Date incident allegedly occurred: September 9, 1988

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

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



University records confirm Judy DeMers did not ask me to stop by her office on September 9, 1988. 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.



9-7 - 9-9-88 (Wed-Fri). Telephone call from Vivian (10:15 p.m.) stating they believe she has anemia, is developing hepatitis, and probably will need to be hospitalized. She stated she had seen Dr. Braunagel. I mentioned the possibility of a reduced academic load or withdrawal from medical school. On Thursday, 9-8, Dr. Braunagel called. States Vivian had spoken with the on-call resident, Dr. Joseph. Her complaint had been extreme tiredness. Dr. Braunagel says this is inconsistent with the last time he saw her on 9-1-88. He had not seen her since then and states no conversation regarding anemia, hepatitis, or hospitalization ever took place. We agreed that a psychiatric consult was warranted. Vivian is in counseling on a weekly basis at FPC. I asked Vivian to stop by my office on Friday (9-9-88). I left at 6:00 p.m. when she had not stopped by.



Accompanying University records reveal DeMers concocted this prevarication long after dismissal.

Chronological student record entries



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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