The following timeline, based on facts not controverted by the Corporation Counsel, indicates the absurdity of the District's argument in Freedman v. D.C. Dept. Human Rights, D.C.C.A. no. 96-CV-961 (Sept. 1, 1998).
a. I started working at Akin Gump as an agency-supplied temp on about March 3, 1988.
b. Throughout the period March 4, 1988 to October 2, 1991 I exhibited the psychiatric disorder "ideas of reference," which, according to Akin Gump, rendered me not suitable for employment and potentially violent.
c. Throughout my employment I received laudatory performance evaluations (in the custody of Personnel Administrator Laurel Digweed) that did not record any bad conduct despite the fact that according to Akin Gump I suffered from a psychiatric disorder that rendered me potentially violent and not suitable for employment throughout my tenure. Digweed was named by the firm as one of the three decisionmakers who terminated my employment effective October 29, 1991.
d. My personnel file (in the custody of decisionmaker Digweed) did include any reprimands (oral or written) for bad conduct at any time during my tenure despite the fact that according to Akin Gump I suffered from a psychiatric disorder that rendered me potentially violent and not suitable for employment throughout my tenure.
e. There is no documentation of any bad conduct throughout my tenure. The first document critical of my conduct came into existence only after I lodged a harassment complaint on October 23-24, 1991.
f. I lodged a harassment complaint against my direct supervisor Robertson (and other firm personnel) on October 23 and October 24 1991.
g. Robertson wrote a seemingly retaliatory memo about me on October 24, 1991 and prepared a seemingly retaliatory performance evaluation. Robertson was named by the firm as one of the three decisionmakers who terminated my employment effective October 29, 1991. Dennis Race prepared a memo to his file dated October 29, 1991 that states that his investigation of my harassment complaint disclosed that my behavior was disruptive and bizarre, but does not identify any complaining parties by name and does not cite any specific incidents. These three documents -- all written after October 23, 1991-- are the only contemporaneous documents alleging that I engaged in bad conduct: two documents prepared by Robertson (against whom I had lodged a harassment complaint) and one document prepared by Race who lied when he advised the Department of Human Rights that he had no knowledge of my sexual orientation and who invidiously failed to advise the Department of Human Rights that I had lodged a harassment complaint against my supervisor, Robertson.
h. The firm terminated my employment effective October 29, 1991.
i. On May 22, 1992 Akin Gump filed a sworn declaration with the Department of Human Rights alleging that it had determined in consultation with mental health professionals, including practicing psychiatrist who did personally examine me, that I suffered from a "disorder" that caused me to attach a negative meaning to trivial events and that rendered me potentially violent. The sworn declaration does not cite a single instance of bad conduct, but alleges retroactively that an investigation in late October 1991 by Dennis Race disclosed that some of my coworkers viewed my behavior as disruptive and bizarre. Akin Gump did not identify any of these individuals -- even after the Department of Human Rights expressly asked Akin Gump to do so. The sworn declaration filed by Dennis Race (one of the three decisionmakers who terminated my employment) fails to indicate that I had lodged a harassment complaint against my supervisor Robertson, thereby denuding Robertson's seemingly retaliatory acts of any retaliatory animus.