Whether the NH District Court abused its discretion in dismissing a Rehabilitation Act retaliation claim, failing to hold Dartmouth accountable for deliberate indifference to a Title IX violation, and whether the NH Board of Medicine violated Petitioner's due process rights

QUESTIONS PRESENTED I. Did the NH District Court abuse its discretion in dismissing a proper Rehabilitation Act retaliation claim, when it incorrectly claimed a “scoured” record did not contain any evidence of protected conduct under the Rehabilitation Act, when in fact no less than three instances of protected conduct existed? II. By turning a blind eye to the Baylor standard re deliberate indifference and failure to investigate Title IX violations, did the NH District Court hold Petitioner Isaacs to an incorrect standard when it required him to demonstrate as a prerequisite that the harassment occurred due to his sex, before holding Dartmouth accountable for not investigating an alleged assault? III. Did the NH Board of Medicine violate Section 1983, and Petitioner’s Fourteenth Amendment due process rights, when it withheld key exonerating evidence from an evidentiary hearing that resulted in the nationwide publication of a false Board reprimand? Preliminary Introduction This case concerns a fourteen-year legal dispute between Petitioner Jeffrey Isaacs, a top ranked medical school graduate, and various institutions and individuals who, thus far, have succeeded in delaying or permanently ending his dream of being a doctor. In 2005, Petitioner was enrolled at University of Southern California’s Keck School of Medicine. A fellow student who boasted of being admitted to USC ii QUESTIONS PRESENTED Continued through connections became involved in a dispute with Petitioner. In defending the aforementioned student, and the Keck Dean involved in her admission, Keck took unfair disciplinary action against Isaacs. Petitioner filed lawsuit in the California Central District Court, asserting various contract claims and a Rehabilitation Act claim; Petitioner had been undergoing treatment for a concussion at the time, which, apparently, he recovered from as he ultimately excelled during medical school. The dispute ended with an agreement sealing Petitioner’s Keck records. Keck subsequently went through three consecutive medical school Deans, all either accused or found guilty of serious crimes. Petitioner arrived at Respondent Dartmouth’s medical residency program in 2011. After six months, Dartmouth terminated Isaacs for non-disclosure of the sealed Keck records. During these six months, Isaacs alleges he was hazed and abused, by a school that decided to hold his non-disclosure of Keck against him. He developed substantial new medical ailments as a result of this mistreatment. He was terminated without the fair hearing required by national accreditation rules. In January 2012, Petitioner Isaacs again sought redress under the Rehabilitation Act retaliation in the New Hampshire District. Upon filing, he sent former Dartmouth and World Bank President Jim Yong Kim a Rule 26 Preservation Letter. Within a week or so, ili QUESTIONS PRESENTED — Continued Dartmouth intentionally deleted all of Isaacs’ emails and medical records. This prompted a motion for sanctions in the NH District Court against Dartmouth and Kim for evidence spoliation. Meanwhile, Isaacs was granted a subpoena in the Texas Western District Court for PACER records as he sought to prove Dartmouth was obstructing justice through evidence spoliation and perjury. The New Hampshire District denied sanctions and promptly granted an unopposed summary judgment to Dartmouth, while Isaacs had a pending motion requesting a hearing. The First Circuit denied a timely appeal. A Writ of Certiorari was petitioned to this Court. Certiorari was not granted. Around the same time as the aforementioned Summary Judgment, the New Hampshire Board rescinded Petitioner’s NH Medical License for not disclosing the sealed Keck records. The Board issued a false public order that “there was no provision sealing Isaacs’ Keck records.” Isaacs had discussed the sealed records on an exhaustive number of occasions with Board Investigator Cahill, and had sent him copies of the sealing provisions by email. Isaacs