Date incident allegedly occurred: August 24, 1988

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

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



University records reveal I neither met with nor spoke to Judy DeMers on August 24, 1989. Consequently, I did not mention a Counselor to Judy DeMers on this date. I ran for a position on a University committee known as the SPRC. I ran on the basis the committee required someone with maturity who would not make rash decisions that would harm students and ultimately discredit the University. A rumor obviously lacking creditability circulated suggesting the SPRC placed me on a leave of absence the year before. 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. (Judy DeMers should be more professional than to submit rumors of this nature to University committees and the US District Court.)



I met with her again, for an hour, on 8-24-89. She will secure a counselor through UND Psychological Services. During this meeting, I also confronted her about running for SPRC on a platform that SPRC had treated her unfairly during the previous year. (She never appeared before SPRC last year).



Accompanying chronological University record entries reveal DeMers concocted this prevarication long after dismissal.



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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