Response | Filed: August 03, 2026
| Entered: August 03, 2026
Noshi v. Massachusetts Institute of Technology
Civil Rights: Jobs | Massachusetts
Memorandum in Opposition to Motion
MEMORANDUM in Opposition re 12 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM MEMORANDUM IN OPPOSITION to 12 Motion to Dismiss filed by Mohammad Noshi. (Attachments: # 1 Exhibit Non Legal Attacks and Improper Characterizations in Defendants Motion to Dismiss, # 2 Exhibit Timeline of Correspondences: Defendants Request for Unnecessary 60 Day Extension (Summarizes the exchange reflected in Exhibits B 1 through B 5), # 3 Exhibit Email from Defense Counsel to Plaintiff, June 18, 2026, Requesting A Massive 60 Day Extension, Appearing 10 Days After Service of Complaint, # 4 Exhibit Email from Defense Counsel to Plaintiff, June 19, 2026, Demanding Response Within Less Than Three Business Hours, # 5 Exhibit Email from Plaintiff to Defense Counsel, June 19, 2026, Objecting to Unreasonable Deadline, Pressure Tactic, and Requesting Reasonable Time as Pro Se Litigant, Objecting to 60-Day Extension as Excessive Due to Defendants Intimate Familiarity with Their Own Conduct, and Reasonably Proposing a 21-Day Extension Instead, # 6 Exhibit Email from Defense Counsel to Plaintiff, June 22, 2026, Immediately Conceding 60 Day Extension Upon Plaintiffs Explicit Opposition, Agreeing to 21-Day Extension Plaintiff Proposed, Characterizing Plaintiffs Legitimate Response as Unfortunate, and Admitting Additional Days Would Have No Impact on Its Trajectory, # 7 Exhibit Email from Plaintiff to Defense Counsel, June 22, 2026, Accepting a Relief of 21 Day Extension He Proposed, Relying on Counsels Promise / Representation of a Straight Forward Motion and Stating He Will Not Have Time to Review Drafts, # 8 Exhibit Timeline of Last-Minute Correspondences: Defendants Motion to Dismiss (Summarizes the exchange reflected in Exhibits C 1 through C 3), # 9 Exhibit Email from Defense Counsel to Plaintiff, July 17, 2026, Requesting Immediate / Rushed Meet and Confer on the Final Business Day, # 10 Exhibit Email from Plaintiff to Defense Counsel, July 17, 2026, Responding Promptly, Requesting Unprovided Information Needed to Prepare for Conference, and Stating Weekend and Deadline Unavailability, # 11 Exhibit Automated Away Response from Plaintiff, July 17, 2026, Confirming Unavailability Over the Weekend and Deadline, # 12 Exhibit Email from Plaintiff to MIT Officials, February27,2025, Promptly Responding to No Trespass Order, Refuting False Accusations, and Confirming Requesting Essential Documents)(Noshi, Mohammad)