OTHER KEY DOCUMENTS:
1. Recent APA Post from Dr. Susan McDaniel Regarding Re-engagement 5/13/2016
2. Engagement Letter Sidley Austin LLP and APA 11/20/2014
3. Listserv Request for Notes and Other Documents 9/7/2015
4. Board Response to Council Regarding Privileged Status of Documents 10/29/2015
5. Council Notes 8/2015
6. Council Notes 8/2015
7. Timeline Review Process Chart 5/15/2016
8. Raymond Interview 3/13/2013
9. Soldz Interview 5/24/2012; 5/30/2013
10. Excerpt from Draft Chapter Seven of Pay Any Price Deleted from Final Text 1/5/2012
11. Memo Analyzing Gerwehr Emails from Nathaniel Raymond to James Risen 9/12/2011
12. Memo to FBI from Nathaniel Raymond 10/15/2012
13. Reisner emails 5/7/2015; 3/10/2016
14. Reisner chapter 2010 and interview 4/30/2013
15. Letter from Hoffman and Sidley to Kaslow and McDaniel Regarding his "Factual" Conclusions 8/3/2015
16. Nadine Kaslow's video statement regarding Hoffman's factual findings 7/2015
17. Severance payments for key staff reported to Council (including 1.3 million for the CEO as detailed under the Financial Report tab/link) 8/2015
18. The head of the Special Committee, Dr. Nadine Kaslow, dancing at the CEO's severance party 12/11/2015
19. PENS Guidelines 6/22/2018
21. Investigation of medical personnel involvement in abuse 5/2005
22. News conference referenced on PENS listserv 7//2005
23. Obama review of Guantanamo requesting additional BSCT support 2/2009
24. APA Counsel acknowledgement that APA has fiduciary duty to fix the Report 2/2016
25. APA 2016 President email regarding rehiring of Hoffman to fix the Report 4/15/2016
26. Reported Costs Associated with the Investigation 7/13/2018
27. Example: Letter from APA Undercutting Hoffman's Findings 7/13/2017
31. "The Hoffman Report is full of speculation, unsubstantiated evidence, and innuendo." 8/27/2018
32. In spite of a clear conflict of interest APA rehires David Hoffman and Sidley Austin LLP to fix their Reports a third-time but they refuse to fix either of them in spite of clear evidence in their possession demonstrating the Reports' falsehoods, the APA Board's admissions the Reports contain clear falsehoods, and the APA's in-house counsel's statements to its governing Council that APA has a fiduciary duty to fix the Reports. 4/15/ 2016 See Resnick Affidavit. Admission of APA Counsel from APA Council Meeting. 2/2016
33. APA notifies all Council members that it has removed the landing page for the Independent Review and the first version of the Report from its website. Plaintiffs obtain multiple statements from witnesses that APA General Counsel, Deanne Ottaviano falsely represented to the APA Council of Representatives during the August 10, 2018 Council meeting that the Plaintiffs have refused APA settlement offers and that the first version of the Report was was not posted APA on the APA website. Ottaviano again calls out and threatens witnesses who assist Plaintiffs and reiterates APA's intention to inappropriately draw out the lawsuit and deplete Plaintiffs' resources. (On September 10, 2018 Hoffman, Sidley Austin, and APA filed a request with the D.C. Court to further delay Plaintiffs' ability to reach the merits. See DC Litigation item 21.) 8/21/2018
34. On August 21, 2018 APA announced to all Council members via email that APA had revised and republished the APA timeline. Through an interactive link to the APA timeline provided in her email, and with the clear intention of reaching a wider audience than just those on the APA Council, APA through and on the direction of its General Counsel, Deanne Ottaviano, intentionally republished the September 4, 2015 Hoffman Report with David Hoffman's, Sidley Austin's and APA's clear knowledge and admissions of the falsehoods permeating in the Report. This anticipated republication was documented with the DC Court on July 23, 2018 and that document was served on Defendants' counsel. 8/21/2018
35. APA adds substantial new timeline content discrediting Hoffman's and Sidley's findings including: 1) The Division 19 Task Force Report Discrediting Hoffman's and Sidley's findings, 2) February 16, 2016 and May 15, 2016 (Hoffman's and Sidley's conflicts of interest) letters from the former Ethics Chairs, 3) June 12, 2016 letter from former APA Presidents, and an 4) "entry for February 16, 2017 stating, 'Five plaintiffs filed a lawsuit against the Association arising out of the publication of the Independent Review." (That complaint and the others identified the two copies and locations of two versions of the Reports on the APA website, see Ottaviano false representations to Council set forth in 33). 8/21/2018
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he Hoffman Report is full of speculation, unsubstantiated evidence, and innuendo.The Hoffman Report is full of speculation, unsubstantiated evidence, and innuendo.The The Hoffman Report is full of speculation, unsubstantiated evidence, and innuendo.The Hoffman Report is full of speculation, unsubstantiated evidence, and innuendo.
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