On Friday, April 3, 1998, at my request, a follow-up session with my manager, Keenan Wright, and the Director of Employee Relations, Lucy Finger, was conducted. Below is my understanding of questions and responses.

I asked who was the author of the counseling document. Keenan's reply was that Bill Thurlow wrote most of it, with his input.

Under the FACTS heading:

Bullet 1 - I asked why a my 'employee reply' to the performance annual review, and the eventual outcome, was not also noted. This lack, to me, violated our core company values of celebrating wins. The reply was that the counseling statement was a subjective statement from my manager(s), and my reply, were sufficient unto themselves.

Bullet 2 - I asked why this statement also did not celebrate the win, and focused on the negative. Same reply.

Bullet 3 - I asked if the cited Judy Kramer had had come to either Keenan Wright or Bill Thurlow with the problem. The response was 'no'. I then asked the source of his knowledge, since he was not present at the cited meeting. His reply was 'other team members came to me with their concerns'. I then asked who, specifically. Both Keenan Wright and Lucy Finger declined to provide that information.

Bullet 4 - I asked if the cited Carol Pfingston had come to either Keenan Wright or Bill Thurlow with the problem. The response was 'no'. I then asked the source of his knowledge, since he was not present at the cited meeting. His reply was 'other team members came to me with their concerns'. I then asked who, specifically. Both Keenan Wright and Lucy Finger declined to provide the information. Keenan Wright also stated that he had not talked to Carol Pfingston, but was more accessible to Bill Thurlow, who had talked to her. I still maintain that the cited information did not occur during the same meeting as cited in bullet 3.

Bullet 5 - I asked what other team members had considered "...James behavior was extreme and unacceptable for a professional". Again, Keenan Wright and Lucy Finger declined, saying they wanted to avoid a confrontation. I replied that in light of my success in resolving the problems cited in bullets 1 and 2, wouldn't it be best if I was able to continue this pattern of success. No reply.

Bullet 6 - I noted that Keenan Wright had previously stated that Frank Scranton, a contractor to our department, had been reluctant to say anything. Keenan Wright denied coercing any statement. I then produced copies of all documents and e-mails addressed to Frank prior to the cited issue. Even though I was physically incapable of providing any support, the fact that Frank was in possession of the sum total of my knowledge on the subject, the 'fact' that Frank FELT I was rude obtained.

Under the IMPACT heading:

I commented that the statement "Team members have stated they will not meet with James in one-on-one sessions; therefore, business productivity is impacted" to me means that others refusal to do their job is not my problem, it is a management problem.

Keenan Wright also volunteered, after I distributed a copy of the second opinion diagnosis, that he had read all the other medical documentation I had given him; not every word, but enough to better understand my condition.

I then asked, since the 'charges' seemed so lame, that the document, with attachments, be expunged from my record. I was denied.

Lucy Finger then requested that I procure a medical information release so that information could be obtained from the doctor. She also requested that I list what "reasonable accommodations in the work place" I wanted.