth, social security number, address, driver's license number, goverment issued-identification number, health insurance information, and medical information, including medical records / numbers, diagnosis and treatment information, for the purpose of identity theft / fraud by unknown others. In a letter dated January 24, 2025, TTUHSC informed the plaintiff of these facts. Several times plaintiff has reached out to the defendant to resolve the theft of his identity resulting from defendant's negligence to no avail. IV. Relief Plaintiff seeks monetary damages in the amount of one billion dollars and any other equable relief the court may grant plus all court costs 2 PageID 2 Case5:25-cv-00251-H 5:25-cv-00251-H Document 1 Page Filed3 of 6 11/12/25 Case Document 1 Filed 11/12/25 PageID 3 Page 3 of 6 in connection with this lawsuit. V. Jury Demand Plaintiff demands a trial by jury on all issues herein pursuant to F.R.C.P. rule 38(b). VI. Declaration Plaintiff declares, under penalty of perjury, that all facts stated herein is true and correct to the best of his knowledge. Signed this 30th day of October, 2025. alan Lucas Alan Lucas, 644056 8602 Peach Avenue Lubbock, Texas 79404-7777 3 PageID 3 Case5:25-cv-00251-H 5:25-cv-00251-H Document 1 Page Filed4 of 6 11/12/25 Case Document 1 Filed 11/12/25 PageID 4 Page 4 of 6 October 30, 2025 United States District Court Clerk Northern District Of Texas Lubbock, Division 1205 Texas Avenue, Room. 209 Lubbock, Texas 79401-4091 Dear clerk, Please file the enclosed and bring the matter to the attention of the court. Cordially, Alan Lucas 8602 Peach Avenue Lubbock, Texas 79404-7777 RECEIVED NOV 12 2025 CLERK U.S. DISTRICT COURT NORTHERN DISTRICT OF TEXAS PageID 4 Case5:25-cv-00251-H 5:25-cv-00251-H Document Filed 11/12/25 Page 5 of 6 Case Document 1 Filed 1 11/12/25 Page 5 of 6 PageID 5 PageID 5 8602 Peach avenue Alan Lucas, 644056 NOV 12 2025 CLERK U.S. DISTRICT COURT RECEIVED NORTHERN DISTRICT OF TEXAS Lubbock, Texas 79404-7777 79401-402759 Lubbock Division Northern District of Texas United States District Court Lubbock, Texas 79401-4091 1205 Texas avenue, Room 209 8 NOV 2025 AM 1 L LUBBOCK TX 794 2025 1775 2025 OF AMERICA FOREVER/USA UNITED STATES S Case5:25-cv-00251-H 5:25-cv-00251-H Document Filed 11/12/25 Case Document 1 Filed 11/12/251Page 6 of 6 PageID 6 Page 6 of 6 PageID 6 JUSTICE INSTITUTIONAL DIVISION BY TEXAS DEPARTMENT OF CRIMINAL PRIVILEGED INMATE MAIL NOT INSPECTED