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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

__________________________________________ ) RAKESH KUMAR, Ph.D. ) 1881 N. NASH STREET, #1802 ) ARLINGTON, VA 22209 ) ) Civ. No. 1:15-cv-00120 Plaintiff )

) COMPLAINT v. )

) )

GEORGE WASHINGTON UNIVERSITY ) SERVE: MARY LYNN REED ) 2100 PENNSYLVANIA AVENUE, NW ) SUITE 250 ) WASHINTON, DC 20050 )

) Defendant )

__________________________________________)

COMPLAINT

COMES NOW Dr. Rakesh Kumar (“Dr. Kumar” or “Plaintiff”), and states his Complaint

against George Washington University (“GW” or “Defendant”) as follows:

THE PARTIES

1. Dr. Kumar is and at all times herein mentioned was, an individual residing in the

state of Virginia. Dr. Kumar is Professor of Biochemistry and Molecular Medicine in the

Department of Biochemistry and Molecular Medicine at GW’s School of Medicine and Health

Sciences. Dr. Kumar resides at 1881 North Nash Street, #1802, Arlington, Virginia, 22209.

2. GW is an academic institution of higher education authorized to conduct business

and conducting business in the District of Columbia with its principal place of business located

Case 1:15-cv-00120-JDB Document 1 Filed 01/23/15 Page 1 of 29





























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