Case: White v. The New School

COMPLAINT against The New School. (Filing Fee $ 405.00, Receipt Number ANYSDC-30901156)Document filed by Brandon White. (Attachments: # 1 Exhibit A. 12/4/23 correspondence: academic disruption from assault and December 4th protest, # 2 Exhibit B. 12/4/23 correspondence: White giving TNS notice of discrimination at December 4th protest, # 3 Exhibit C. 12/7/23 correspondence: TNS informing White of complaints against him, # 4 Exhibit D. 12/7/23 correspondence: White responding to complaints against him, # 5 Exhibit E. 12/7/23 correspondence: academic disruption from hostile environment, # 6 Exhibit F. 12/7/23 correspondence: White seeking guidance from academic advisor regarding hostile environment, # 7 Exhibit G. 12/11/23 correspondence: White requesting evidence from TNS, # 8 Exhibit H. 2/5/24 correspondence: White formal response to complaints, # 9 Exhibit I. Early-stage preliminary investigative report, # 10 Exhibit J. 2/21/24 correspondence: White response to TNS regarding early-stage investigative report, # 11 Exhibit K. 3/1/24 correspondence: academic disruption from grievance process and hostile environment, # 12 Exhibit L. 3/5/24 correspondence: White addressing problems with TNS's grievance process, # 13 Exhibit M. 3/11/24 correspondence: academic disruption from grievance process and hostile environment, # 14 Exhibit N. 3/18/24 correspondence: TNS sharing mid-stage investigative report, # 15 Exhibit O. 4/1/24 correspondence: White addressing problems with mid-stage investigative report, # 16 Exhibit P. 4/9/24 correspondence: White addressing outstanding questions about pre-hearing meeting, # 17 Exhibit Q. 4/12/24 correspondence: TNS sharing final investigative report, # 18 Exhibit R. 4/15/24 correspondence: White addressing problems with grievance process, # 19 Exhibit S. 4/17/24 correspondence: legal letter to TNS addressing systemic issues with grievance process, # 20 Exhibit T. 4/18/24 correspondence: TNS refusal to address letter from White's attorneys, # 21 Exhibit U. 4/22/24 correspondence: TNS denying White's request for security services, # 22 Exhibit V. Decision Letter, # 23 Exhibit W. 5/1/24 correspondence: academic disruption from grievance process and hostile environment, # 24 Exhibit X. 5/9/24 correspondence: academic disruption from grievance process and hostile environment.).(Sarelson, Matthew) (Entered: 04/08/2025)

1 Exhibit A. 12/4/23 correspondence: academic disruption from assault and December

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2 Exhibit B. 12/4/23 correspondence: White giving TNS notice of discrimination at

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3 Exhibit C. 12/7/23 correspondence: TNS informing White of complaints against him

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4 Exhibit D. 12/7/23 correspondence: White responding to complaints against him

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5 Exhibit E. 12/7/23 correspondence: academic disruption from hostile environment

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6 Exhibit F. 12/7/23 correspondence: White seeking guidance from academic advisor

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7 Exhibit G. 12/11/23 correspondence: White requesting evidence from TNS

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8 Exhibit H. 2/5/24 correspondence: White formal response to complaints

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9 Exhibit I. Early-stage preliminary investigative report

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10 Exhibit J. 2/21/24 correspondence: White response to TNS regarding early-stage i

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11 Exhibit K. 3/1/24 correspondence: academic disruption from grievance process and

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12 Exhibit L. 3/5/24 correspondence: White addressing problems with TNS's grie

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13 Exhibit M. 3/11/24 correspondence: academic disruption from grievance process an

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14 Exhibit N. 3/18/24 correspondence: TNS sharing mid-stage investigative report

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15 Exhibit O. 4/1/24 correspondence: White addressing problems with mid-stage inves

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16 Exhibit P. 4/9/24 correspondence: White addressing outstanding questions about p

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17 Exhibit Q. 4/12/24 correspondence: TNS sharing final investigative report

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18 Exhibit R. 4/15/24 correspondence: White addressing problems with grievance proc

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19 Exhibit S. 4/17/24 correspondence: legal letter to TNS addressing systemic issue

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20 Exhibit T. 4/18/24 correspondence: TNS refusal to address letter from White'

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21 Exhibit U. 4/22/24 correspondence: TNS denying White's request for security

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22 Exhibit V. Decision Letter

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23 Exhibit W. 5/1/24 correspondence: academic disruption from grievance process and

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24 Exhibit X. 5/9/24 correspondence: academic disruption from grievance process and

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CIVIL COVER SHEET filed..(Sarelson, Matthew) (Entered: 04/08/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to The New School, re: 1 Complaint,,,,,,,,,. Document filed by Brandon White..(Sarelson, Matthew) (Entered: 04/08/2025)

ELECTRONIC SUMMONS ISSUED as to The New School. (vf) (Entered: 04/09/2025)

Case Opening Initial Assignment Notice

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Andrew L. Carter, Jr. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(vf)

Magistrate Judge Robyn F. Tarnofsky is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vf)

Case Designation

Case Designated ECF. (vf)

Case Designated ECF

AFFIDAVIT OF SERVICE. All Defendants. Service was accepted by Scott Belford. Director of Emergency Operations. Document filed by Brandon White..(Sarelson, Matthew) (Entered: 04/15/2025)

NOTICE OF APPEARANCE by Michael E. Baughman on behalf of The New School..(Baughman, Michael) (Entered: 04/25/2025)

LETTER MOTION for Extension of Time to File Answer re: 1 Complaint,,,,,,,,, Move, Or Otherwise Respond To The Complaint addressed to Judge Andrew L. Carter, Jr. from Michael E. Baughman dated 04/25/2025. Document filed by The New School..(Baughman, Michael) (Entered: 04/25/2025)

ORDER granting 7 Letter Motion for Extension of Time to Answer re 1 Complaint. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 4/28/2025) The New School answer due 6/2/2025. (ar) (Entered: 04/28/2025)

FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Jacob William Roth to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31036338. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Brandon White. (Attachments: # 1 Affidavit Affidavit of Jacob Roth in Support of PHV Motion, # 2 Exhibit Certificate of Good Standing Nebraska, # 3 Exhibit Certificate of Good Standing District of Columbia, # 4 Exhibit Certificate of Good Standing Florida, # 5 Proposed Order Proposed Order Granting Pro Hac Vice for Jacob Roth).(Sarelson, Matthew) Modified on 5/6/2025 (rju). (Entered: 05/06/2025)

MOTION for Jacob William Roth to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Brandon White. (Attachments: # 1 Affidavit Affidavit of Jacob Roth in Support of PHV Motion, # 2 Exhibit Certificate of Good Standing Nebraska, # 3 Exhibit Certificate of Good Standing District of Columbia, # 4 Exhibit Certificate of Good Standing Florida. Supreme Court, # 5 Exhibit Certificate of Good Standing Florida. The Florida Bar, # 6 Proposed Order Proposed Order Granting Pro Hac Vice for Jacob Roth).(Sarelson, Matthew) (Entered: 05/06/2025)

Notice Regarding Deficient Motion to Appear Pro Hac Vice

Notice Regarding Deficient Motion to Appear Pro Hac vice

>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. 9 MOTION for Jacob William Roth to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-31036338. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Florida; Motion must have a wet signature if filing using another individual's Pacer account; Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (rju)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 10 MOTION for Jacob William Roth to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju)

ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE granting 10 MOTION for Jacob William Roth to Appear Pro Hac Vice. The motion of Jacob W. Roth, for admission to practice Pro Hac Vice in the above captioned action is granted.. (Signed by Judge Andrew L. Carter, Jr on 5/9/2025) (jca) (Entered: 05/09/2025)

LETTER MOTION for Conference (Pre-Motion) addressed to Judge Andrew L. Carter, Jr. from Michael E. Baughman dated 06/02/2025. Document filed by The New School..(Baughman, Michael) (Entered: 06/02/2025)

LETTER addressed to Judge Andrew L. Carter, Jr. from Matthew Sarelson dated 06/05/2025 re: Response to Letter Motion. Document filed by Brandon White..(Sarelson, Matthew) (Entered: 06/05/2025)

NOTICE OF APPEARANCE by Jacob Roth on behalf of Brandon White..(Roth, Jacob) (Entered: 06/05/2025)

ORDER denying 12 Letter Motion for Conference. The Court DENIES Defendant's request for a premotion conference and sets forth the following briefing schedule: Opening briefs due June 30, 2025; Opposition briefs due July 14, 2025; Replies, if any, due July 21, 2025. The Clerk of Court is respectfully directed to terminate the letter motion at ECF No. 12. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 6/9/25) (yv) (Entered: 06/09/2025)

Set/Reset Deadlines

Set/Reset Deadlines: Motions due by 6/30/2025. Responses due by 7/14/2025. Replies due by 7/21/2025. (yv)

LETTER MOTION for Extension of Time addressed to Judge Andrew L. Carter, Jr. from Michael E. Baughman dated 06/13/2025. Document filed by The New School. (Attachments: # 1 Proposed Order Granting Letter Motion for Modified Briefing Schedule).(Baughman, Michael) (Entered: 06/13/2025)

ORDER granting 16 Letter Motion for Extension of Time. The Court hereby GRANTS the Parties' request and modifies the briefing schedule as follows: Opening briefs due on July 18, 2025; Opposition briefs due on August 8, 2025; and Reply briefs due on August 18, 2025 The Clerk of the Court is respectfully directed to terminate the letter motion at ECF No. 16. SO ORDERED. ( Motions due by 7/18/2025.) (Signed by Judge Andrew L. Carter, Jr on 6/16/25) (yv) (Entered: 06/16/2025)

MOTION to Dismiss . Document filed by The New School..(Baughman, Michael) (Entered: 07/18/2025)

MEMORANDUM OF LAW in Support re: 18 MOTION to Dismiss . . Document filed by The New School..(Baughman, Michael) (Entered: 07/18/2025)

CONSENT MOTION for Extension of Time to File Response/Reply as to 17 Order on Motion for Extension of Time, . Document filed by Brandon White..(Sarelson, Matthew) (Entered: 08/07/2025)

STIPULATION AND ORDER REGARDING BRIEFING SCHEDULE FOR DEFENDANT'S MOTION TO DISMISS AND CONSENT TO AMENDMENT, IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for Plaintiff and Defendant, subject to the Court's approval, as follows: 1. The deadline for Plaintiff to file its opposition to Defendant's Motion to Dismiss (ECF No. 18) is extended from August 8, 2025, to August 22, 2025. The deadline for Defendant to file its reply in further support of the Motion to Dismiss is extended from August 18, 2025, to September 5, 2025. This stipulation is entered into without prejudice to the rights of any party to seek further extensions or modifications to the schedule, as may be necessary, subject to Court approval. SO ORDERED. Motions terminated: 20 CONSENT MOTION for Extension of Time to File Response/Reply as to 17 Order on Motion for Extension of Time, . filed by Brandon White., ( Replies due by 9/5/2025., Responses due by 8/22/2025) (Signed by Judge Andrew L. Carter, Jr on 8/7/25) (yv) (Entered: 08/07/2025)

LETTER MOTION for Conference addressed to Judge Andrew L. Carter, Jr. from Jacob William Roth dated 8/22/2025. Document filed by Brandon White..(Roth, Jacob) (Entered: 08/22/2025)

LETTER RESPONSE to Motion addressed to Judge Andrew L. Carter, Jr. from Michael E. Baughman dated 08/27/2025 re: 22 LETTER MOTION for Conference addressed to Judge Andrew L. Carter, Jr. from Jacob William Roth dated 8/22/2025. . Document filed by The New School..(Baughman, Michael) (Entered: 08/27/2025)

ORDER terminating 18 Motion to Dismiss; denying as moot 22 Letter Motion for Conference. The Court is in receipt of the Parties' correspondence in connection with Plaintiffs motion to amend the complaint (ECF Nos. 22, 23). Having consi dered the Parties' arguments, the Court GRANTS Plaintiff leave to amend the Complaint. The Court ORDERS Plaintiff to file his Amended Complaint on September 26, 2025. Defendant will be permitted to file a renewed request for leave to file a motion to dismiss the Amended Complaint if they so wish. The Clerk of Court is respectfully directed to terminate the letter motion at ECF No. 22, which is disposed of in this order, as well as the pending motion at ECF No. 18, which is rendered moot by the filing of an Amended Complaint. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 9/5/2025) (ar)

FIRST AMENDED COMPLAINT amending 1 Complaint,,,,,,,,, against The New School with JURY DEMAND.Document filed by Brandon White. Related document: 1 Complaint,,,,,,,,,. (Attachments: # 1 Exhibit Exhibit A. 12/4/23 correspondence: academic disruption from assault and December 4th protest, # 2 Exhibit Exhibit B. 12/4/23 correspondence: White giving TNS notice of harassment at December 4th protest, # 3 Exhibit Exhibit C. 12/7/23 correspondence: TNS informing White of complaints against him, # 4 Exhibit Exhibit D. 12/7/23 correspondence: White responding to complaints against him, # 5 Exhibit Exhibit E. 12/7/23 correspondence: academic disruption from hostile environment, # 6 Exhibit Exhibit F. 12/7/23 correspondence: White seeking guidance from academic advisor regarding hostile environment, # 7 Exhibit Exhibit G. 12/11/23 correspondence: White requesting evidence from TNS, # 8 Exhibit Exhibit H. 2/5/24 correspondence: White formal response to complaints, # 9 Exhibit Exhibit I. Early-stage preliminary investigative report, # 10 Exhibit Exhibit J. 2/21/24 correspondence: White response to TNS regarding early-stage investigative report, # 11 Exhibit Exhibit K. 3/1/24 correspondence: academic disruption from grievance process and hostile environment, # 12 Exhibit Exhibit L. 3/5/24 correspondence: White addressing problems with TNS's grievance process, # 13 Exhibit Exhibit M. 3/11/24 correspondence: academic disruption from grievance process and hostile environment, # 14 Exhibit Exhibit N. 3/18/24 correspondence: TNS sharing mid-stage investigative report, # 15 Exhibit Exhibit O. 4/1/24 correspondence: White addressing problems with mid-stage investigative report, # 16 Exhibit Exhibit P. 4/9/24 correspondence: White addressing outstanding questions about pre-hearing meeting, # 17 Exhibit Exhibit Q. 4/12/24 correspondence: TNS sharing final investigative report, # 18 Exhibit Exhibit R. 4/15/24 correspondence: White addressing problems with grievance process, # 19 Exhibit Exhibit S. 4/17/24 correspondence: legal letter to TNS addressing systemic issues with grievance process, # 20 Exhibit Exhibit T. 4/18/24 correspondence: TNS refusal to address letter from White's attorneys, # 21 Exhibit Exhibit U. 4/22/24 correspondence: TNS denying White's request for security services, # 22 Exhibit Exhibit V. Decision Letter, # 23 Exhibit Exhibit W. 5/1/24 correspondence: academic disruption from grievance process and hostile environment, # 24 Exhibit Exhibit X. 5/9/24 correspondence: academic disruption from grievance process and hostile environment).(Roth, Jacob) (Entered: 09/08/2025)

1 Exhibit Exhibit A. 12/4/23 correspondence: academic disruption from assault and

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2 Exhibit Exhibit B. 12/4/23 correspondence: White giving TNS notice of harassment

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3 Exhibit Exhibit C. 12/7/23 correspondence: TNS informing White of complaints aga

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4 Exhibit Exhibit D. 12/7/23 correspondence: White responding to complaints agains

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5 Exhibit Exhibit E. 12/7/23 correspondence: academic disruption from hostile envi

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6 Exhibit Exhibit F. 12/7/23 correspondence: White seeking guidance from academic

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7 Exhibit Exhibit G. 12/11/23 correspondence: White requesting evidence from TNS

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8 Exhibit Exhibit H. 2/5/24 correspondence: White formal response to complaints

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9 Exhibit Exhibit I. Early-stage preliminary investigative report

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10 Exhibit Exhibit J. 2/21/24 correspondence: White response to TNS regarding early

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11 Exhibit Exhibit K. 3/1/24 correspondence: academic disruption from grievance pro

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12 Exhibit Exhibit L. 3/5/24 correspondence: White addressing problems with TNS

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13 Exhibit Exhibit M. 3/11/24 correspondence: academic disruption from grievance pr

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14 Exhibit Exhibit N. 3/18/24 correspondence: TNS sharing mid-stage investigative r

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15 Exhibit Exhibit O. 4/1/24 correspondence: White addressing problems with mid-sta

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16 Exhibit Exhibit P. 4/9/24 correspondence: White addressing outstanding questions

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17 Exhibit Exhibit Q. 4/12/24 correspondence: TNS sharing final investigative repor

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18 Exhibit Exhibit R. 4/15/24 correspondence: White addressing problems with grieva

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19 Exhibit Exhibit S. 4/17/24 correspondence: legal letter to TNS addressing system

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20 Exhibit Exhibit T. 4/18/24 correspondence: TNS refusal to address letter from Wh

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21 Exhibit Exhibit U. 4/22/24 correspondence: TNS denying White's request for

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22 Exhibit Exhibit V. Decision Letter

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23 Exhibit Exhibit W. 5/1/24 correspondence: academic disruption from grievance pro

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24 Exhibit Exhibit X. 5/9/24 correspondence: academic disruption from grievance pro

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LETTER addressed to Judge Andrew L. Carter, Jr. from Michael E. Baughman dated 09/19/2025 re: Motion To Dismiss And Proposed Briefing Schedule. Document filed by The New School. (Attachments: # 1 Proposed Order Setting Briefing Schedule).(Baughman, Michael) (Entered: 09/19/2025)

ORDER, The Court hereby GRANTS the Parties' request and sets the briefing schedule as follows: Opening briefs due on October 10, 2025; Opposition briefs due on November 7, 2025; and Reply briefs due on November 21, 2025. The Clerk of the Court is respectfully directed to terminate the letter motion at ECF No. 26. SO ORDERED. ( Motions due by 10/10/2025., Replies due by 11/21/2025., Responses due by 11/7/2025) (Signed by Judge Andrew L. Carter, Jr on 9/19/25) (yv)

MOTION to Dismiss The Amended Complaint. Document filed by The New School..(Baughman, Michael) (Entered: 10/10/2025)

MEMORANDUM OF LAW in Support re: 28 MOTION to Dismiss The Amended Complaint. . Document filed by The New School..(Baughman, Michael) (Entered: 10/10/2025)

RESPONSE in Opposition to Motion re: 28 MOTION to Dismiss The Amended Complaint. . Document filed by Brandon White..(Roth, Jacob) (Entered: 11/07/2025)

REPLY MEMORANDUM OF LAW in Support re: 28 MOTION to Dismiss The Amended Complaint. / Defendant The New School's Reply Memorandum of Law in Support of its Motion to Dismiss the Amended Complaint. Document filed by The New School..(Baughman, Michael) (Entered: 11/21/2025)

NOTICE OF APPEARANCE by Josiah Contarino on behalf of Brandon White..(Contarino, Josiah) (Entered: 01/20/2026)