Lewis v. Administrators of the Tulane Educational Fund

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
CAMERON LEWIS 	CIVIL ACTION
VERSUS 	NO: 	26-1001
THE ADMINISTRATORS OF THE TULANE
EDUCATIONAL FUND
SECTION: “E” (4)
ORDER AND REASONS
Before the Court is a Motion for Protective Order (R. Doc. 22) filed by Defendant, the
Administrators of the Tulane Educational Fund (“Defendant” or “Tulane”), seeking the Court to
issue 	a 	protective 	order 	requiring 	Plaintiff 	to 	(1) 	cease 	all 	harassing 	and 	inappropriate
communications to Tulane employees and administrators; and (2) direct all communications
intended for Tulane employees and administrators to undersigned counsel for appropriate handling
with the exception that Plaintiff may direct (a) communications about current classes and
coursework to her Tulane employees responsible for class scheduling, professors and/or teaching
assistants and (b) communications about current student support services to her assigned support
persons, Dean Erica Woodley and/or Mr. Kyle Pearson. Tulane further requests that Plaintiff be
limited to sending no more than one email per day to undersigned counsel, with that email to
contain all communications and questions that Plaintiff wishes to raise. The Motion is opposed. R.
Doc. 26. The matter was heard by oral argument on August 26, 2026.
I. 	Introduction
A. Factual Summary
Plaintiff Cameron Lewis (“Plaintiff” or “Lewis”) is a current student at Tulane University
pursuing a master’s degree in physics. In 2018, Lewis contends that she was diagnosed with Post
Traumatic Stress Disorder (“PTSD”) and Generalized Anxiety Disorder (“GAD”). R. Doc. 1.
Lewis contends that in 2025, she was diagnosed with Agoraphobia and Panic Disorder. Id.
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Lewis contends that as of Fall 2025, she was registered with Tulane’s Goldman Center for
Accommodations as a student with a disability. Id. Lewis contends that on August 19, 2025, upon
the start of the Fall 2025 semester, she requested disability accommodation from the Goldman
center for remote access to her courses. Id. Lewis contends that Tulane did not provide her with
the accommodation and that she was therefore unable to effectively participate in her coursework.
Id. Lewis contends that when she expressed her concerns to the university, she was told to
withdraw from her coursework. Id.
Lewis contends that on September 30, 2025, her accommodation request was approved,
but it was not implemented for the Fall 2025 semester. Id. Lewis contends that her accommodation
request was approved after the allotted timeframe for students to withdraw without penalty and as
a result, she lost her tuition payments for the fall semester. Id.
On May 8, 2026, Lewis filed this civil action against the Administrators of the Tulane
Educational Fund (“Defendant” or “Tulane”), alleging that Tulane discriminated against her based
on disability in violation of the Americans with Disabilities Act (“ADA”), the Americans with
Disability Act Amendment Act (“ADAAA”), 42 U.S.C. § 12101 et seq., and Section 504 of the
Rehabilitation Act of 1973 (“Section 504”), 29 U.S.C. § 794. Id.
Lewis filed a previous suit alleging similar claims in the Fall of 2025. That suit was
voluntarily dismissed in March 2026. During that suit, many communication issues arose between
Lewis and Tulane, such as Lewis allegedly directing litigation-related questions to Tulane
employees rather than Defense counsel, Amy McIntire. This issue among others has persisted in
the instant litigation.
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B. Subject Motion for Protective Order
On August 18, 2026, Tulane filed the instant Motion for Protective Order. R. Doc. 22. In
its 	Memorandum 	in 	Support, 	Tulane 	argues 	that 	Lewis’s 	“inappropriate 	and 	harassing”
communications have “recently escalated and become constant and untenable.” R. Doc. 22 at 1.
Tulane cites various examples.
First, Tulane cites a series of AI-generated cartoons that Lewis allegedly created and
emailed to several Tulane employees. R. Doc. 22-1 at 5-6. Tulane’s Counsel argues that Lewis’s
messages alongside the AI-generated cartoons—such as “I heard a scary movie is not showing at
your institution, so I drew a pretty picture of you. I was hoping to get it autographed”—are
harassment. R. Doc. 22-1 at 4.
Tulane proffers another example wherein between approximately July 31, 2026, and
August 10, 2026, Lewis allegedly communicated legal questions intentionally disguised as
disability-related questions to her assigned Disability Resource Professional (“DRP”), Jessica
Machado (“Machado”). See R. Doc. 22-8. On July 31, 2026, Lewis asked Machado to reassign her
to a different DRP that is not directly involved in Lewis’s pending litigation against Tulane. Id. at
3. Additionally, Lewis identified her concerns that she is unable to ask questions to her own DRP
about her accommodations as a student because she keeps getting redirected to Tulane’s Counsel.
On August 4, 2026, Machado confirmed that she would remain Lewis’s DRP. That same
day, Lewis emailed Machado a list of questions regarding subjects such as who is responsible for
administering 	her 	disability 	accommodation 	requests, 	Machado’s 	discretion 	to 	exercise
independent professional judgement in granting or denying her requests, whether Tulane’s
Counsel has any role in the administration of Lewis’s accommodations, and whether the process
for administering her accommodations has changed due to the pending litigation. Id. at 7.
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On August 7, 2026, Machado informed Lewis to direct her questions to Tulane’s Counsel.
Id. at 6. On August 10, 2026, Tulane contends that Lewis again directed the same questions to
Machado. R. Doc. 22-9. On August 11, 2026, Machado again redirected Lewis to Tulane’s
Counsel and Lewis communicated her confusion as to whether her DRP could outsource her
disability-related questions to Tulane’s Counsel, and why her questions were considered litigation-
related such that they needed to be referred to Tulane’s Counsel. Id. at 5. After receiving no clear
answer, Lewis requested a meeting with Michael Fitts, the President of Tulane University.
Tulane argues that Lewis has refused to appropriately communicate with Tulane’s Counsel
under the guise that she has an attorney, even though Lewis is pro se. Tulane refers to multiple
emails in which Lewis has given allegedly fake phone numbers to Tulane’s Counsel after claiming
that she has an attorney. R. Doc. 22-11. Tulane alleges that these are Lewis’s attempts to avoid
directly communicating with Tulane’s Counsel. Tulane argues that Lewis has abused the pro se
process.
Finally, Tulane attaches exhibits regarding Lewis’s requests for Tulane to provide her with
someone to advise her through the complicated process of making internal complaints with
Tulane’s Equal Opportunity Office. R. Doc. 22-10. Tulane refers to Lewis’s internal complaints
in its Motion and supporting Memorandum but attaches additional exhibits wherein Lewis
advocated for another Tulane student, George Zhao. It is unclear whether such communications
are relevant to the ongoing litigation between the parties.
On August 20, 2026, Lewis filed her Memorandum in Opposition to the instant motion. R.
Doc. 26. Lewis acknowledges that during litigation, there may be a need for protective order, but
not one that is so broad that it encompasses even non-litigation-related communications. Id.
Specifically, Lewis expresses her concern that a sweeping protective order granted in Tulane’s
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favor would prevent her from accessing information about her accommodations which she utilizes
in her everyday academic life. Id. Further, Lewis contends that her AI-generated “artwork” has
been taken too seriously by Tulane. Id. Lewis contends that such “artwork” was created as an
expressive form of criticism, and it clearly used satire, exaggeration, and imagery to display her
message. Id. Lewis argues that Tulane “may dislike the message or consider the imagery
unsettling, but those reactions do not by themselves establish a true threat, harassment, or good
cause for a sweeping prior restraint.” R. Doc. 26 at 2.
On August 26, 2026, the subject Motion was heard by oral argument before this Court. R.
Doc. 33.
II. 	Standard of Review
A) Protective Orders
According to Rule 26(c)(1) of the Federal Rules of Civil Procedure, “[a] party or any person
from whom discovery is sought may move for a protective order in the court where the action is
pending.” F ED. R. C IV. P. 26(c)(1).
The district court is entrusted wide discretion to decide whether to and to what extent to
issue a protective order. Nguyen v. Excel Corp., 197 F.3d 200, 209 n.27 (5th Cir. 1999) (citations
omitted). For example, the court may order that the parties conduct discovery by a particular
method. FED. R. C IV. P. 26(c)(1)(C).
If the movant demonstrates “good cause,” the court may issue an order to protect a party
or person from annoyance, embarrassment, oppression, or undue burden or expense.” F ED. R. C IV.
P. 26(c)(1). Rule 26(c)’s “good cause” requirement indicates that the party seeking a protective
order has the burden “to show the necessity of its issuance, which contemplates a particular and
specific demonstration of fact as distinguished from stereotyped and conclusory statements.” In re
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Terra Int’l, Inc., 134 F.3d 302, 306 (5th Cir. 1998) (quoting United States v. Garrett, 571 F.2d
1323, 1326 n.3 (5th Cir. 1978)).
“Harassment” is not mentioned by Rule 26, but it is reasonably contemplated. For the
purposes of this Order, “Harassment” is defined as “[u]nwarranted speech or behavior causing
annoyance, alarm, distress, or intimidation, usually occurring persistently over a period of time.”
Harassment, OXFORD ENGLISH DICTIONARY ONLINE (3d ed. 2023).
B) Pro Se Litigants
The Fifth Circuit has held that “pro se pleadings are held to less stringent standards than
pleadings drafted by lawyers,” and “pro se pleadings must be treated liberally.” U.S. v. Robinson,
78 F.3d 172, 174 (5th Cir. 1996); Priester v. Lowndes County, 354 F.3d 414, 418 (5th Cir. 2004).
However, pro se litigants are not exempt from complying with the Federal Rules of Civil
Procedure and the Local Rules. NCO Fin. Sys., Inc. v. Harper-Horsley, No. 07-4247, 2008 WL
2277843, at *3 (E.D. La. May 29, 2008) (quoting Birl v. Estelle, 660 F.2d 592, 593 (5th Cir. 1981).
Further, pro se status does not “relieve [a litigant] of the obligation to comply with the governing
rules addressing the proper means of obtaining discovery.” Jackson v. Navy Fed. Credit Union,
No. 25-1821, 2026 WL 2937668, at *1 (E.D. La. Sept. 30, 2026).
This also means that pro se litigants must follow the applicable ethical rules, which in this
District are the Louisiana Rules of Professional Conduct. See E.D. La. LR 83.2.3, 83.2.7. Rule 4.2
of the Louisiana Rules of Professional Conduct provides that unless the other lawyer consents, a
lawyer or pro se litigant shall not communicate about “the subject of the representation” with a
person the lawyer or pro se litigant knows to be represented by a lawyer in the matter. La. Rules
of Prof’l Conduct R. 4.2. This necessarily includes communications with individuals the lawyer
or pro se litigant knows to be a “director, officer, employee, member, shareholder or other
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constituent of a represented organization” who either (1) “supervises, directs or regularly consults
with the organization’s lawyer” about the matter; (2) “has the authority to obligate the organization
with respect to the matter; or (3) whose act or omission in connection with the matter may be
imputed to the organization for purposes of civil or criminal liability.” Id.
C) Methods of Discovery
Discovery in federal court is governed by the Federal Rules of Civil Procedure. The scope
of discovery is governed by Rule 26, which provides that “[p]arties may obtain discovery regarding
any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the
needs of the case.” FED. R. C IV. P. 26(b)(1). Information within this scope need not be admissible
at trial to be discoverable Id.
If a party is represented by an attorney, service of discovery requests must be made on the
attorney unless the court orders otherwise. F ED. R. C IV. P. 5(b)(1).
Parties seeking to gather discoverable information may do so by multiple methods,
including oral or written depositions (Rule 30 and Rule 31), interrogatories (Rule 33), requests for
production of documents or tangible things or to permit entry onto land (Rule 34), physical and
mental examinations (Rule 35), and requests for admission (Rule 36). FED. R. C IV. P. 30, 31, 33,
34, 35, 36. Any deficiencies with discovery responses are governed by Rule 37.
III. 	Analysis
Tulane argues that Plaintiff’s communications to Tulane employees and Tulane Counsel
are inappropriate and harassing, and that a protective order limiting the nature and frequency of
such communications is necessary. Tulane additionally contends that Plaintiff is abusing her pro
se litigant status by not following the Rules of Civil Procedure regarding proper discovery
methods, this District’s Local Rules, and the Louisiana Rules of Professional Conduct. As support,
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Tulane compares Plaintiff’s behavior to that demonstrated in Eustice v. Louisiana Through Bd. Of
Supervisors of Louisiana State Univ., No. 18-1008, 2020 WL 3520298 (M.D. La. June 29, 2020).
Plaintiff concedes to reasonable regulation of her communications which are objectively
inappropriate and/or harassing. However, Plaintiff argues that Tulane provides no definition for
“harassment” or “inappropriate” with which to assess the communications at issue. Further,
Plaintiff argues that this case is distinguishable from Eustice. Plaintiff expresses concern that a
broad protective order limiting her communication with Tulane employees would impede upon
her right to university support services in her capacity as a student. Plaintiff requests that any
protective order issued by the Court provide safeguards to protect Plaintiff’s access to student
services separate from this litigation.
A) AI Generated Images
It is undisputed that Plaintiff created and communicated AI-generated “artwork” featuring
depictions of interactions with the Tulane Goldman Center for Student Accessibility, the Equal
Opportunity Office, and other internal offices at the university. See R. Doc. 22-1 at 5-6. Tulane
points to these images as examples of why it should be granted a protective order.
The disputed images depict Plaintiff’s opinions, emotions, and personal feelings about
various Tulane offices. The Court finds such communications are inappropriate in the context of
litigation. The Court finds that illustrations of this nature should not be communicated by Plaintiff
to Tulane employees or Tulane’s Counsel.
In line with the requirements set forth by the Fifth Circuit in In re Terra Int’l, 134 F.3d at
306, these images demonstrate specific facts sufficient to necessitate the issuance of a protective
order. To this extent, Tulane has satisfied its burden of demonstrating “good cause” and therefore,
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the Court grants Tulane’s request for a protective order to prevent future communications by
Plaintiff of this nature.
B) Frustration & Confusion Do Not Constitute Harassment
Tulane cites a few other examples of Plaintiff’s communications to Tulane employees
which Tulane contends constitute harassment. However, for the reasons assigned below, the Court
finds that they are not harassment.
First, Tulane cites an email sent by Plaintiff on March 11, 2026, to unidentified Tulane
employees—likely Tiffany Smith, the Director of Equal Opportunity & Resolution Management
(“Smith”), and Erica Woodley, Dean of Students (“Woodley”)—to express her frustration and
confusion as to why Tulane employees were redirecting her emails to Tulane’s Counsel when in a
previous proceeding, Plaintiff was “excluded from conferring or communicating with” Tulane’s
Counsel. R. Doc. 22-5 at 2-3. Plaintiff expressed her concern that Tulane was retaliating against
her for filing separate internal complaints. Id. at 3. Specifically, Plaintiff expressed that Tulane
was creating barriers to her access to student resources by redirecting all her questions to Tulane’s
Counsel, including those unrelated to the litigation. Id.
After receiving no response, Plaintiff followed up with Smith and Woodley on March 22,
and again on April 2, 2026. Id. at 2. On April 3, 2026, Smith redirected Plaintiff to Tulane’s
Counsel allegedly because of Plaintiff’s previous, voluntarily dismissed civil action against
Tulane. Id. at 1. Smith did not address any of Plaintiff’s questions regarding her access to student
resources, and Tulane offers no real argument as to why these communications constitute
harassment.
Upon considering these communications, the Court finds that behavior of this nature is not
harassment but is instead Plaintiff expressing her confusion and frustration with simultaneously
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navigating pro se litigation and maintaining her access to student resources. The Court advises
Plaintiff to proceed with caution when using legal terms like “retaliation” in communications she
intends to be unrelated to the litigation.
However, such language and Plaintiff’s confusion should not automatically result in Tulane
employees redirecting Plaintiff’s emails to Tulane’s Counsel without answering what is within the
scope of their authority as Tulane employees. Such behavior further perpetuates the instant
communication issues. 	For 	example, 	an 	email 	regarding Plaintiff’s internal requests 	and
complaints with the university, such as FERPA requests or Equal Opportunity complaints, are not
to be redirected to Tulane’s Counsel. If Tulane employees are unsure what portions of Plaintiff’s
communications are separate from the litigation and within the scope of their authority to respond,
they should consult Tulane’s Counsel prior to redirecting the entire communication.
Second, Tulane presented another piece of “evidence” to the Court at oral argument. On or
around August 19, 2026, Plaintiff allegedly contacted Samantha Burns of Tulane’s Office of
Student Conduct to ask whether Tulane’s allegation of harassment against Plaintiff in the instant
Motion triggers a finding of harassment by the internal Office of Student Conduct. Plaintiff
allegedly expressed concern about a potential finding of harassment against her in her capacity as
a student without there ever having been an internal investigation or hearing.
Again, the Court finds that communications of this nature do not constitute harassment.
Like the Court’s advice to the Plaintiff, this Court advises Tulane to be careful with its use of legal
terms such as “harassment” in this litigation which may reasonably cause Plaintiff to believe
implicates her administrative rights in her capacity as a student.
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C) Plaintiff’s Ex Parte Communications
As a pro se litigant, Lewis is not exempt from complying with relevant procedural and
substantive rules, including the Federal Rules of Civil Procedure, this District’s Local Rules, and
the Louisiana Rules of Professional Conduct. NCO Fin. Sys., Inc., 2008 WL 2277843, at *3.
Although Lewis is not a licensed and practicing attorney, she consents to proceed under these
Rules by representing herself in the instant litigation. See Birl, 660 F.2d at 593 (“One who proceeds
pro se with full knowledge and understanding of the risks involved acquires no greater rights than
a litigant represented by a lawyer . . . [r]ather, such a litigant acquiesces in and subjects himself to
the established rules of practice and procedure.”).
Along with its allegations of harassment and inappropriate communications, Tulane argues
that Plaintiff is abusing her status as a pro se litigant by participating in ex parte communications
in violation of Rule 4.2 of the Louisiana Rules of Professional Conduct.
To support this, Tulane attempts to draw comparisons to Eustice v. Louisiana Through Bd.
Of Supervisors of Louisiana State Univ., 2020 WL 3520298, at *8 (M.D. La. June 29, 2020). In
Eustice, the U.S. District Court for the Middle District of Louisiana granted the defendant-
university’s motion for sanctions and dismissed the plaintiff-student’s claims against the university
with prejudice due to the plaintiff’s abhorrent communications used to harass defense counsel. Id.
at *7.
Previously, the court had entered a protective order in favor of the defendant-university
which required the pro se plaintiff to halt all direct communications with university faculty and
administrators, and to route all communication to the defendant through defense counsel. Id. at *2.
The protective order was entered to protect university faculty members and administrators based
on plaintiff’s violations of the university Code of Student Conduct, including being placed on
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disciplinary probation, providing falsified academic records, and plaintiff’s arrest for cyberstalking
a fellow student with sexual advances. Id. at *1. However, the plaintiff used this instruction as an
excuse to harass and indirectly threaten defense counsel. Id. at *2.
The court focused on the plaintiff’s history of formally charged violations of university
rules and the sexually explicit nature of many of the communications sent to defense counsel and
an opposing party. Id. at *1, 3-5. The plaintiff also obtained personal information about defense
counsel, including personal phone numbers and emails of defense counsel, which he used to
indirectly threaten defense counsel by expressing his desire to personally sue defense counsel,
utilizing curses, referencing his “physique and bodybuilding regimen, his feelings toward women,
his ownership of weapons,” and sending nude images. Id. at *5-7. The court reasoned that
dismissal of the plaintiff’s claims was an appropriate sanction because of the severity of the
plaintiff’s violation of the court’s previous order for the plaintiff to communicate with defense
counsel rather than directly with the defendant. Id. at *7.
While Tulane did cite relevant law for the proposition that a pro se plaintiff may not use
their pro se status as a shield against following procedural and professional rules, the plaintiff in
Eustice is very distinguishable from Lewis. Id. at *8 (citing NCO Financial Systems, Inc. v.
Harper-Horsley, No. 07-4247, 2008 WL 2277843, at *3 (E.D. La. May 29, 2008) (internal citation
omitted). For one, the plaintiff in Eustice was charged with multiple violations of the university’s
Code of Student Conduct for plagiarism and lying about his academic record, and he was arrested
for cyberstalking another student. Id. at *1. Lewis has not been charged with any similar type of
violation of a Tulane internal rule, nor has she been arrested for stalking Tulane employees or
related people.
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Second, the plaintiff in Eustice was sending far more explicit, consistent, threatening
content to LSU defense counsel. Here, Lewis has sent lots of emails to Tulane’s Counsel and
previously refused to communicate with her, but Lewis now agrees to work with Tulane’s Counsel.
As to other Tulane employees, Lewis sent critical AI-artwork, which is certainly off-putting but
does not suggest any indirect threat of violence or harm. Third, the plaintiff in Eustice was subject
to sanctions for a previously issued protective order. Conversely, no formal order has been issued
by a court for Lewis to violate.
Despite this, Tulane is correct that Lewis should be directing all litigation-related questions
and inquiries to Tulane’s Counsel. See E.D. La. LR 83.2.7; La. Rules. Prof’l. Conduct R. 4.2. Rule
4.2 of the Louisiana Rules of Professional Conduct provides that unless the other lawyer consents,
a lawyer or pro se litigant shall not communicate about “the subject of the representation” with a
person the lawyer or pro se litigant knows to be represented by a lawyer in the matter. La. Rules
of Prof’l Conduct R. 4.2. As a represented organization, Rule 4.2 also extends to many of Tulane’s
employees. See id. Here, the “subject of the representation” necessarily includes the events at issue
in this litigation regarding Plaintiff’s Fall 2025 accommodation requests, including who had
authority over those requests, what the process was for assessing those requests, what information
was considered in assessing those requests, etc. Essentially, the “subject of the representation”
necessarily includes asking Tulane employees questions which could bear on the university’s
liability in Plaintiff’s instant litigation.
However, Tulane’s Counsel concedes that she instructed Plaintiff to communicate with
certain Tulane employees regarding her disability accommodations, and now Tulane argues that
Plaintiff has been exceeding the scope of that consent by asking questions related to the subject of
the instant litigation. Between July 31, 2026, and August 10, 2026, Plaintiff repeatedly
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communicated a list of questions to her Disability Resource Professional, Jessica Machado. See R.
Doc. 22-8; R. Doc. 22-9. Plaintiff asked about Machado’s exercise of independent professional
judgment regarding Plaintiff’s accommodation requests, for the identity of the individual who has
final authority to approve or deny her accommodations requests, the identity of who is responsible
for the review of her medical records in connection to her accommodation requests, and other
questions about Tulane’s internal process of administering and/or resolving students’ pending
accommodations requests. See R. Doc. 22-9 at 1-2.
The Court finds that Plaintiff’s questions are legal questions which relate to the subject of
the representation in violation of Rule 4.2 of the Louisiana Rules of Professional Conduct. La. R.
Prof’l Conduct R. 4.2. Particularly, the Court finds that Plaintiff’s questions relate more to the
issue of Tulane’s potential liability for Plaintiff’s ADA claims than such questions may relate to
the 	facilitation 	of 	Plaintiff’s 	current 	accommodation 	requests. 	Permitted 	disability-related
questions include anything that allows Lewis to function in the school as a student, including
attending class, studying, taking tests, etc. Anything else is litigation-related. The Court finds that
Plaintiff must separate her requests about the facilitation of her disability requests in her capacity
as a student from legal questions in her capacity as a pro se litigant.
Further, to ask legal questions of Tulane employees, Plaintiff must employ formal
discovery 	methods 	in 	accordance 	with 	the 	Federal 	Rules 	of 	Civil 	Procedure, 	including
interrogatories, requests for production of documents or things, and depositions. The Court
recommends that Plaintiff review Rules 26 through 37, which discuss the scope of discovery,
procedure to obtain discovery, and enforcement mechanisms for noncompliance. Plaintiff must
serve all discovery requests upon Tulane Counsel, not upon Tulane employees. See FED. R. C IV.
P. 5(b)(1).
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D) Plaintiff’s Designated Contacts
To prevent further communication issues between Lewis and Tulane, it is necessary for the
Court to outline the individual Tulane employees and non-employees that Plaintiff may contact.
Such designations will ensure that there is no further disturbance to Lewis’s access to disability
accommodations and support services in her capacity as a Tulane student and additionally will
clarify which individuals she should not contact because they are involved in the instant litigation.
First, previously, Tulane assigned Machado and Woodley—both of whom are witnesses in
the instant litigation—as resources for Plaintiff’s separate disability requests and support services.
Tulane’s Counsel concedes that she directed Plaintiff to communicate with Machado and Woodley
regarding her current disability accommodations but argues that Plaintiff has taken to demanding
that these employees answer interrogatory-style questions related to her present lawsuit. R. Doc.
22-1 at 6.
As previously discussed, the Court finds that Plaintiff’s questions directed to Machado and
Woodley between July 31 and August 10, 2026, are legal questions related to the subject of the
instant litigation and thereby constitute inappropriate ex parte communications in violation of La.
R. Prof’l Conduct R. 4.2. See R. Doc. 22-8; R. Doc. 22-9. However, given Machado and Woodley’s
involvement as key witnesses in the instant litigation, it was inappropriate for Tulane’s Counsel to
permit Plaintiff to communicate with them about non-litigation related matters in the first place,
especially given Tulane’s Counsel’s knowledge of the history of communication issues between
the parties.
Further, because Machado is a key witness in Tulane’s case, and because the lines therefore
become murky as to whether certain questions are disability-related or litigation-related, the Court
orders that Plaintiff be assigned a new Disability Resource Professional. At oral argument, the
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Court facilitated the assignment of Angela James, a non-witness, to serve as Plaintiff’s DRP.
Plaintiff may further direct disability-related questions to Ms. James, but she should proceed with
caution to avoid asking Ms. James legal questions.
Next, regarding Plaintiff’s concern about being restricted to specific case management and
victim services personnel, Tulane assigned Plaintiff two case managers—Woodley and Kyle
Pearson, Director of Tulane’s Case Management & Victim Support Services (“Pearson”)—to
provide victim support services to Plaintiff in connection to an unrelated criminal matter in which
Plaintiff is a victim-witness. Plaintiff believes that her request to be reassigned to a different case
manager is an accommodation request. As to Pearson, Plaintiff contends that she would be more
comfortable being assigned a female case manager given the sensitive nature of the criminal matter
in which she will be testifying. The Court finds Plaintiff’s concern to be legitimate.
Further, the Court finds that Tulane’s alternative offer of Woodley is not appropriate
because Plaintiff has initiated a separate, ongoing equal opportunity complaint in which Woodley
is a respondent, thereby making Woodley’s assignment as her case manager a conflict of interest.
Tulane contends that there are no other qualified personnel available to provide Plaintiff adequate
support, and the Court agrees. The Court has connected Plaintiff with Hannah Blalock at the New
Orleans Family Justice Center to coordinate non-university affiliated victim support services.
Finally, as a student, Plaintiff is entitled to remain in communication with her current
professors, and/or research assistants regarding her current classes and coursework, and employees
responsible for class scheduling. Plaintiff may remain in contact with the following Tulane
employees, as identified by Plaintiff at oral argument: Professor Mark Melasky, Professor
Stephanie Mease, Mr. Robert Sanchez, and Dr. Dennis Bondar. To the extent that these professors
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change, the Court asks that Plaintiff provide a list of names to the Court and to Tulane’s Counsel
to ensure that such individuals are in the zone of proper communication.
There are two professors who Plaintiff should not communicate with due to their status as
witnesses in the instant litigation. Specifically, Plaintiff will not communicate with Dr. Ryan
Glasser or Dr. John Perdew because they were both her professors in the Fall 2025 semester at
issue in this litigation, and they may be called as witnesses by Tulane.
E) Frequency of Plaintiff’s Communications
Tulane requests that Plaintiff be limited to no more than one communication with Tulane’s
Counsel per day in which Plaintiff must express all thoughts and inquiries. Tulane contends that
this request was made as a precaution to prevent Tulane’s Counsel from getting “20 emails an
hour” from Plaintiff but does not point to any example in which Plaintiff initiated communications
at this frequency and quantity.1
The Court finds Tulane’s request to be too restrictive and declines to impose any specific
limit on the frequency and quantity of Plaintiff’s communications to Tulane’s Counsel. However,
given the clarifications provided by this Order regarding who Plaintiff may contact about what,
communications directed or redirected to Tulane’s Counsel should be less frequent overall.
Plaintiff agrees to communicate with Tulane’s Counsel regarding the instant litigation.
IV. 	Conclusion
IT IS ORDERED that the Defendant's Motion for Protective Order (R. Doc. 22) is
GRANTED in part and DENIED in part.
1 The Court understands that Tulane is likely referring to an email sent to Plaintiff by Tulane’s Counsel on March 27,
2026, in which Tulane’s Counsel attempted to address Plaintiff’s “several emails” regarding which Tulane employees
Plaintiff may communicate with, Plaintiff’s FERPA requests, setting up a meeting with Tulane’s sexual misconduct
response team, and whether Tulane’s Code of Student Conduct is a binding contract. R. Doc. 22-4 at 1.
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IT IS GRANTED to the extent that Plaintiff shall not communicate inappropriate AI-
generated images to Tulane employees or Tulane’s Counsel for the remainder of this litigation.
IT IS FURTHER GRANTED to the extent that Plaintiff shall not participate in ex parte
communications related to the subject of this litigation with Tulane employees in violation of Rule
4.2 of the Louisiana Rules of Professional Conduct.
IT IS FURTHER GRANTED to the extent that Plaintiff shall not communicate directly
with Tulane employees designated in this Order as witnesses for the remainder of this litigation.
IT IS DENIED to the extent that Plaintiff is otherwise permitted to communicate with
Tulane employees regarding non-litigation-related matters, subject to limitations laid out in this
Order.
IT IS FURTHER DENIED to the extent that Tulane employees with whom Plaintiff is
permitted to communicate shall not automatically redirect Plaintiff’s non-litigation-related
communications to Tulane’s Counsel if such communications are within the scope of their
employment.
IT IS FURTHER DENIED to the extent that Plaintiff’s communications to Tulane
employees and Tulane’s Counsel do not constitute harassment.
IT IS FURTHER DENIED to the extent that the frequency and quantity of Plaintiff’s
communications to Tulane’s Counsel shall not be limited.
New Orleans, Louisiana, this 16th day of October 2026.
KAREN WELLS ROBY
UNITED STATES MAGISTRATE JUDGE
Case 2:26-cv-01001-SM-KWR Document 44 Filed 10/16/26 Page 18 of 18