Akin Gump's Conduct the Proximate Cause of my Disorder

December 13, 1993
3801 Connecticut Avenue, NW
Apartment 136
Washington, DC  20008

Suzanne M. Pitts, MD
George Washington University
          Medical Center
2150 Pennsylvania Avenue, NW
Washington, DC 20037

Dear Dr. Pitts:

This letter is intended to advise you that during the period beginning with my job termination on October 29, 1991 by the law firm of Akin, Gump, Strauss, Hauer & Feld and continuing to the present I have not found it possible at all times to conduct a diligent search for alternative employment.

Beginning on October 29, 1991 as a direct result of the malicious conduct of Akin Gump management, I have suffered from psychological symptoms, severe at times, that have prevented me from seeking employment, despite my intense desire to return to gainful employment. These symptoms have including intense anxiety, irritability, feelings of dread, and a constant reliving of the painful experiences that I suffered during my employment at Akin Gump.

I did not suffer from these specific symptoms prior to the termination on October 29, 1991; the symptoms arose at the time of the termination and, indeed, are a direct consequence of the termination. During the period immediately prior to October 29, 1991--from late May 1991 until October 8 1991--I consulted weekly with psychologist, Dr. William D. Brown, for non-debilitating anxiety. As a psychologist, Dr. Brown is precluded from treating clients with severe emotional disorders. Principle 2 (Competence) of the Ethical Principles of Psychologists (amended June 2 1989), promulgated by the American Psychological Association (APA), requires that “[p]sychologists recognize the boundaries of their competence and the limitations of their techniques.”  A psychologists’ continued treatment of a severely disturbed client would constitute a violation of the aforementioned ethical principle. The APA, which conducted a review of Dr. Brown’s handling of my case, has determined that Dr. Brown’s therapy did not exceed his competence (see letter dated September 23, 1993 issued by the American Psychological Association enclosed).

The finding of the APA that Dr Brown’s handling of my case did not violate that organization’s ethical principles regarding a psychologist’s competence leads to one inescapable conclusion: that during the period immediately prior to my termination on October 29, 1991--from late May 1991 until October 8, 1991--I did not suffer from psychological symptoms of sufficient severity so as to preclude competent nonmedical handling by a psychologist. Further, the APA’s disposition of my Complaint against Dr. Brown is consistent with the logical inference that any severe and debilitating symptoms from which I currently suffer are a direct consequence of the malicious actions of Akin Gump management in late October 1991 in terminating my employment and the malicious actions perpetrated by Akin Gump management in connection with the unlawful termination investigation conducted by the District of Columbia Department of Human Rights and Minority Business Development. 1/

In conclusion, I wish to advise you that during the period October 29, 1991 to the present, because of  psychological symptoms--severe at times--I have not found it feasible at all times to conduct a diligent search for alternative employment. Further, my present medical condition is a direct consequence of the malicious conduct of Akin Gump.

Sincerely,

Gary Freedman
_______________________
1/ You will recall that I commenced weekly psychotherapy at the George Washington University Medical Center on October 27, 1992. During the session on the morning of December 22, 1992 you advised me that you discerned improvement in my condition (see letter dated December 24, 1992, enclosed). Coincidentally, on December 22, 1992 the Postal Service delivered to me a copy of Akin Gump’s Response to Interrogatories and Document Request filed with the D.C. Department of Human Rights in connection with that agency’s unlawful termination investigation. Akin Gump’s filing was replete with malicious factual distortions and defamatory accusations. In addition, the pleadings included fabricated--though at the time credible and disturbing--evidence that I had been secretly certified insane and potentially violent by an unidentified psychiatrist! By late January 1993--only weeks after I had read the extremely disturbing falsehoods contained in pleadings filed by Akin Gump--you determined that it was therapeutically advisable that I undertake twice-weekly consultations and suggested for the first time that I take medication. Quite probably, the marked progress I had made after about seven weeks of therapy, which you noted on December 22, 1991, was nullified by the intense emotional distress I experiences as a result of Akin Gump’s defamation. There can be no doubt that the malicious conduct of Akin Gump management, at times outrageous, has had a markedly deleterious effect on my mental state, as it would on any reasonable person, and has, as a consequence, directly and severely--though one hopes, temporarily--impaired my ability to seek alternative employment.