Ramsi Woodcock
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Supplemental Response to the Motion for Judgment on the Pleadings
On October 16, I filed a supplemental response to the University officials’ motion for judgment on the pleadings. My response argues that immunity does not bar my claims. It also argues that my suspension, my exclusion from the law school building, faculty meetings and student advising, and the investigation into my speech were retaliation against…
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Notice of Supplemental Authority on the Word ‘Should’ in ABA Interpretation 203-1
At the September 30 hearing, the defendants argued for the first time that ABA Interpretation 203-1 does not bind the University because it says a dean “should not” be appointed over the stated objection of a substantial majority of the faculty, rather than “shall not.” I responded that Interpretation 203-1 states what the mandatory requirement…
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Order Denying a Temporary Injunction
The court denied my motion for a temporary injunction setting aside Dean Van Tatenhove’s appointment. The court found that “the faculty participated in good faith in each of the searches, that the University failed to hire, or even extend offers, to numerous well-qualified candidates approved by the faculty, and then hired the only candidate who…
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Attorney General’s Motion to Dismiss the SJR 55 Claim
The Attorney General moved to be heard on the constitutionality of Senate Joint Resolution 55 and to dismiss Count IX of my complaint in the state suspension case, which challenges SJR 55.
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University’s Motion to Dismiss the State Suspension Case
The University moved to dismiss the state suspension case.
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Notice Regarding State-Court Proceedings
At the October 6 hearing on my motion for a temporary restraining order, the court asked about my state-court proceedings. I explained that nothing the state court has done authorizes or restrains the investigation, that no ruling on interim relief in either court can bind the other, and that the federal court is the only…
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University Officials’ Response to the Motion for a Temporary Restraining Order
The University officials responded to my motion for a temporary restraining order.
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Response to Dispositive Motions
Before the October 6 hearing, the court asked whether the investigation causes irreparable harm, how immunity applies, and how its decision would affect third parties. I explain that the investigation is not a prelude to the unconstitutional action but the action itself, that immunity does not bar injunctive relief, and that the third parties most…
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Order Quashing Subpoenas
The court quashed my subpoenas to Van Tatenhove, Capilouto, and DiPaola to testify at the September 30 hearing on my motion for a temporary injunction. It described the disputed facts as “broader issues of university governance,” and said it was unsure what statute or case law would allow a court to intervene in the appointment…
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Emergency Motion for a Temporary Restraining Order
I asked for a temporary restraining order halting the remaining stages of the investigation and lifting my suspension until the court rules on my motion for a preliminary injunction.
