Date incident allegedly occurred: February 28, 1990

Date of official medical school "dismissal": June 25, 1990

Date University first notified me of this charge: February 8, 1991



University records show no meetings transpired between Judy DeMers and myself on February 28, 1990, and no four-part agreement exists in any form whatsoever. Consequently, I never entered any such agreement with Judy DeMers. Moreover, I attended classes on a regular basis until my de facto dismissal on April 12, 1990. Additionally, University personnel do not record student attendance because the Medical School lacks an attendance policy. Nevertheless, Associate Dean Judy DeMers lied to University committees and ultimately the Court by creating and utilizing the following false statement to obtain my medical school dismissal.



2-28-90. I met with Vivian in my office and reminded her of our on-going four part agreement: Attend classes; try to get along with her classmates; stay in therapy; and try to obtain enough sleep/exercise/social activity. Vivian has started missing classes. Attendance has been irregular for 2-3 weeks.



Chronological memorandums authored by Judy DeMers reveal she concocted this prevarication long after dismissal.

Date of Entry Subject of University of North Dakota Student Record Entry
February 20, 1990 A hearing charging me with overhearing a conversation about nothing specific
March 5, 1990 Confidential memo regarding Judy DeMers' plan to ending my medical career

Accessibility to complete medical school record is obtainable by clicking the hypertext entitled "Complete Student Records" located on the Home Page.


Appendix contains applicable regulations disregarded by the University of North Dakota.


Citing sovereign immunity, the University of North Dakota refuses to comply with regulations guaranteeing me the opportunity to respond to this factually incorrect allegation contrived months after my dismissal!


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