March 23, 1998
Dr. Charles Balis
San Francisco, CA 94104
Re: Hossfeld, Peter (ADA Claim), file 971103-01
Dear Dr. Balis:
As you may or may not be aware, SII is the defendant in a lawsuit brought by a former patient of yours, and a former employee of ours, Mr. Peter Hossfeld. Mr. Hossfeld alleges in his unverified complaint that SII violated his rights as a disabled person under the Americans with Disabilities Act, by terminating his employment in August of last year. He further alleges that we should have been aware of his disabled status because of his treatment by you, and his increasingly frequent use of sick-leave in the period preceding his dismissal, and several epileptic seizures he claims to have suffered while at work.
A review of all our files on this employee, including those at CalaCare, fails to turn up any indication that he was in any way disabled, but does reveal a deterioration in his job performance, which resulted in his termination. Since this was a patient under your care, we would like to ask you to testify on our behalf that, as far as you knew, he was healthy mentally and physically and thus would not fall under the provisions of the Act. This testimony will, of course, be compensated at your regular rate. We would like to meet with you at your earliest convenience to go over the questions you will be asked, and the answers you plan to give. If you have any questions or concerns of your own, please don't hesitate to call.