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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

JANE DOE NO. 1, JANE DOE NO. 2,
and JANE DOE NO. 3,
Plaintiffs,

vs. CIVIL ACTION NO. 
TEXAS CHRISTIAN UNIVERSITY,
DR. DIANE SNOW, DR. ANDREW
SCHOOLMASTER, DR. ROB GARNETT,
DR. DARRON TURNER,
RUSSELL MACK, LEIGH HOLLAND
and AARON CHIMBEL,

Defendants.

JURY DEMAND

mammommomwocmomomwocmomom

 

KEVIN B. WIGGINS OF WHITE AND WIGGIN S, 
MOTION TO WITHDRAW AND SUBSTITUTE
NNAMDI M. ANZOIE AS LEAD ATTORNEY
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, Kevin B. Wiggins, Managing Partner of White and Wiggins, LLP, and
asks this Court to allow him and his Firm to withdraw as counsel for Jane Doe Nos. 1, 2, and 3
(collectively, ?Plaintiffs?) and substitute Nnamdi M. Anozie, Managing Partner of Anozie LLP,

as lead counsel stating as follows:

MOTION TO WITHDRAW

Pursuant to Local Rule 83.12, Kevin B. Wiggins, and White and Wiggins, LLP, seek to
withdraw as counsel because Plaintiffs desire to employ other counsel. Plaintiffs Jane Doe Nos.
1, 2 and 3 are African-American women who have ?led suit against Defendants, Texas Christian
University Dr. Diane Snow, Dr. Andrew Schoolmaster, Dr. Rob Gamett, Dr. Darron

Turner, Russell Mack, Leigh Holland and Aaron Chimbel for discriminatory treatment they faced

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at TCU and TCU-sanctioned activities because of their race and gender.

Defendants? actions violate Title VI of the Civil Rights Act of 1964; Title XI of the Education
Amendments of 1972; Section 504 of the Rehabilitation Act of 1973; Title of the Americans
with Disabilities Act of 1990; fraud; negligence; assault and emotional distress.

Nnamdi M. Anozie, Managing Partner of Anozie, LLP, will be substituted as the attorney
for Plaintiffs. His Texas Bar Number is 24087107, and his mailing address, e-mail address and

telephone number are as follows: 6120 Swiss Avenue, #140838, Dallas, Texas 75214,

nma@anoziellp.com, (469) 693-9087.

Plaintiffs approve this substitution. The withdrawal and substitution will not delay these

proceedings because Nnamdi M. Anozie has appeared as an attorney in this case on Plaintiffs?

behalf.

CONCLUSION

In light of the foregoing Kevin B. Wiggins of White and Wiggins, LLP respectfully

requests that the Court Grant this Motion to Withdraw and that Nnamdi M. Anozie of Anozie,

LLP be substituted as counsel for Plaintiffs.

Respectfully submitted,

WHITE WIGGINS, LLP


g/ r? .-
fl/r'

 

Kevin B. Wiggins
kbwiggins@whitewiggins.com
State Bar No. 21441600

3700 Paci?c Ave. Ste. 3740
Dallas, Texas 75201

T: 214.665.4150

F: 214.665.4160

 

Vdg? 4 UI 4 

Plaintiffs contend

deU 4U l?llUU Vdg? 6 UI LI- lid!

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

JANE DOE NO. 1, JANE DOE NO. 2,
and JANE DOE NO. 3,
Plaintiffs,

vs. CIVIL ACTION NO. 
TEXAS CHRISTIAN UNIVERSITY,
DR. DIANE SNOW, DR. ANDREW
SCHOOLMASTER, DR. ROB GARNETT,
DR. DARRON TURNER,
RUSSELL MACK, LEIGH HOLLAND
and AARON CHIMBEL,

Defendants.

JURY DEMAND



 

ORDER ON KEVIN B. WIGGINS OF WHITE AND WIGGINS, 
MOTION TO WITHDRAW AND SUBSTITUTE
NNAMDI M. ANZOIE AS LEAD ATTORNEY
After considering Kevin B. Wiggins Motion to Withdraw as lead counsel of record for

Plaintiffs Jane Does Nos. 1, 2 and 3, the Court GRANTS the Motion to Withdraw and ORDERS

that Nnamdi M. Anozie be substituted as lead counsel of record for Plaintiffs.

SIGNED on 2020.

 

 

U.S. DISTRICT JUDGE PRESIDING

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APPROVED ENTRY REQUESTED:

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Vdg? 4 UI 4 

ANOZIE, LLP

/S/Nnamdi Anozie
Nnamdi M. Anozie

Bar No. 24087107

E: nma@anoziellp.com

6120 Swiss Avenue, #140838
Dallas, Texas 75214

T: 469.693.9087

 

 

WHITE WIGGINS, LLP

Kevin B. Wiggins

 

Kevin B. Wiggins

Bar No. 21441600

E: kbwiggins@Whitewiggins.com
1700 Paci?c Avenue, Suite 3740
Dallas, Texas 75201

T: 214.665.4150

F: 214.665.4160