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John R. Cesario, Esq.
October 22, 1998
Page Three

him) in the course of his complaints.

2. That I engaged in a "blatant lie" by informing Mr. Bennett, that (a) none of Mr. Wilson's courses required the use of the University's computer labs and (b) he remains a student in good standing at the University.

In determining the accuracy of the first charge, the ARDC should take note that Mr. Wilson appears to have had two separate and distinct complaints against Northern Illinois University. First, he complained that he was denied adequate and/or timely accommodation for his disability. Second, even after being accommodated, he vociferously complained about his treatment at the hands of those charged with administering our Center for AccesstAbility Resources (CAAR), a service available to all students and faculty. His ARDC complaint should be considered within those dual contexts.

To begin, I am not certain who placed the words "did not" on my copy of Mr. Cunningham's letter, nor do I know the circumstances under which they were so placed. I cannot rule out the possibility that at some time I wrote those words although it does not appear to be my handwriting. The Cunningham letter speaks for itself and I have no doubt that the copy in Mr. Wilson's possession is the accurate one. That I copied my own file copy of the letter without noticing the two handwritten words is undeniable. Had the original words been crossed out, or otherwise stricken from Mr. Cunningham's letter, that would have been an indication that someone was trying to change an official document. However, that was not the case. Whoever added those two words could hardly have expected anyone to assume that the scribbled words substituted for the typed words in an official letter sent by the University's Director of Human Resource Services.

As important, the ARDC should consider the context and time frames of both my letter to Mr. Bennett and Mr. Cunningham's to Mr. Wilson. Cunningham's January 11, 1996, letter (included in Group Exhibit 1) was a reply to Mr. Wilson's complaints and noted that Mr. Wilson had requested no additional accommodation under the ADA (or otherwise) and that the ADA Committee had no jurisdiction to hear complaints about the job performance of University employees. It may be that the meetings to which Mr. Cunningham referred at the bottom of this letter were held in conjunction with Mr. Wilson's (eventually successful) attempts to obtain special equipment. I believe that it is true that Mr. Wilson did not subsequently meet with Mr. Bowen or Dr. Gresholdt -- the immediate supervisors of the CAAR office -- to press his complaints against the CAAR employees administrators.

Go to page four of Shur's response