Date incident allegedly occurred: October 9, 1989

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

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



University records reveal no meeting transpired between Judy DeMers and myself on October 10, 1989. My class notes verify I did attend classes the week before the examinations. Note: The School of Medicine does not record student attendance because the School of Medicine lacks an attendance policy. Moreover, I was not officially a member of any study group. Therefore, I did not have access to, nor did I utilize study materials from members of any study group, or third party. I certainly hope no student believed otherwise. I never possessed copies of the notes to which Judy DeMers is referring. 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.



10-9-89. I met with Vivian because she hadnít attended class at all the week before (the week preceding block exams) and I saw a negative pattern of behavior re-appearing. She also had been part of a study group for Behavioral Science. Although she used information from other group members, she did not do her assignment---leaving the group "high and dry". I tried to point out the potential repercussions of this type of behavior. Vivian, later, wrote me two notes, apologizing for this behavior.



Accompanying University records 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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