The following is a statement I submitted to the U.S. Social Security Administration in support of my claim for disability benefits filed on April 20, 1993. The undated document was apparently written in April 1993; it was appended to an ethics complaint I filed on April 26, 1993 with the American Psychological Association against a former treating psychologist, William D. Brown, Ph.D.
The statement was made under penalty of prosecution for making false statements per 42 U.S.C. 408: Penalties for Making False Statements to Obtain Social Security Benefits. The veracity of the Statement is supported by the admission against interest highlighted in yellow.
STATEMENT IN SUPPORT OF SOCIAL SECURITY DISABILITY BENEFITS
1. During the period June 13, 1988 to October 29, 1991 I was employed as a legal assistant at the law firm of Akin, Gump, Strauss, Hauer & Feld (“Akin Gump,” “firm,” “former employer”) located at 1333 New Hampshire Avenue, NW, Suite 400, Washington, DC 20036.
2. On October 24, 1991 I complained to management that I was a victim of harassment by co-workers, supervisory personnel, and attorneys.
3. On October 29, 1991 I was terminated by Akin Gump. Mr. Dennis M. Race (202 887-xxxx), an attorney manager of the firm, advised me that he was unable to substantiate my allegations of harassment and that there appeared to be a lack of fit between me and other firm personnel. I was advised that two supervisory employees [Maggie Sinnott and J.D. Neary] stated that they found me difficult to work with, that they could not work with me, and that they were afraid of me.
Mr. Race determined, in consultation with two mental health professionals, including a psychiatrist, that I was paranoid and potentially violent. He determined that allowing me to remain on the firm’s premises might constitute negligence.
4. On February 4, 1992 I filed a Complaint with the District of Columbia Department of Human Rights (DOHR) alleging that Akin Gump’s decision to terminate my employment was unlawfully based on the perception that I was homosexual in violation of the District of Columbia Human Rights Act of 1977. DOHR’s investigation of the Complaint [Docket No. 92-087-P(N)] is pending.
Akin Gump was extended an opportunity to mediate the Complaint; the offer to mediate is continuing in nature. To date, Akin Gump has refused to mediate the Complaint, suggesting that the firm continues to believe that its decision to terminate was justified and that I continue to suffer from a serious mental disorder that renders me unemployable.
5. Akin Gump’s Response to the DOHR Complaint characterizes my mental state as paranoid and terms my behavior as bizarre, violent, and disruptive. The description of my mental state contained in the Response suggests a diagnosis of Delusional (Paranoid) Disorder, DSM-III 297.10, a psychotic condition.
The Response states that firm personnel were afraid of me, that I had difficulty communicating with peers, and that I demanded to work in total isolation.
6. I believe that I am employable and that my former employer’s decision to terminate my employment was unlawful, malicious, and discriminatory. However, my belief that I am employable may represent my inability to appreciate the seriousness of what my former employer determined, in consultation with a psychiatrist, to be a grave mental disorder, that, in fact, renders me unemployable.
7. During the period of my employment I formed certain beliefs that might be termed paranoid. I have advised my treating psychiatrist, Dr. Suzanne M. Pitts, that I continue to hold these beliefs. (Notwithstanding this seemingly paranoid ideation I have been diagnosed as suffering from a bi-polar disorder, DSM-III 296.70.) I believe that:
(a.) My former employer has been in communication with each of the mental health professionals I consulted during my employment and that the mental health professionals informed my former employer of the content of each of he sessions. None of the mental health professionals admitted, when asked, that they were in communication with my former employer.
(b.) My former employer has been having regular communications with the Department of Psychiatry, George Washington University Medical Center, where I am currently in therapy. My treating psychiatrist, Dr. Pitts, denies that such communications are going on.
(c.) My former employer had an informal agreement with the former manager of my apartment building, Ms. Elayne Wranik, whereby the manager would inspect my apartment daily, without my consent, and report her findings back to my employer.
(d.) My former employer, without my consent, gained access to my apartment on January 2, 1990, prepared a video-tape of my apartment, and sent a copy of the video-tape to my sister.
(e.) My former employer has had regular and frequent communications with my sister, Mrs. Estelle Jacobson (609 727-3295). I believe that the communications began in about late October 1988 and continue to the present. My sister denies ever having communicated with my former employer.
(f.) My former employer has submitted a copy of my autobiography to various experts including Professors Peter Gay at Yale, Fritz Stern at Columbia, and Harold Blum [sic, should read "Bloom"] at New York University and Yale. I believe that my former employer has also consulted and submitted a copy of my autobiography to Dr. Ernst Ticho and Dr. Gerald Post, two local psychiatrists, as well as Dr. Anthony Storr, a psychiatrist in the United Kingdom. (I provided a copy of the autobiography to my current treating psychiatrist, Dr. Pitts.) I also believe that Mr. Robert Strauss, a founding partner of the firm and former U.S. Ambassador to Russia, gave a copy of my autobiography to former U.S. Secretary of State, James Baker in June 1991.
(g.) My former employer arranged, without my knowledge or consent, to have an Akin Gump supervisory employee, John D. Neary, consult with one of my former psychiatrists, Dr. Stanley Palombo, on April 16, 1990. My belief has not been confirmed.
(h.) My former employer shared with supervisory employees confidential mental health information obtained from various mental health professionals whom I consulted. I believe that these supervisory employees proceeded to use the confidential mental health information to harass me.
8. I believe that during the entire period of my employment I was harassed daily by co-workers, supervisory personnel, and attorneys at Akin Gump. Management was unable to substantiate my allegations of harassment and contends that my ideation is dominated by paranoid “ideas of reference” that are the product of a serious mental disorder that renders me potentially violent (or violent) and presumably, in my former employer’s opinion, unemployable.