Full opinion text
MEMORANDUM OPINION COLLEEN KOLLAR-KOTELLY, United States District Judge Plaintiff Mohammad Javad Hajjar-Ne-jad brings this action pro se against the George Washington University, principally challenging his dismissal as a medical student from GWs School of Medicine and Health Sciences in July 2007. Presently before the Court is Defendant’s [154] Motion for Summary Judgment. Upon consideration of the pleadings, the relevant legal authorities, and the record as a whole, the Court GRANTS Defendant’s [154] Motion for Summary Judgment. Accordingly, this action is DISMISSED WITH PREJUDICE in its entirety. I. BACKGROUND A. Factual Background Defendant the George Washington University (“GW” or “Defendant”) is a private, not-for-profit, university located in Washington, D.C. Def.’s Ex. 1 (Goldberg Deck) ¶ 3. It offers an M.D. degree through its School of Medicine and Health Sciences (“Medical School”). Id. ¶ 4. Plaintiff Mohammed Javad Hajjar-Nejad (“Hajjar-Nejad” or “Plaintiff’) was an M.D student in Defendant’s Medical School from August 18, 2004 until July 26, 2007. Pl.’s Facts ¶ 5. On November 7, 2003, Plaintiff signed an Offer of Acceptance form provided by Defendant confirming his decision to attend GW’s Medical School. Def.’s Ex. 3 (Hajjar-Nejad Dep. Exhibits), Ex. 36 (Offer of Acceptance). Plaintiffs Third Amended Complaint presents his race as “Arabic or Middle Eastern,” his religion as “Muslim,” and his national origin as “Iranian” (the nationality of his parents). TAC ¶ 7. The standard curriculum for M.D. students at GW’s Medical School spans four years, with the first two years focused on classroom instruction in the basic sciences and the final two focused on clinical clerk-ships and electives. Def.’s Ex. 4 (Schroth Deck) ¶¶ 3-5. When Plaintiff was an M.D. ■student, GW also ran an alternative curriculum for third-year students — referred to as the “third year honors curriculum.” Id. ¶ 6. This Honors curriculum varied from the standard curriculum in the distribution of time spent in the inpatient and outpatient clinical settings. Id. ¶ 7. Honors curriculum students also had to perform a special project, which could include such things as basic science research, clinical research, community service, medical humanities research, health policy research, and international health research. Id. ¶¶8-9. During the 2006-2007 academic year, W. Scott Schroth, M.D., M.P.H., Senior Associate Dean for Academic Affairs, (“Dean Schroth”) ran the Honors curriculum. Id. ¶ 1, 13. Plaintiff applied to the Honors curriculum for his third year, and on April 22, 2006, Dean Schroth notified Plaintiff that he had been selected for the program after a review of applications by a committee of nine faculty members. Pl.’s Ex. 12 (Honors Curriculum Acceptance Email). Plaintiffs special project as part of the Honors curriculum involved research into cardiovascular disease. Pl.’s Ex. 8 (Plaintiffs MSEC Statement) at 147-52. Plaintiffs first rotation, or “clerkship,” in the Honors curriculum was internal medicine, which was headed by Dr. Robert Jablonover and ran from July 7, 2006 to August 11, 2006. Def.’s Ex. 3, Ex. 14 (Subcommittee Minutes of May 30, 2007) at 1. On July 25, 2006, during this clerkship, Plaintiff sent an e-mail to Dr. Jab-lonover, reporting an alleged “recent difficulty” Plaintiff was experiencing with a resident who supervised his work. Def.’s Ex. 3, Ex. 4 (July 25, 2006 E-mail) at 1. Plaintiff complained the “tone, manner, and actions” of this resident were “very unprofessional and coercive.” Id. at 1. Plaintiff also detailed several disagreements with this resident, whom he felt was interfering with his education. Id. at 1-2 (“[A] learning environment should be positive and conducive to student learning. This resident has become an obstacle to this.”). Dr. Jablonover replied to Plaintiffs e-mail the same day stating “thank you for your message and for bringing this to my attention. It would be difficult for me to meet today at 1:30; would 4:30 be okay today?” Def.’s Ex. 3, Ex. 8 (Jab-lonover-Schroth E-mail Exchange) at 2. Based on e-mails in the record, Dr. Jab-lonover apparently met with Plaintiff regarding his concerns with this resident and e-mailed other doctors asking them to “meet with [this resident] to anonymously discuss [Plaintiffs concerns] ... and to help provide her with some feedback and guidance re: her interactions with students and her role as a teacher.” Id. On August 23, 2006, Dr. Jablonover sent an e-mail to Dean Schroth which set out the details of Plaintiffs evaluation for the internal medicine clerkship. Id. at 1-2. This e-mail states that Plaintiffs “overall performance grade was 2 (low pass)” and identifies the following issues with Plaintiffs performance: “[d]id not always seem to complete reading assignments; average knowledge base; sometimes focuses on basic sciences without necessarily applying the information clinically to the patient”; “[s]ometimes had difficulty generating differential diagnosis; did not always focus on/prioritize clinical duties”; “[s]ometimes not prepared with his patients’ information; now [sic] always present on rounds • (intermittent); did not seem to appreciate opportunities inherent in hands-on learning; resistant to feedback sometimes; sometimes defensive when given constructive feedback”; “[s]ometimes seemed uncomfortable talking with patients, which sometimes made therapeutic relationships difficult; sometimes gowned and gloved when not appropriate clinically.” Id. This evaluation did also note positive aspects of Plaintiffs performance in the rotation, with Dr. Jablonover stating “he did present in student conference with me an excellent resident-level Powerpoint presentation.” Dr. Jablonover also specifies in this e-mail that he met with Plaintiff about his grade and “explained to [Plaintiff] that [he] was presenting information given to [him] second-hand [by other doctors supervising Plaintiff] and that there are always two or more sides or perspectives to an issue.” Id. In response, Dr. Jablonover notes that during this discussion “he seemed to counter each point and was defensive throughout.” Dr. Jablonover concluded his e-mail to Dean Schroth by noting, “I don’t think the problem is one of academics but more one of attitude. I’m concerned that [Plaintiff], while being very motivated, is often seems [sic] quite resistant and closed to constructive feedback. I encouraged him to be more open to suggestions given to him by others who are farther along in their training and to discuss with them in a constructive manner any disagreements that might arise.” Id. Dr. Jablonover also noted that Plaintiff would likely be interested in challenging his grade. Id. Dean Schroth replied to this e-mail stating that he was scheduled to meet with Plaintiff that Friday. Id. at 1. He also provided background on the process for student complaints regarding grading. Id. Neither party cites evidence in the record of any e-mail communication between Dean Schroth and Dr. Jablonover regarding Plaintiff that occurred prior to this exchange. On August 25, 2006, Dean Schroth sent an e-mail to Dr. Jablonover and another physician, Dr. Samantha McIntosh, summarizing his August 25, 2006 meeting with Plaintiff: [H]ad a very interesting discussion with [Plaintiff] today. [Although I think his agenda all along related to his concerns about his evaluation, he spent the first 10 minutes explaining how he wanted to work with me on the medical center strategic plan to improve teaching at the medical school. [H]e has some good points and I appreciate his interest in quality improvement. [H]owever, all of this obviously came out of his experience in medicine. I’ll reflect back to you what he was concerned about. [F]irst, he sees his weak evaluation as a ‘grudge’ by the department because he did not get along with the resident and leveled criticisms at the department and the clerkship director. [H]e felt like rounds were too long, not focused much on education per se (more on just getting clinical tasks done) and had little bedside teaching. [H]e was concerned that he was rarely observed taking a history or physical exam (he’s probably right on this one, to which [I] agreed). [H]e denied being difficult at times, ascribing this to one misunderstanding with his resident who paged him to come perform a rectal exam and then was not there when he showed up. [H]e went off to do something else and then got ‘yelled’ at for not being there. [H]e implied that he’d had little feedback about his performance during the 6 weeks. [H]e was fairly dismissive of his meetings with [R]obert, implying that you were contradictory in your advice and poorly informed about his fund of knowledge and work habits. [I] think I can see how he got himself into this situation. [H]e is very rigid, and his interaction style, although polite on the surface, is not collaborative but rather confrontational and critical. [I] reflected this back to him in those exact terms because he was making me feel defensive and uncomfortable, but [I]’m not sure he’s hearing me either. [I]n the end, [I]’m not sure we got very far. [H]e will challenge his evaluation and follow our regs. [I] told him that if he didn’t like your decisions he could go to [W]asserman, and then to the [D]ean’s office if he wants. [I]t will be interesting to see how he does on other rotations. [I] told him point blank that [I] thought he needed to be more introspective about his interpersonal style and think about how he interacts with others. Def.’s Ex. 3, Ex. 12 (Written Statement to MSEC), Ex. 2. Plaintiff next proceeded to his surgery-clerkship, which ran from August 14, 2006 to September 22, 2006. Def.’s Ex. 3, Ex. 24 (Askari Surgery Evaluation). Dr. Juliet Lee was the clerkship director for the surgery clerkship and Dr. Reza Askari was a senior resident in this rotation. Def.’s Ex. 6 (Askari Decl.) ¶ 4; Def.’s Ex. 7 (Lee Decl.) ¶ 1. On September 21, 2006, Dr. Lee sent an e-mail to Dean Schroth expressing concerns regarding Plaintiffs performance in the surgery clerkship. This e-mail reads: I have to let you know about one of the students in the new curriculum, [Plaintiff]. He has really struggled throughout the six weeks and my major concern is that he lacks insight into his own deficiencies and has progressed minimally throughout the rotation in his clinical judgment and understanding. I have been following his progress over the last several weeks with the residents and they are at their wit’s end with him. [REDACTED] They give him almost daily feedback about his performance and the Chief resident has been giving him weekly formal feedback. Despite all efforts, he has not made any strides.... He also has been noted to wander off from the rotation for a few hours at a time, saying he has medical appointments to one person and then giving another story to another member of the team. As far as I know, he was only excused by me for one medical appointment. He also mentioned that he had to go do some lab work. If he has some work that he is performing for his project and using surgery clerkship time to do it, I am not going to tolerate it. He also told the residents that he has a medical condition which requires him to eat frequently. While this is OK to get something to eat, it shouldn’t take three hours.... In terms of his book knowledge, he is doing fine. But none of this information has been translated to patient care or clinical medicine. I am seriously concerned about him and his ability to function. From the residents[’] standpoint, they would not want [Plaintiff] taking care of them. My understanding from them and the attendings is that he will likely get a low pass for his clinical rotation in Surgery. With the changes in the grade points for the new curriculum students, he would be at a -A for his total points. Failing the clerkship is -7 points. While I think he might pass overall based on exams, I think his clinical skills are far behind what we expect of third years. Def.’s Ex. 3, Ex. 19 (Lee-Schroth E-mail Exchange). Dean Schroth replied to Dr. Lee’s e-mail with the following: [T]his is 100% consistent with the information that we received from his first rotation, the medicine clerkship, who also gave him a low pass (and lots of feedback that he resists). [I] have met with [Plaintiff] repeatedly. [H]e lacks insight into his deficiencies I’m afraid. [I] would urge you and the residents to strongly consider whether his performance is indeed ‘passing’ or not. [T]eeh-nically, a low pass is still a pass, and he will move on through the curriculum. [I]f you really think that he has serious clinical performance deficiencies, a below passing grade (eg. [sic] conditional or fair) will bring this to a clear ‘head’ and allow us to work with him on remediation efforts. [H]e is very bright and very ‘book’ smart, but he has trouble functioning in the clinical environment, difficulty working as part of a team, and lacks insight into these problems. [I] see that he is scheduled to meet with me again next week. [P]robably about this issue [I] suspect. Id. There is no evidence in the record of any e-mail communication between Dean Schroth and Dr. Lee regarding Plaintiff that occurred prior to this exchange. In addition, Dean Schroth states that he did not intend his e-mail as a directive to give Plaintiff a below passing grade, Def.’s Ex. 4 ¶ 17, and Dr. Lee states that she did not perceive it as such, Def.’s Ex. 7 ¶ 5. Plaintiff also received a negative evaluation for the surgery clerkship from Chief Resident Reza Askari. In this evaluation, Askari states “[t]here were several instances in which there appeared to be inconsistencies in the information [Plaintiff] provided to the members of the team. He often told members of the team varying stories as to his whereabouts and the need to be elsewhere.” Def.’s Ex. 3, Ex. 24 at 3. Dr. Askari noted that these “several instances of untruthfulness, raise[] doubts as to adherence to ethical principles” and “[Plaintiffs] lack of ethical integrity toward the members of the team and his colleagues makes his overall performance unacceptable.” Id. at 4, 6. Askari did note that Plaintiff was “educationally motivated, did ask for repeated feedback and wanted to improve, however while he made a small amount of progress, the lack of adherence to ethical principles hurt his overall performance.” Id. at 5. Plaintiff alleges that at one point during his surgery clerkship, he asked Dr. Askari to eat breakfast with him. Def.’s Ex. 2 at 272:4-19. According to Plaintiff, Dr. As-kari replied “I don’t eat with your kind.” Id. Defendant disputes that this statement was ever made. Def.’s Facts ¶ 37. Plaintiff concedes that both he and Dr. Askari are of Iranian descent. Pl.’s Facts ¶ 33. He alleges that Dr. Askari is a member of the Baha’i faith, and argues that this statement shows Dr. Askari’s discriminatory purpose in negatively evaluating Plaintiff. Def.’s Ex. 2 at 272:15-19. However, there is no evidence in the record that Askari is a member of the Baha’i faith, and in his deposition, Plaintiff recognized that his belief that Askari is Baha’i is speculation. Id. at 263:22-264:9. Dean Schroth met with Plaintiff on September 25, 2006, as he said he planned to in his email to Dr. Lee. Def.’s Ex. 4 ¶ 18. Prior to this meeting, on September 22, 2006, Plaintiff submitted to Dean Schroth a document entitled “Motion for Injunctive Relief of Incorrect/Wrong Evaluation and for Development of an Active Task Force Committee.” Def.’s Ex. 2 at 85:17-86:18; Def.’s Ex. 3, Ex. 5 (Plaintiffs Motion) at 1; This fifteen page document is styled as a legal brief, and includes a case caption which states “MJ HAJJAR-NEJAD, MSI-II, Complainant, Vs. Department of Medicine, Respondent.” Def.’s Ex. 3, Ex. 5 at 1. In its introduction, the document “requests the overturning of the evaluation by the Department of Medicine and, more importantly and essentially, for the creation of an active task force committee composed of students, administrators, deans, and hospital officials for the coordination and implementation of our goals and objectives as spelled out so explicitly in the University strategic plan.” Id. In this document, Plaintiff appears to take issue with the setup of the clinical curriculum as well as his grade in the internal medicine clerkship. Id. at 14-15. According to Dean Schroth’s private memo regarding the September 25, 2006 meeting, he discussed Plaintiffs appeal of his medicine grade as well as the concerns raised by Dr. Lee regarding Plaintiffs surgery clerkship. Def.’s Ex. 4, Ex. A (Schroth Memo of Sept. 25, 2006 Meeting) at 1. In this memo, Dean Schroth states: [Plaintiff] continues to be defensive and shows no insight into the fact that he is having these problems. [H]e blames everything on residents who don’t teach well, are ‘unethical’ and uninterested in patient care or student learning. I told him point blank that he needs to stop doing his research on the side, and focus on what is causing these problems in his performance. [I] plan to remove him from the honors curriculum and [I] told him this. [I] will gather some more information about his performance from the medicine and surgery teams. [H]e is staring [sic] OB at [Holy Cross Hospital] today. Id. Plaintiff disputes that Dean Schroth told him to discontinue his research at the September 25, 2006 meeting. Pl.’s Facts ¶ 50. Plaintiff next proceeded to his obstetrics and gynecology clerkship, which ran from September 25, 2006 to October 20, 2006. Def.’s Ex. 3, Ex. 27 (Gaskins Evaluation) at 1. Plaintiff also received negative evaluations in this rotation. Dr. Sherita Gaskins, a clinician in the obstetrics and gynecology clerkship, raised concerns regarding Plaintiffs conduct during the clerkship. Id. “[P]laintiff consistently left morning sign outs before they were over. His fellow students complained that he refused to assist them in the morning rounds (which is a requirement for all students).” Id. at 3. As one of several examples of her concerns regarding Plaintiffs truthfulness, she stated that “[Plaintiff] misrepresented Dr. Mufarrij, the site director, by telling me that he had Dr. Mufarrij’s permission to take the afternoons off to study during the last week of the rotation. When Dr. Mufarrij and I compared notes, he informed me that this was not the case. [Plaintiff] had not spoken to him about taking time off.” Id. at 2. Dr. Gaskins concluded her evaluation by stating: [Plaintiff] is undoubtedly a very intelligent, ambitious student, but we as a group had very serious concerns regarding his very unprofessional behavior. He openly lied to us on more than one occasion and he refused to pull his weight with regard to patient care. Integrity is one of the cornerstones of our profession and the strong lack of it demonstrated at this early stage of [Plaintiffs] career is very disturbing. Id. at 5. Obstetrics and gynecology attending physician Dr. Joel Palmer also gave Plaintiff a negative evaluation, stating that he “appears to find the easy way out of doing work” and “has on several occasions left before the recommended time for students to be here in the hospital.” Def.’s Ex. 3, Ex. 28 (Palmer Evaluation) at 2. Dr. Palmer stated that Plaintiff '“[n]eeds to be informed that there is a requirement for physicians or physicians in training to be truthful and cooperative with the other physicians he works with.” Id. at 4. Subsequently on October 18, 2006, Dr. Lee e-mailed Dean Schroth a -letter prepared by Dr. Askari discussing concerns with Plaintiffs “professionalism and integrity.” Pl.’s Ex. 22 (Plaintiffs Appeal to Vice President for Academic Affairs) at 97. In her e-mail, Dr. Lee stated, “[a]s we discussed before, [Plaintiff] had much difficulty on the surgical rotation on a number of issues. I think the residents and at-tendings tried very hard to work with him.” Id. The letter from Dr. Askari states that Plaintiff “lacked the ability to synthesize ... information into useful assessments and clinical plans.” Def.’s Ex. 6, Ex. B (Askari Memorandum) at 1. “With relation to his behavior towards other members of the team, there were problems as well. I had several complaints by the other student of the team as -to the unfair distribution of eases, which eventually led me to assign the daily cases myself and no longer left it up to the students to pick.” Id. Dr. Askari closed his letter with the following: However, my biggest problem with [Plaintiff] relates to his adherence to honesty and ethical principles. As the rotation continued it started to become apparent that [Plaintiff] was often telling .different members of the team, including myself and our attending staff different stories as to his whereabouts during parts of the day (examples of his need for a dental appointment for which he never went to, or the need to get a loan to pay for his dental visit).... It appears that while on the surface [Plaintiff] was motivated, on repeated attempts he failed to show improvement in his clinical assessments and most importantly he lacked honesty and integrity and failed to show adherence to basic ethical principles. I am thereby unable to pass him for his surgical clinical rotation. Id. at 1-2. Dean Schroth responded to Dr. Lee’s e-mail containing Dr. Askari’s letter by stating “this is very concerning. [S]o I assume this means he will receive at least a conditional (if not a fail) grade for the surgery clerkship? [I]f so, [I] need to know ASAP because it will mean that we must pull him out of the honors curriculum (!) and integrate him back into the standard curriculum.” Pl.’s Ex. 22 at 97. With regard to Dr. Askari’s e-mail, Dean Schroth asked “will reza’s evaluation be submitted as part of his formal surgery evaluation? [I] think it should be, and it may trigger a professional comportment committee review. [I] will go over it with the other deans.” Id. Later that same day, October 18, 2006, Dean Schroth e-mailed Plaintiff requesting that the two meet. Def.’s Ex. 3, Ex. 29 (Schroth October 18, 2006 E-mail). This e-mail read: [W]e need to talk this week. I am waiting on the final word from surgery, but it looks like you “will not pass the surgery clerkship. [T]his means that we will have to mainstream you back into the regular curriculum. [W]e have a few options which we can discuss. [T]he immediate question is to decide what you will do next week: stay for another month of OB, or move to another clerkship (primary care and psychiatry both have room to accommodate you). [P]lease call the office. I have time to meet on Friday both in the morning or the afternoon. I know you are at HC now, so we can also do this by phone. Id. Plaintiff failed to respond, despite apparently being in the building where Dean Schroth’s office is located on October 20, 2006. Def.’s Ex. 4, Ex. B (Gebara Memorandum) at 3. On October 20, 2006, Dean Schroth sent Plaintiff another e-mail, with the subject line of “hello?”, again requesting that the two speak: [Plaintiff], you need to call me. [Y]ou will not be starting pediatrics on Monday. [Y]ou need to transition to the regular curriculum and pediatrics does not have room for you for two months. [Y]ou can start on psychiatry or primary care, but we need to talk about this right away. [H]arolyn [Johnson, an administrative assistant in the Dean’s office] has been trying to reach you all afternoon at home, cell phone, and at HC hospital. [W]e’ve paged you and called all the units at HC. I sent you a message two days ago, but you have not responded. CALL ME on my cell phone:.... I’ll have it on the rest of the day and most of the time over the weekend. Def.’s Ex. 3, Ex. 30 (Schroth October 20, 2006 E-mail). Plaintiff did not respond to this e-mail. Instead, on October 23, 2006, according to Defendant, Plaintiff reported for his pediatrics rotation. Def.’s Ex. 4 ¶¶ 23. Upon learning from the coordinator of this rotation that Plaintiff had done so, Dean Schroth had him sent to GW. Id. ¶24. Plaintiff states that he contacted Dean Schroth to set up an appointment on the morning of October 23, 2006. Pl.’s Facts ¶ 59. However, there is other evidence in the record that Plaintiff admitted receiving Dean Schroth’s emails and failed to respond to them. Def.’s Ex. 3, Ex. 14 at 2-3. In any case, Plaintiff met with Dean Schroth on October 23, 2006. Def.’s Ex. 4 ¶ 25. Also present for parts of this meeting were Dr. Jim Scott, Dean of the Medical School (“Dean Scott”), Dr. Yolanda Haygood, Associate Dean for Student and Curricular Affairs, and Plaintiffs parents. Id. During these discussions, Plaintiff was told that he would be receiving a below passing grade in the surgery clerkship, that he was being returned to the standard curriculum, and that he needed to focus on improving his clinical performance instead of doing research. Id. ¶ 26. Plaintiff asserts that at this meeting Dean Schroth also threatened that Plaintiff would be forced to take a leave of absence. Pl.’s Facts ¶ 67. Plaintiff also alleges that Dean Scott promised that the Medical School would take no further action against Plaintiff after removing him from the Honors curriculum. Id. At the same time, Plaintiff also contends that Dean Scott told Plaintiff that he would not allow Plaintiff to go into surgery as a profession and would place false performance appraisals on Plaintiff’s permanent file and transcript, so as to prohibit his transfer to any other medical school or graduate program. Id. The Court notes that in a document prepared by Leigh Anne Gebara, Executive Assistant to the Dean, memorializing the portion of the October 23, 2006 discussions that she attended, none of these allegations are supported. Def.’s Ex. 4, Ex. B. Further, in a letter Dean Schroth states that he sent to Plaintiff summarizing the October 23, 2006 discussion and the preceding events, there is no mention of a request that Plaintiff take a leave of absence, Dean Scott’s alleged vow not to pursue further action against Plaintiff, or Dean Scott’s alleged threats to keep Plaintiff from becoming a surgeon and bar his transfer. Id., Ex. C (Schroth Letter Summarizing October 23, 2006 Meeting). Ultimately, Plaintiff received the below passing grade of “conditional” in his surgery rotation based on the fact that he failed the clerkship’s clinical portion. Def.’s Ex. 3, Ex. 20 (Plaintiffs Surgery Evaluation). On December 27, 2006, Dean Schroth sent Plaintiff a letter informing him of plans to “form a Professional Comportment Subcommittee of the Medical School Evaluation Committee (MSEC) to investigate the numerous instances of unprofessional behavior reported in your clinical evaluations from the medicine, surgery, and obstetrics and gynecology clerkships completed earlier this semester.” Id., Ex. D (Schroth letter of December 27, 2006). This letter also provided Plaintiff with a copy of the Regulations for M.D. Candidates (“Regulations”) which governed the Professional Comportment review process. These Regulations set out procedures for evaluation of a student’s professional comportment, stating “[o]ccasionally, a student’s behavior, or pattern of behavior, may raise concerns as to the student’s suitability to continue in the study of medicine. The process described below is intended to deal with behavior that may be unacceptable to the School of Medicine and Health Sciences or raise questions about the student’s fitness for the practice of medicine.” Def.’s Ex. 3, Ex. 16 (SMSHS Bulletin) at 32. On February 20, 2007, Associate Dean Rhonda Goldberg sent Plaintiff an e-mail stating that she would be “facilitating [the] process” of forming the Professional Comportment Subcommittee. Def.’s Ex. 12 (Third Amended Complaint Exhibit) at 76. She further stated “I am to notify you about the composition of the Subcommittee and you are allowed ten days to object to any person’s appointment to the Subcommittee.” Id. Dean Goldberg then stated “[t]he Subcommittee I am proposing is” and listed four names. Id. Plaintiff responded to this e-mail on March 2, 2007. Id. at 77. In this e-mail, Plaintiff did not object to any specific member named in Dean Goldberg’s e-mail, but rather objected to the process by which he was removed from the Honors curriculum and the fact of the Subcommittee’s formation. Id. Dean Goldberg responded to this email on March 8, 2007 stating: My e-mail to you on February 20, 2007 was to request that you confirm that you have no objections to any of the proposed Subcommittee members. Since you did not object in your email, I will assume that all are approved and therefore I will set up a meeting to review your situation. Please understand that the purpose of the meeting is to discuss your behavior reported in your clinical evaluations from the medicine, surgery and obgyn clerkships. I am not clear about your reference to the Honors curriculum or the MSEC in your email. You will, of course, have an opportunity to talk with the Subcommittee and share your views. Id. at 78. On March 20 and 22, 2007, Dean Goldberg sent Plaintiff two additional emails advising him of two changes to the membership of the Subcommittee. Id. at 79, 80. She again requested that he e-mail her if he objected to either of these individuals. Id. Plaintiff replied on March 30, 2007 again objecting to the process by which he was removed from the Honors curriculum as well as the fact of the Subcommittee’s formation. Id. at 81. However, he did not specifically object to either individual mentioned by Dean Goldberg. On April 27, 2007, Plaintiff sent Dean Goldberg an e-mail raising various procedural objections in the formation of the Subcommittee and naming four alternative individuals Plaintiff proposed for the Subcommittee. Id. at 93-94. These objections to the individuals on the Subcommittee were untimely under the Regulations. In addition, on April 21, 2007, Plaintiff submitted to GW Dean of Students Linda Donnels a document entitled “Brief of Case Findings.” Def.’s Ex. 3, Ex. 6 (Brief of Case Findings). This document sets out, in outline form, various procedural errors that Plaintiff contends were committed in his dismissal from the Honors curriculum and in the initiation of the Professional Comportment Subcommittee. Id. On May 3, 2007, the Professional Comportment Subcommittee, consisting of two Medical School faculty members and two Medical School students, met to consider the issues raised with respect to Plaintiffs professional comportment. Def.’s Ex. 3, Ex. 13 (Minutes of Professional Comportment Subcommittee May 3, 2007 Meeting). Plaintiff was present and accompanied by • counsel. Id. According to minutes of the May 3, 2007 meeting, the Chair of the Subcommittee, Dr. Bernard Weidermann “explained that [the] meeting pertained to issues of comportment and was not a forum to address disagreements with grades per se.” Id. The Subcommittee then interviewed several individuals, including Plaintiff. Id. At this meeting, Plaintiff presented documents to the Subcommittee, which the Subcommittee “agreed to review.” The Subcommittee also agreed to “consider any questions [Plaintiff] may wish to submit....” Id. On May 4, 2007, Plaintiff e-mailed Dean Goldberg twenty-one proposed questions for the Subcommittee to consider in investigating his professional comportment. Def.’s Ex. 12 at 98-99. On May 30, 2007, the Professional Comportment Subcommittee met again. Def.’s Ex. 3, Ex. 14 (Minutes of Professional Comportment Subcommittee May 30, 2007 Meeting). According to minutes of this meeting, the members discussed the twenty-one questions proposed by Plaintiff and “agreed that all were focused on various procedural questions related to the comportment review process, rather than questions that would add further insight into the events in question.” Id. at 1. By way of example, the Subcommittee noted the following questions proposed by Plaintiff: “If Dr. Lee thought it was necessary to give me any instructions on performance, why did she not inform me in writing before she submitted her letter to the Deans at the very end of the clerkship?” Id. The Subcommittee then discussed “the key elements of concern for professional comportment.” Id. First, reviewing the evidence regarding Plaintiffs internal medicine clerkship, the Subcommittee found that although the concerns with Plaintiffs performance did “not directly speak to comportment issues ... [they] could reflect an interpersonal skills problem that also manifested itself in comportment concerns.” Id. Second, Plaintiffs surgery rotation was “a source of significant problematic reports” regarding Plaintiffs professional comportment. Id. at 1-2. The Subcommittee also found “significant concerns about [Plaintiffs] comportment on the next clerkship in obstetrics and gynecology....” Id. at 2. The Committee also was concerned by Plaintiffs failure to respond to Dean Schroth’s request for a meeting in October 2006: During questioning in the Subcommittee meeting on May 3, [Plaintiff] admitted that he had received Dean Schroth’s messages, but preferred to study for his obstetrics exam scheduled for October 20 rather than focus on the message. However, [Plaintiff] could not offer a credible answer as to why he did not contact Dean Schroth after the exam was completed, well before starting the pediatrics rotation. Rather than answer direct questions to explain his thought process over these days, he kept returning to the fact that he needed to complete his exam. This type of response to direct questioning astonished some Subcommittee members and seemed to support the idea that [Plaintiff] was either directly manipulative or simply unable to process information and respond in a direct fashion, perhaps due to some basic deficit in interpersonal skills. Id. at 2-3. The Subcommittee found that, taken as a whole, “the documents and discussions point to some central themes extending over these clerkships.” Id. at 3. First, “[t]here were numerous instances of misunderstandings regarding [Plaintiffs] absence from clinical duties, all associated with his working on research projects, studying for exams, or attending to personal issues. To this end, he at least worked to manipulate the system to his advantage.” Id. Second, “he appears to have difficulty functioning as a team member with a purpose other than making the best possible grade, and this harms his relations with team members.” Id. Third, “rather than seeking to improve his performance by examining his own behavior, he instead seems inclined to externalize this information to blame others, rather than himself, for all issues. He focuses on grading system process rather than on working to understand how he can improve.” Id. Finally, the Subcommittee found that Plaintiffs “behavior during the comportment review process itself seems to confirm the concerns of his clerkships. Most concerning was his reaction to direct pleas from Dean Schroth in late October to meet with him and develop a new plan for third year.... ” Id. Furthermore, “[throughout numerous emails to plan the comportment hearing, he continued to avoid answering direct questions about the composition and scheduling of the comportment hearing, choosing instead to argue about process. This mode of response was vividly apparent during his attendance at the May 3 meeting as well as his list of follow-up questions which did not address the specific issue of clarifying his actions as requested.” Id. Based on these findings, the Subcommittee issued the following conclusion and recommendations: The Subcommittee members have serious concerns regarding [Plaintiffs] comportment and his ability to function as a physician. We are concerned that he may do well in classroom, standardized tests, and one-on-one interactions, but he appears to need work in synthesizing information into valid differential diagnoses and treatment plans, and he has displayed serious difficulties in working as a team member focused on patient care rather than on individual performance. We believe he should expend a great deal of effort in trying to understand his own interpersonal interaction modes and how that relates to becoming an effective physician. We therefore recommend the following: 1. He must repeat any clerkship for which he receives a grade of low pass or below. 2. Even if he receives passing grades subsequently, the Subcommittee Chair must review his clerkship evaluations when he has completed all clerkships to look for comportment-related issues, and if less than satisfactory will refer to the Medical Student Evaluation Committee for investigation. 3. Following successful completion of all his third-year clerkships, he must complete an acting internship in internal medicine at George Washington University hospital, as soon as possible in his fourth year. This rotation was recommended because of the likelihood that he will have reliable supervision and observation in a complex medical setting. 4. The Subcommittee minutes shall become part of his permanent record. 5. He is encouraged to spend time reflecting on his evaluations and difficulties in these rotations and consider a leave of absence to attend to these details .optimally. He may wish to seek further resources and assistance through the dean’s office to help him improve in these areas. Id. at 3-4. Pursuant to the Regulations, the Subcommittee referred Plaintiffs professional comportment review to the Medical Student Evaluation Committee (MSEC), consisting of faculty members and medical school students. See Def.’s Ex. 3, Ex. 16 at 33. The MSEC met to consider Plaintiffs case on June 18, 2007. Def.’s Ex. 3, Ex. 33 (Letter from Akman to Scott). Plaintiff was present and accompanied by counsel. Id. Based on a letter summarizing this meeting, Bernard Weid-ermann, the Chair of the Subcommittee, presented the Subcommittee’s findings and recommendations and answered questions from the MSEC members. Id. Plaintiff answered questions from the MSEC, and was provided the opportunity to make an oral statement to the MSEC and to submit a written statement after the meeting. Id. Next, according to the summary of its proceedings, the MSEC met in executive session on July 9, 2007 to consider Plaintiffs written statement and to conclude its deliberations on the matter. Id. As summarized in the MSEC Chair’s letter to Dean Scott: A motion was made and seconded to accept the Professional Comportment Subcommittee’s report and recommendations. Serious concerns were raised about [Plaintiffs] professionalism, honesty and integrity, his interpersonal relationships and his capacity to work with others. Of particular concern, were the following: [Plaintiffs] inability to accept responsibility for his own actions; refusal to accept instructions or constructive feedback from residents, faculty and deans; inability to work and communicate effectively with peers and residents; inadequate understanding of the commitment to and responsibility for patient care; lack of insight into personal weaknesses and areas for improvement; and, inappropriate understanding of the role of a medical student in the medical education hierarchy. In addition, the Committee noted that these concerns were not the result of an isolated incident, but appeared to be a pattern in most interactions with [Plaintiff]. The motion to accept the Subcommittee’s report failed to pass by a vote of zero (0) in favor of the motion, ten (10) against, with zero (0) abstentions. The Chair did not vote. A motion for dismissal from the MD Program was made and seconded. There was further discussion regarding the issues above as they related to [Plaintiffs] suitability to practice medicine. In a secret ballot vote, the motion passed by a vote of nine (9) in favor of the motion, zero (0) against the motion, with one (1) abstention. The Chair did not vote. Id. at 2. The MSEC’S recommendation of dismissal was forwarded to Dean Scott, pursuant to the Regulations. Id. at 2; Def.’s Ex. 3, Ex. 16 at 34. Dean Scott met with Plaintiff on July 17, 2007. Def.’s Ex. 3, Ex. 34 (Letter from Scott to Plaintiff). On July 26, 2007, Dean Scott sent Plaintiff a letter stating the following: As you know, the School of Medicine and Health Sciences has initiated a professional comportment proceeding regarding your conduct. Under the Regulations for M.D. candidates, my job is to decide whether to dismiss you from the M.D. Program or allow you to remain. In making that decision, I have carefully considered our July 17, 2007 discussion, the Professional Comportment Subcommittee’s findings and recommendations, the Medical Student Evaluation Committee’s report, and all other materials contained in your confidential file, which includes everything submitted to the MSEC. The MSEC has recommended that the School of Medicine and Health Sciences dismiss you due to your unprofessional comportment. I concur with the MSEC’S recommendation. Accordingly, I have decided to dismiss you from the M.D. Program effective immediately. The Regulations for M.D. Candidates permit you to appeal my decision, within 15 calendar days, to the Vice President for Academic Affairs. Please consult the Regulations for information regarding the basis and procedure for an appeal. Id. Based on this letter, Plaintiff was dismissed from the Medical School on July 26, 2007. Plaintiff appealed his dismissal to Donald Lehman, Ph.D., GW’s Executive Vice President of Academic Affairs on August 7, 2007. Def.’s Ex. 13 (Sigelman Decl.), Ex. A (Plaintiffs Appeal of Dismissal). Lehman delegated the matter, for a decision, to Carol Sigelman, Associate Vice President for Graduate Studies and Academic Affairs. Id., Ex. B (Letter from Lehman to Sigelman). Under the Regulations, “[t]he scope of this appeal is for the vice president for academic affairs or his/ her designee to determine whether the procedures set forth in these Regulations have been followed.” Def.’s Ex. 3, Ex. 16 at 34. On September 13, 2007, Sigelman sent Plaintiff a letter stating: I have thoroughly reviewed the entire written record of the proceedings, including the student’s confidential file and submissions to the Subcommittee on Professional Comportment and the Medical School Evaluation Committee (MSEC), as well as the submissions made by [Plaintiffs counsel] Mr. Zaidi. to Dr. Lehman on [Plaintiffs] behalf. I focused my review on Section E of the Regulations, Evaluation of Professional Comportment, because the matter at hand concerns dismissal from the program as a result of comportment issues. Based on the written record of the proceedings, I have reached the conclusion that the procedures set forth in the regulations for MD Candidates have been followed. Therefore, I sustain the decision of the Dean of the School of Medicine and Health Sciences in the case of [Plaintiff]. Def.’s Ex. 3, Ex. 35 (Sigelman Letter to Plaintiff). Plaintiff claims that on August 9, 2007, during a meeting with Stephen Trachten-berg, the former President of GW, Tra-chtenberg told Plaintiff that, in light of his dismissal, he should “return back to Iran to complete medical studies” as another medical student had done. Pl.’s Facts ¶ 124. In his deposition, President Tra-chtenberg did not specifically recall making this remark. See Pl.’s Ex. 36 (Tra-chtenberg Dep.) at 46:2-13 (“[W]e are really here deep into the muddy of speculation.”). In addition, Plaintiff provides no additional evidence, beyond conclusory allegation, that this remark was ever made. On September 20, 2007, Dean Goldberg sent a letter to Anthony Galarza, Associate Registrar of GW requesting that Plaintiffs “transcript be updated to reflect the change in status” “Dismissed for Reasons of Professional Comportment on July 26, 2007.” Def.’s Ex. 15 (Fillian Dep.), Ex 1. According to Defendant, in response to this letter, Assistant Registrar Larry Filli-an erroneously placed an academic hold on Plaintiffs account, which kept Plaintiff from obtaining a copy of his transcript. Def.’s Ex. 15 at 10:18-11:15; Def.’s Ex. 16 (Fillian Decl.) ¶ 1. Fillian stated that he placed the hold as a precaution to prevent Plaintiff, as a dismissed student, from registering, and did not know it would prevent Plaintiff from obtaining a copy of his transcript. Def.’s Ex. 15 at 15:3-19. On April 7, 2008, after requesting his transcript, GW’s Registrar issued a letter stating: The Office of the Registrar is unable to produce a transcript for the above mentioned individual because this student has a hold on their record and it is the policy of the university not to issue transcripts for students who have specific types of holds. The hold was placed by the Dean of the School of Medicine and Health Sciences and reads “Dismissed per SMHS”. PL’s Ex. 41 (April 7, 2008 Letter from Registrar to Plaintiff). After Plaintiff complained of the hold, GW’s Registrar removed the hold, Fillian apologized to Plaintiff, and GW sent Plaintiff letter “cer-tifyfing] that the, academic hold (SMHS Dean’s Office) preventing the above student from obtaining his transcript was erroneously placed.” Def.’s Ex. 15 at HU-IS; id., Ex. 3 (April 14, 2008 Letter from Registrar to Plaintiff). The letter further states, “[t]he hold was intended to prevent future registration, but unwittingly additionally prevented transcript production.” Id., Ex. 3. On November 19, 2007, GW notified the National Board of Medical Examiners (“NBME”) that it had dismissed Plaintiff. Def.’s Ex. 8 (Harolyn Johnson Decl.), Ex. A (E-mail from Harolyn Johnson to NBME). The NBME co-sponsors the United States Medical Licensing Examination (“USMLE”). Id. ¶4. According to Defendant, a student dismissed from medical school is ineligible to take the exam, even if he is contesting the dismissal. Id. ¶ 6. The NBME routinely asks GW to verify student enrollment before students sit for the exam. Id. ¶ 7. Defendant states that in keeping with this normal practice, it notified the NBME of Plaintiffs dismissal. Id. ¶¶ 8-9. Subsequent to his dismissal, Plaintiff filed a complaint with the District of Columbia Office of Human Rights (“DCOHR”) alleging that (1) Defendant engaged in disparate treatment on the basis of Plaintiffs religion and perceived national origin in taking several of the actions leading up to and concluding in Plaintiffs dismissal from the Medical School, (2) Defendant subjected him to a hostile work environment, and (3) Defendant retaliated against Plaintiff for his written submissions on July 25, 2006, September 22, 2006, and April 21, 2007. PL’s Ex. 20 (Plaintiffs DCOHR Complaint). On June 22, 2009, the DCOHR issued a cause determination finding no probable cause to believe Plaintiffs claims of disparate treatment and hostile work environment. PL’s Ex. 21 (DCOHR Opinion) at 86-87. However, the DCOHR did find probable cause to believe that Defendant retaliated against Plaintiff for his -written complaints. Id. at 86. These determinations were affirmed on January 12, 2010. PL’s Ex. 66 (DCOHR Opinion Denying Cross-Motions for Reconsideration). However, on June 15, 2011, Plaintiff sought to voluntarily withdraw his administrative complaint from further consideration. Hajjar-Nejad v. George Washington Univ., 873 F.Supp.2d 1, 13 (D.D.C. 2012). The Commission, honoring what it saw as Plaintiffs clear and unambiguous desire, granted the request and dismissed the administrative proceedings with prejudice on June 24, 2011. Id. B. Procedural Background This case has a long and winding procedural history, which the Court sets out here in summary form. Plaintiff originally filed suit pro se in the United States District Court for the District of Maryland on April 9, 2010. See Compl., ECF No. [1-4]. By any reasonable measure, Plaintiffs original Complaint was sprawling; it spanned 121 color-coded pages, included 193 paragraphs (several with discrete sub-parts), and was accompanied by thousands of pages of exhibits. Although far from clear, Plaintiff appeared to allege that he was unfairly and unlawfully dismissed from GW based on his race, religion, and perceived national origin in violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq. (“Title VI”); Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. (“Title VII”), the District of Columbia Human Rights Act, D.C.Code § 2-1401.01 et seq. (the “DCHRA”); and his constitutional rights to free speech, the free exercise of religion, and equal protection under the law. On April 19, 2010, the action was transferred to this Court, see Mem. (Apr. 19, 2010), ECF No. [ 1-10], whereupon Plaintiff secured legal counsel and, with GW’s consent, filed an Amended Complaint (the “First Amended Complaint”), see Am. Compl., ECF No. [13]. The First Amended Complaint — itself no model of clarity— included three counts. In Count I, Plaintiff appeared to claim that GW discriminated against him on the basis of his race, religion, and national origin in violation of Title VII; Section 1 of the Civil Rights Act of 1866, 42 U.S.C. § 1981 (“Section 1981”); and the DCHRA. See id. ¶¶ 72-75. In Count II, Plaintiff appeared to claim that GW retaliated against him for engaging in protected activity in violation of Title VII; Section 1981; and the DCHRA. See id. ¶¶ 77-79. In Count III, Plaintiff alleged that GW breached the terms of the Offer of Acceptance by dismissing him from the Medical School. See id. ¶¶ 81-83. On July 26, 2010, GW filed its first Motion to Dismiss, targeted at Plaintiffs First Amended Complaint. See Def.’s Mot. to Dismiss First Am. Compl., ECF No. [14]. On August 20, 2010, Plaintiff, then acting through counsel, responded by filing a partial opposition and voluntarily dismissing Counts I and II of the First Amended Complaint without prejudice. See Pl.’s Partial Opp’n to Def.’s Mot. to Dismiss First Am. Compl. and Voluntary Dismissal of All Pending Civil Rights Claims, ECF No. [17]. Concurrently, Plaintiff moved this Court for leave to file a Second Amended Complaint omitting his “civil rights claims” but retaining his claim for breach of contract, see Pl.’s Mot. for Leave to File Second Am. Compl., ECF No. [18], which the Court granted, see Order (Aug. 24, 2010), ECF No. [19]. On August 24, 2010, Plaintiff filed his Second Amended Complaint. See Second Am. Compl., ECF No. [20]. Despite the sweep of its allegations, Plaintiffs Second Amended Complaint asserted a single cause of action sounding in breach of contract. See id. ¶¶ 58-60. Specifically, Plaintiffs Second Amended Complaint contended that the Offer of Acceptance constitutes a binding contractual agreement and that GW breached the agreement by dismissing him from the Medical School. See id. On September 17, 2010, GW filed its second Motion to Dismiss, which Plaintiff, through his chosen legal counsel, opposed. See Def.’s Mem. of P. & A. in Supp. of its Mot. to Dismiss Pl.’s Second Am. Compl., ECF No. [21-1]; Pl.’s Mem. in Opp’n to Def.’s Mot. to Dismiss Second Am. Compl., ECF No. [22]. After this motion was fully briefed, however, Plaintiff filed his second Motion to Amend, seeking to add claims arising under Title VI, Title VII and Section 1981. See PL’s Mem. in Supp. of PL’s Mot. to Reinsert Civil Rights Compls., ECF No. [24], Even though Plaintiff was represented by counsel at the time, he filed his second Motion to Amend pro se. This prompted his legal counsel to file a Motion to Withdraw. See Mot. for Leave to Withdraw as Pl.’s Counsel of Record, ECF No. [25]. Therein, Plaintiffs counsel represented that “[s]everal disagreements ha[d] arisen” between him and Plaintiff “with respect to the management of this case,” id. at 1, and claimed that Plaintiff filed his Motion to Amend with the Clerk of the Court without his prior review or approval, id. at 2. On August 15, 2011, this Court issued a detailed Memorandum Opinion and Order resolving GW’s second Motion to Dismiss, Plaintiffs second Motion to Amend, and Plaintiffs counsel’s Motion to Withdraw. See Hajjar-Nejad v. George Wash. Univ., 802 F.Supp.2d 166 (D.D.C.2011). Beginning with GW’s Motion to Dismiss, the Court first noted that Plaintiff, through his chosen counsel, had voluntarily narrowed the, scope of his Second Amended Complaint to assert a single claim sounding in breach of contract — specifically, his claim that the written Offer of Acceptance constituted a binding agreement between him and GW and that GW breached the terms of that agreement by dismissing him from the Medical School and refusing to provide him with the contemplated educational services. However, outside of this Offer of Acceptance, “Hajjar-Nejad’s Second Amended Complaint fail[ed] to provide adequate notice of his breach of contract claim to the extent he intended] to base it on an unidentified universe of ‘regulations,’ ‘policies,’ ‘rules,’ ‘procedures,’ and ‘directives.’” Id. at 175. Moreover, the Court underscored that “Hajjar-Nejad’s claim for breach of contract, as it is framed in the Second Amended Complaint, is based on one, and only one, alleged breach — namely, that GW allegedly ‘rescinded the contract to provide educational services to [Plaintiff] through its precipitous and unlawful dismissal of [him].’ ” Id. at 177 (quoting Second Am. Compl. ¶ 59). Indeed, in his opposition to GW’s second Motion to Dismiss, Plaintiff “confirm[ed] this and expressly disclaimed] that he [was] alleging that anything outside of the ultimate contract termination constituted separate actionable breaches.” Id. at 175 (quotation marks and citation omitted). Nonetheless, the Court could not conclude that Plaintiff had “completely failed to state a claim for breach of contract.” Id. Plaintiff had incorporated the Offer of Acceptance into the Second Amended Complaint, specifically alleged that it constituted a mutually binding agreement supported by consideration on both sides, maintained that GW breached the Offer of Acceptance by dismissing Plaintiff from the Medical School, and averred that he had suffered damages as a result of the alleged breach. Noting that GW had “never argue[d] that the Offer of Acceptance does not — as a matter of law — impose any obligations on GW that would preclude it from dismissing Hajjar-Nejad [from the Medical School] under the facts alleged,” the Court concluded that “Haj-jar-Nejad ha[d] stated sufficient facts to provide GW with ‘fair notice’ of a claim that GW breached the Offer of Acceptance by dismissing Hajjar-Nejad from the Medical School in July 2007.” Id. at 176-77. Only that narrow claim survived GW’s second Motion to Dismiss. After resolving GW’s second Motion to Dismiss, the Court turned to Plaintiffs second Motion to Amend, through which he sought to reintroduce claims arising under Title VI, Title VII, and Section 1981. Briefly stated, the Court found that Plaintiffs second Motion to Amend, which he had filed pro se despite being represented by counsel, was proeedurally defective because he had failed to comply with the meet-and-confer requirements imposed by Local Civil Rule 7(m) and had further failed to provide a proposed amended pleading as required by Local Civil Rules 7(i) and 15.1. See id. at 178-79. For these reasons, the Court denied Plaintiffs second Motion to Amend, advising Plaintiff that, “[t]o the extent [he] intended] to move this Court for leave to amend his complaint, he must include with his motion to amend a proposed pleading identifying each [and] every claim he intends to pursue in this action and a short and plain statement of the factual basis for those claims.” Id. at 179. Finally, in its August 15, 2011 Memorandum Opinion and Order, the Court granted Plaintiffs counsel’s Motion to Withdraw, which Plaintiff had not opposed. See id. at 179-80. Although Plaintiff was subsequently afforded an opportunity to secure alternate legal counsel, he has elected to proceed in this action pro se. Subsequently, on September 7, 2011, Plaintiff filed his Third Motion to Amend. See Pl.’s Mot. for Leave to File Third Am. Compl., ECF No. [38]. In this motion, Plaintiff sought to assert additional claims for breach of contract and for violations of Title VT, Title VII, Section 1981, the DCHRA, and his constitutional rights under the First and Fourteenth Amendments. In a Memorandum Opinion and Order issued January 4, 2012, the Court granted in part and denied in part Plaintiffs Third Motion to Amend. See Hajjar-Nejad v. George Washington Univ., 873 F.Supp.2d 1 (D.D.C.2012). Specifically, for reasons stated in the opinion, the Court denied Plaintiff leave to amend his complaint to add (a) breach of contract claims beyond his claim that GW breached the Offer of Acceptance by dismissing him from the Medical School in July 2007, (b) claims that GW discriminated and retaliated against him in violation of the DCHRA, (c) claims of discrimination and retaliation arising under Title VII, (d) constitutional claims arising under the First and Fourteenth Amendment; and (e) claims of discrimination and retaliation arising under Title VI based on acts pre-dating April 9, 2007. Id. at 17. However, the Court granted Plaintiff leave to amend his complaint insofar as he sought to add claims identified in his proposed Third Amended Complaint that alleged (a) discrimination or retaliation under Title VI based on acts occurring on or after April 9, 2007; and (b) claims of discrimination or retaliation under Section 1981 based on acts occurring on or after April 9, 2006. Id. In order to avoid disputes as to which portions of the proposed Third Amended Complaint filed by Plaintiff were rendered viable by this opinion, the Court directed the Clerk of the Court to file a redacted version of the Third Amended Complaint attached to the Court’s opinion. Id. at 16-17. See generally TAC. The Court further stated that the Third Amended Complaint would be viable only insofar as it was compatible with the terms of the Court’s orders in this case. Hajjar-Nejad, 873 F.Supp.2d at 17. The parties then proceeded to discovery, supervised by Magistrate Judge John M. Facciola. See Hajjar-Nejad v. George Washington Univ., No. 10-cv-626, 2013 WL 2635190 (D.D.C. June 12, 2013); Hajjar-Nejad v. George Washington Univ., No. 10-cv-626, 2013 WL 178729 (D.D.C. Jan. 16, 2013); Hajjar-Nejad v. George Washington Univ., No. 10-ev-626, 2012 WL 1655724 (D.D.C. May 9, 2012). On March 29, 2013, Defendant filed its [154] Motion for Summary Judgment, seeking dismissal of this case in its entirety and an entry of judgment in Defendant’s favor. Plaintiff subsequently filed a [158] Response to Defendant’s Memorandum in Support of its Summary Judgment Motion. This response consisted of 283 pages of briefing, and was accompanied by a 171 page Statement of Facts as well as 3,126 pages of exhibits. By Minute Order issued May 2, 2013, this Court struck Plaintiffs response and all the attached exhibits for failing to comply with the instructions set forth in the Court’s [146] Scheduling and Procedures Order. Specifically, Plaintiff had failed to file a statement of material facts responding to the specific facts set out by Defendant and stating whether each fact was admitted or denied. See Minute Order (May 2, 2013). In addition, the Court noted that “Plaintiffs statement of facts is egregiously lengthy and is abounding with facts that are not relevant to Plaintiffs claims and certainly not ‘material.’ To proceed on these pleadings would be a severe waste of the time and resources of both the Court and the parties.” Id. The Court ordered Plaintiff to file a renewed response to Defendant’s motion, correcting the identified deficiencies. Further, the Court ordered that Plaintiffs renewed opposition not exceed fifty pages and that his revised statement of facts not exceed seventy-five pages. After the Court denied Plaintiffs request for reconsideration of this Order, Plaintiff filed his [ 168] Opposition to Defendant’s Motion for Summar