April 20, 1993
3801 Connecticut Avenue, NW
Washington, DC 20008
Mr. James L. Kestell
1101 15th Street, NW
RE: McNeil v. Akin, Gump, Strauss, Hauer & Feld
Dear Mr. Kestell:
Enclosed are copies of pleadings in Freedman v. Akin Gump, filed with DOHR:
(1) Akin Gump's Response to Interrogatories and Document Request (I include only the Response to Particulars: all of Akin Gump's attachments are included as attachments to my Reply); and
(2) My Reply to Akin Gump's Response.
I also include a copy of a letter submitted to DOHR detailing the events on the day of my termination, including the actions of my supervisor, Chris Robertson.
Note that Akin Gump's failure to adequately investigate my allegations of harassment against Chris Robertson, and management's failure to investigate the retaliatory nature of Chris Robertson's actions following my charge of harassment, may allow you to add a count of Negligent Retention in McNeil v. Akin Gump.
Also, Chris Robertson's retaliation following my charge of harassment (specifically the numerous intentionally false statements in her memo to Dennis Race dated October 25, 1991) may constitute the tort of Intentional Interference with Contract in my case. (I understand that DC recognizes language in employment manuals as establishing an implied contract right.)
Finally, with respect to Akin Gump's Response, note the absurd statement on the first age: "Later, [on August 1, 1989] Claimant was employed as a full-time legal assistant ("paralegal") to manage massive amounts of documents for a major client (See Attachment C). Shortly thereafter, [on March 9, 1989] the client filed for bankruptcy protection and eventually the legal work diminished." At best, this error indicates Akin Gump's lack of knowledge of the material facts (which carries implications regarding the thoroughness of its investigation of my charge of harassment prior to my termination); at worst, it's an intentional misrepresentation of a material fact.
Re: Meeting with James Kestell, Esq. in April 1993: