May 20, 1996
3801 Connecticut Ave., NW #136
Washington, DC 20008-4530
Philip C. Leadroot
U.S. Secret Service
Washington Field Office
RE: Freedman v. D.C. Dept. Human Rights D.C. Superior Court -- 95 MPA 0014
Dear Mr. Leadroot:
Enclosed for the information of the U.S. Secret Service is a copy of the "Brief of Respondent in Opposition to Petition for Review of No Probable Cause Determination by Department of Human Rights," filed by the D.C. Corporation Counsel in the above-referenced matter on May 17, 1996.
The U.S. Secret Service is advised that the D.C. Corporation Counsel has reaffirmed the following prior finding of fact made by the D.C. Department of Human Rights (DHR):
Dr. Gertrude R. Ticho [a psychiatrist] identified Complainant's behavior, putting a negative meaning to virtually every event as "ideas of reference" and cautioned that individuals in similar circumstances may become violent. DHR Letter of Determination, issued June 30, 1993, Finding of Fact No. 6 at p. 7, Record at 17.
The U.S. Secret Service is advised that the D.C. Corporation Counsel has reaffirmed that an allegation made by a senior supervisor at the law firm of Akin, Gump, Strauss, Hauer & Feld (Akin Gump) at the time of my job dismissal that I might have been planning to burglarize the firm with the intent to carry out a homicidal attack IS NOT evidence of a hostile work environment. Further, the action taken by senior supervisors to secure an office suite against an armed assault to be carried out by me IS NOT evidence of a hostile work environment. See Complainant's Application for Reconsideration of No Probable Cause Finding, filed July 27, 1993 at Attachment A, Record at 41 ("All I know is that Chris [Robertson] said, 'You all know Gary is gone. And they're coming to change the locks, because we're afraid Gary may come back and he may try to kill me.'")
The U.S. Secret Service is advised that the D.C. Corporation Counsel has reaffirmed that the following statement made to me by a co-worker at the law firm of Akin Gump IS NOT evidence of a hostile work environment: "We're all afraid of you. We're afraid you're going to buy a gun, bring it in, and shoot everybody." See Complainant's Reply to Respondent's Response to Interrogatories and Document Request, filed January 5, 1993 at p. 38, Record at 276.
The U.S. Secret Service is further advised that the D.C. Corporation Counsel has unilaterally expanded the original determination made by DHR that the employer's decision to terminate was based in part on my complaint of harassment to the employer that comprised ten incidents. The D.C. Corporation Counsel has expanded the justification for the employer's decision to include a body of allegations that I never made to the employer and which therefore played absolutely no role in the employer's termination decision and its alleged concerns regarding my potential for violence. (The additional allegations are drawn from statements I submitted to DHR after the job termination). In expanding the justification for the employer's decision to terminate to include a body of allegations I never even made to the employer, the D.C. Corporation Counsel has implicitly fortified the employer's assertion that the termination decision was based on its concerns about my mental stability and potential for violence. In the view of the D.C. Corporation Counsel it now appears that I am even more disturbed and potentially violent than even the employer could have originally feared.
Bob Strauss's law partners have stated under penalty of criminal sanctions--and the D.C. Corporation Counsel has affirmed--that my beliefs about Akin Gump are the product of a pathological mental process (consistent with paranoid schizophrenia 1/) that renders me potentially violent. Mr. Strauss's partners and the D.C. Corporation Counsel refuse to acknowledge that a determination made by senior Akin Gump supervisors at the time of my job dismissal that I might have been armed and homicidal (that I might carry out a burglary with the intent to commit a brutal multiple homicide) is evidence of a hostile work environment.
I respect the decision of the U.S. Secret Service not to investigate the sworn statements and actions of the law partners of Treasury Secretary Robert E. Rubin's long-time close personal friend and confidant, Robert S. Strauss relating to fears concerning my potential for violence (including murder) in a situation where the D.C. Corporation Counsel has affirmed that those sworn statements were nonpretextual in nature and my work environment was not hostile or offensive.
To the extent that the D.C. Corporation Counsel has affirmed that my beliefs about my employment experience at the law firm of Akin Gump are the product of a pathological mental process identified as "ideas of reference," the enclosed "Brief of Respondent in Opposition to Petition for Review of No Probable Cause Determination by Department of Human Rights" may be material to a possible future insanity defense were I to commit an act of violence (including murder) as feared by senior managers and partner of the law firm of Akin Gump--a fear affirmed by the D.C. Corporation Counsel as genuine and not the product of a hostile or offensive work environment. Moreover, the D.C. Corporation Counsel has unilaterally fortified any possible future insanity defense available to me were I to commit an act of violence (including murder) by its act of expanding the justification for the termination to include allegations I never even communicated to the employer.
One assumes that attorneys representing Francisco Martin Duran 2/ would have given their eye teeth to have at their disposal for their client's defense a document such as the enclosed brief issued by the D.C. Corporation Counsel, which (1) affirms the alleged statements of a psychiatrist implicitly relating to my capacity to form criminal intent--statements that the psychiatrist herself expressly denies ever having made; and (2) unilaterally expands the apparent factual basis of that psychiatrist's professional opinion.
cc: DOJ; U.S. Attorney; The Washington Post (tentative)
1/ John Hinckley, Jr., found not guilty by reason of insanity in the attempted assassination of former President Ronald Reagan, has been diagnosed as suffering from paranoid schizo-phrenia, a mental illness that prominently features "ideas of reference." Prior to his assassination attempt John Hinckley lived in a mental world of fantasy and delusion not unlike that attributed to me by the D.C. Corporation Counsel in its unilaterally expanded iteration of the legal justification for my job termination.
2/ In the trial of Francisco Martin Duran on the charge of attempted assassination of the President of the United States, Assistant U.S. Attorneys Eric Dubelier and Brenda Johnson successfully overcame the defendant's insanity plea by demonstrating that Mr. Duran's purported delusional system was not long-held and genuine. In my own case, the Brief of Respondent D.C. Corporation Counsel constitutes a written affirmation by the highest legal officer of the District of Columbia that (1) certain of my beliefs as to my employment experiences at Akin Gump are the product of a pathological mental process (prominent in the psychotic disorders), identified as "ideas of reference," that is associated with a risk of violent conduct; (2) unilaterally expands the scope of that belief system beyond that origi-nally found by the D.C. Department of Human Rights to include findings that arguably relate to a fixed delusional system relevant to an insanity defense in a possible future felony prosecution; (3) tends to establish (unlike the Duran case) that my belief system is genuine and long-held; and (4) overcomes the written (or otherwise memorialized) denials of a psychiatrist that she had ever offered her professional opinion that my belief system is the product of a pathological mental process that is associated with a risk of violence.