The D.C. Department of Human Rights made a specific finding in June 1993 that I reported ten incidents to my employer, the law firm of Akin, Gump, Strauss, Hauer & Feld. I believed the incidents were evidence of harassment that was limited to random behaviors carried out by firm personnel only. The agency adopted the employer's production that represented the incidents as "ideas of reference," a psychiatric "disorder" that, according to the employer, rendered me not suitable for employment and potentially violent. The ten incidents designated by the agency, per the employer's production, as "ideas of reference" were random, unrelated and uncoordinated acts by various firm personnel: acts that would not support an inference by a psychiatrist that I suffered from a systematic delusion of persecution.
In it's defense of my appeal of the agency's no probable cause finding the District argued before the D.C. Court of Appeals (in 1997) that "after-acquired evidence" (not known to the employer as of the termination on October 29, 1991) -- including my belief that the employer's senior managers (including Robert S. Strauss and Vernon E. Jordan, Jr.) approved the criminal break-in of my residence in early January 1990; that senior managers obtained personal facts about me from my sister and others and disseminated those facts to firm personnel; and that the firm's senior managers unlawfully obtained confidential mental health information from my then-treating psychiatrist, in violation of the D.C. Mental Health Information Act, and disseminated that information to firm personnel -- supported the employer's termination decision.
I submitted a copy of the District's Reply Brief to the U.S. Social Security Administration (SSA) during the summer of 1997 in support of my claim of continued eligibility for benefits. The District's Brief improperly laid the factual groundwork for the SSA to possibly conclude that my beliefs might constitute the far more serious "delusions of reference" associated with delusional (paranoid) disorder rather than "ideas of reference" as found by the D.C. Department of Human Rights in its Initial Determination in June 1993.
The District's Reply Brief of July 1997 would have made it appear to the Social Security Administration at the time of its periodic review of my claim in the summer of 1997 that the District had determined that my illness was more severe than first recognized by the D.C. Department of Human Rights in its Initial Determination of June 1993 when that agency affirmed that I believed I had been subjected to ten incidents of harassment in the workplace by firm personnel (a belief described by the agency as "ideas of reference"). The District's Reply Brief implicitly asserted for the first time that my symptoms supported the diagnostic criteria of delusional (paranoid) disorder: a longstanding and genuinely held belief in a systematic conspiracy by Akin Gump's senior attorney managers to break into my apartment; to disseminate confidential mental health information unlawfully obtained from my treating psychiatrist; and to disseminate personal facts about me obtained via surreptitious communications with my sister and others. See U.S. v. Francisco Martin Duran, United States Court of Appeals, D.C. Circuit, 96 F.3d 1495 (Oct. 8, 1996) (insanity defense failed because defendant did not establish that his "delusions" were genuine and long-held).
In effect, the District's Reply Brief (1997) affirmed for the first time that I held genuine and long-held beliefs about Akin Gump's senior managers that would arguably tend to establish an insanity defense under Duran. The earlier findings of fact made by the D.C. Department of Human Rights in its Initial Determination (June 1993) and its Decision on Reconsideration (September 1993) would not establish the existence of a long-held belief in a systematic delusion of persecution involving the former U.S. Ambassador to the Soviet Union (Robert Strauss) and a close personal friend of the President of the United States (Vernon Jordan).
The legally-irrelevant after-acquired evidence foisted on the D.C. Court of Appeals by the D.C. Corporation Counsel (and which I submitted to the SSA in support of my continued eligibility for disability benefits) was not simply an additional quantum of evidence; it was an additional quantum of evidence different in kind from the findings of fact made by the D.C. Department of Human Rights.
I submitted a copy of the District's Reply Brief to the U.S. Social Security Administration (SSA) during the summer of 1997 in support of my claim of continued eligibility for benefits. The District's Brief improperly laid the factual groundwork for the SSA to possibly conclude that my beliefs might constitute the far more serious "delusions of reference" associated with delusional (paranoid) disorder rather than "ideas of reference" as found by the D.C. Department of Human Rights in its Initial Determination in June 1993.
The District's Reply Brief of July 1997 would have made it appear to the Social Security Administration at the time of its periodic review of my claim in the summer of 1997 that the District had determined that my illness was more severe than first recognized by the D.C. Department of Human Rights in its Initial Determination of June 1993 when that agency affirmed that I believed I had been subjected to ten incidents of harassment in the workplace by firm personnel (a belief described by the agency as "ideas of reference"). The District's Reply Brief implicitly asserted for the first time that my symptoms supported the diagnostic criteria of delusional (paranoid) disorder: a longstanding and genuinely held belief in a systematic conspiracy by Akin Gump's senior attorney managers to break into my apartment; to disseminate confidential mental health information unlawfully obtained from my treating psychiatrist; and to disseminate personal facts about me obtained via surreptitious communications with my sister and others. See U.S. v. Francisco Martin Duran, United States Court of Appeals, D.C. Circuit, 96 F.3d 1495 (Oct. 8, 1996) (insanity defense failed because defendant did not establish that his "delusions" were genuine and long-held).
In effect, the District's Reply Brief (1997) affirmed for the first time that I held genuine and long-held beliefs about Akin Gump's senior managers that would arguably tend to establish an insanity defense under Duran. The earlier findings of fact made by the D.C. Department of Human Rights in its Initial Determination (June 1993) and its Decision on Reconsideration (September 1993) would not establish the existence of a long-held belief in a systematic delusion of persecution involving the former U.S. Ambassador to the Soviet Union (Robert Strauss) and a close personal friend of the President of the United States (Vernon Jordan).
The legally-irrelevant after-acquired evidence foisted on the D.C. Court of Appeals by the D.C. Corporation Counsel (and which I submitted to the SSA in support of my continued eligibility for disability benefits) was not simply an additional quantum of evidence; it was an additional quantum of evidence different in kind from the findings of fact made by the D.C. Department of Human Rights.
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