Whether a student can state a retaliation claim under Section 504 and Title VI

QUESTIONS PRESENTED Dr. Isaacs respectfully petitions the United States Supreme Court to address the following questions presented and grant a writ of certiorari. 1. Whether the Ninth Circuit erroneously determined that a student cannot state a retaliation claim under Section 504 of the Rehabilitation Act and Title VI of the Civil Rights Act, because “no adverse employment action” would exist. 2. Whether USC’s continuous online broadcast of Petitioner’s sealed and acquitted academic record represents an open-ended RICO predicate act that tolls the statute of limitations. 3. Whether the courts below erred in finding that a Gibson Dunn & Crutcher entertainment lawyer’s decision to impose a campus ban against a former University of Southern California medical student warranted protection by the anti-SLAPP statute, and that the campus ban did not violate the First and Fourteenth Amendment because USC is a private school. 4. Whether the factual allegations of the Complaint, accepted as true as they must, preclude the District Court’s reliance on waiver, res judicata, and the statute of limitations to dismiss claims against Defendant-Appellee University of Southern California Keck School of Medicine. li QUESTIONS PRESENTED — Continued 5. Whether the Complaint’s allegations against a particular individual associated with the New Hampshire Board of Medicine are timely and sufficiently viable to survive a Rule 12(b)(6) motion to dismiss. Here marks the sixth certiorari petition concerning a most unfortunate series of events that relate back to a gross anatomy lab in October of 2005, when a fellow first-semester medical student asked Petitioner to stay in her bedroom on a “Keck SOM Surfing Club” trip to a Baja Mexico villa. Petitioner had no prior communication with said student, a daughter of a prominent NIH director, who had recently broken up with another classmate she had dated briefly that semester. A virtual soap opera ensued over a paragraph of text messages. Back in 2005, very few Americans sent text messages; today, the “text” would hardly raise an eyebrow even under heightened #metoo era standards, except for the fact that Petitioner has spent nearly a decade and a half in court trying to resume his promising medical career, a World Bank President resigned over the matter, and now, Gibson Dunn seeks to dismiss a landmark Apple anti-trust lawsuit over Petitioner’s contested medical credentials. Indeed, these events would be better left forgotten — something Petitioner intended to do when he settled the dispute in 2008, and moved on to excel at another medical school and achieve a perfect “99” on the National Boards. But Respondents, and their attorneys, ili QUESTIONS PRESENTED Continued have made a fourteen-year vocation out of oppressing the Petitioner, and unfortunately, some details must be retold. At the Keck Surf Club Mexico trip, the classmate’s ex-boyfriend became most upset that the NIH classmate had “moved on.” This lead to her being subjected to ridicule and peer pressure from several of the exboyfriend’s friends, also Keck classmates. This matter heightened to a disagreement in front of the library, where Petitioner explained to the NIH officer’s daughter that he was on medications for a head injury, and wanted to be left alone. She responded “Do get better,” sarcastically. Petitioner then replied to her with a paragraph of text messages where he relayed highly personal comments spread as rumor by the ex-boyfriend, including an allegation that she had vandalized a Keck “audience response” tablet with the words “Wanna F&*K”? That lead to some sort of emotional outburst inside the Keck Library by the NIH classmate, when she realized the ex-boyfriend had generated slanderous rumors. The next day Petitioner was hauled into Katsufakis’ office, where the Dean asked him “How does it feel to be caught with your pants down.” The Dean took an “unusual” interest in the matter, personally counseling Petitioner, all the while