July 2, 1993
3801 Connecticut Avenue, NW
#136
Washington, DC 20008
Gertrude R. Ticho, MD
3120 Brandywine Street, NW
Washington, DC
Dear Dr. Ticho:
This will confirm our telephone conversation on the morning of July 2, 1993 in which you stated that you did not make a representation regarding my mental status to Mr. Dennis M. Race of the law firm of Akin, Gump, Strauss, Hauer & Feld in late October 1991 or at any time.
I am enclosing a statement that I prepared which affirms that you did not make a representation regarding my mental state to my former employer, as falsely alleged by my former employer in documents it filed with the District of Columbia Department of Human Rights and Minority Business Development. I request that you sign and date the statement and return it to me in the enclosed envelope.
I am also forwarding that portion of the Department of Human Rights opinion letter that falsely attributes statements to you, together with an additional copy of the prepared statement which you may keep for your own records.
I greatly appreciate your assistance in this matter.
Sincerely,
Gary Freedman
The following is the text of the statement I prepared for Dr. Ticho to sign. She did not sign this statement. Rather she sent me a letter on her letterhead affirming that she had no contacts with Dennis M. Race, and affirming that she never saw me in consultation.
TO THE DC DEPARTMENT OF HUMAN RIGHTS AND MINORITY BUSINESS DEVELOPMENT:
This statement confirms that Mr. Gary Freedman placed a telephone call to me on the morning of Friday July 2, 1993 and inquired as to whether I had ever made a representation regarding Mr. Freedman's mental status to Mr. Dennis M. Race of the law firm of Akin, Gump, Strauss, Hauer & Feld.
Mr. Freedman read to me over the telephone the following portion of an opinion letter issued by the District of Columbia Department of Human Rights and Minority Business Development: "Dr. Gertrude Ticho 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."
I, Dr. Gertrude R. Ticho, affirm that I was never contacted by, nor have I ever spoken with, Mr. Dennis M. Race or any attorney manager of the law firm of Akin, Gump, Strauss, Hauer & Feld, in late October 1991 or at any time. On no occasion was I ever requested by Mr. Dennis M. Race or any attorney manager at Akin, Gump, Strauss, Hauer & Feld to offer a representation regarding Mr. Freedman's mental status. I do not know the identity of Mr. Dennis M. Race and have never communicated with him. I do not know, nor can I explain, why attorney managers of the law firm of Akin, Gump, Strauss, Hauer & Feld would allege in documents filed with the District of Columbia Department of Human Rights and Minority Business Development that I made the statements falsely attributed to me. The only time I have ever spoken with Mr. Gary Freedman was the telephone call that Mr. Freedman placed to me on July 2, 1993.
__________________________
Gertrude R. Ticho, MD
3120 Brandywine Street, NW
Washington, DC
(202) 244-2113
_________________________
Date
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2 comments:
"virtually every event"
Keep in mind: By Akin Gump's own admission, I only complained about 6 incidents! Six incidents out of 3.5 years of employment is a far cry from "virtually every event."
Gertrude R. Ticho, M.D.
3120 Brandywine Street, N.W.
Washington, D.C. 20008
_____
Telephone: 202-244-2113
July 4, 1993
Dear Mr. Freedman,
When you called me on the morning of July 2, 1993 you asked me two questions, which I promised to answer in writing.
1.) I never met, nor have I ever spoken to a Mr. Dennis R. Rice [sic].
2.) I do not know your identity, Mr. Gary Freedman nor have I ever seen you for a diagnostic evaluation.
Sincerely,
Gertrude R. Ticho, M.D.
[Record on appeal at 62, Freedman v. D.C. Dept. Human Rights, D.C.C.A. 96-CV-961 (Sept. 1, 1998)]
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