February 11, 1995
3801 Connecticut Ave., NW
Washington, DC 20008
David M. Bowie
Supervisory Special Agent
Federal Bureau of Investigation
Washington Field Office
Washington, DC 20535
RE: Freedman v. Akin, Gump, Strauss, Hauer & Feld
Dear Mr. Bowie:
I wish to inform the Federal Bureau of Investigation that I am currently receiving disability benefits from the U.S. Social Security Administration, that I will be filing for an extension of disability benefits in the upcoming months, and that my disability benefits claim is made in absolute good faith.
I forward for your information the following documentation regarding my disability claim:
1. Letter dated February 10, 1995 to Philip C. Leadroot, U.S. Secret Service re: current status of determinations by various parties that I remain a serious threat to persons in my immediate environment and unemployable.
2. Letter dated October 17, 1994 to Eric H. Holder, Jr., U.S. Attorney for the District of Columbia re: apparent false sworn statements filed by attorney managers of the law firm of Akin, Gump, Strauss, Hauer & Feld concerning its disability determination.
3. Tape recording comprising my conversations with:
(a.) Gertrude R. Ticho, M.D. on July 2, 1993 in which Dr. Ticho denies having communicated with any attorney managers of Akin Gump as found by the D.C. Department of Human Rights;
(b.) Ilana Baptiste on July 2, 1993 in which Ilana Baptiste states her inability to substantiate finding by D.C. Department of Human Rights that an unnamed Sheppard Pratt Preferred Resources counselor communicated with attorney managers of Akin Gump;
(c.) my sister, Mrs. Estelle Jacobson, on August 26, 1993 in which my sister registers her incredulity at diagnosis of bipolar disorder (manic depression) made by the George Washington University Medical Center.
As you know, based on documentation that I have previously forwarded to your office, Akin Gump was able to avoid the terms of its own disability insurance contract with UNUM Life by failing to advise me upon my job termination on October 29, 1991 that Akin Gump had determined that I suffered from a mental disability and that I was being terminated for that reason. By the terms of the UNUM Life contract, a beneficiary is required to file a claim within 30 days of onset of disability. I did not learn that Akin Gump had determined that I was disabled until December 22, 1992 upon my receipt of Akin Gump's Response to Interrogatories and Document Request filed with the D.C. Department of Human Rights, more than a year after the onset of disability, which according to Akin Gump was October 29, 1991. Irrespective of my right under COBRA to retain disability insurance coverage, my right to file a claim with UNUM Life lapsed, by the express terms of the UNUM Life contract, as of November 29, 1991.
Akin Gump has, in effect, avoided increases in its insurance premium liability under a private disability insurance contract by deceptively withholding material facts from a beneficiary regarding the nature and onset of disability thereby preventing the beneficiary from filing a timely claim, resulting in the shifting of financial burden of benefits payments from a private insurer onto the U.S. Social Security Administration.