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[Cached Version]
Published on: 6/1/2008
Last Visited: 6/1/2008
Upon information and belief Interim Dean Smith engaged in a concerted effort to terminate Dr. Aguayo from MSM by permitting discriminatory, hostile, and retaliatory actions by MSM African-American/black faculty and administration, including but not limited to Dr. Rose, Dr. Sanders, Dr. Ofili, Dr. Crawford, Dr. Reed and Interim President Satcher, in order to further the effort of the MSM "concerned faculty and staff, and the MSM BOT to permanently remove Dr. Aguayo from MSM.
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Upon information and belief and during approximately the same time as the allegations set forth above, Myra Rose, James Reed, Marvin Crawford, Lawrence "Dusty" Sanders, and Elizabeth Ofili, members of the MSM Department of Medicine faculty and staff, were unhappy with the governance of Dr. Aguayo as Chair of the Department of Medicine, specifically with the fact that Dr. Aguayo had worked for changes to the Professional Component Base Salary ("PCBS") compensation structure, that Dr. Aguayo was hiring non-blacks in positions of authority in the Department of Medicine, and that Dr. Aguayo demanded accountability and responsibility from the entire Department regardless of race.
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211. Upon information and belief, Dr. Rose engaged in such concerted activity in order to assist Dr. Reed in obtaining the position of Chief for Medicine for MSM at Grady Memorial Hospital, a position appointed by the Chair of the Department of Medicine and formerly held by Dr. Michael Heisler, a non-black. 212.
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Upon information and belief, Dr. Reed, in a concerted effort with "the concerned faculty and staff" and members of the MSM BOT, published and disseminated unsubstantiated allegations against Dr. Aguayo to MSM faculty, staff, BOT and the Composite Board, including but not limited to allegations of unlicensed practice of medicine and refusal to apply for a Georgia medical license, resulting in Dr. Aguayo,s removal and ultimate termination as Chair of the Department of Medicine.
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Upon information and belief, Dr. Reed engaged in such concerted activity in order to assist Dr. Rose in regaining the position of Interim Chair of the Department of Medicine.
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214. Upon information and belief, Dr. Reed engaged in such concerted activity because Dr. Aguayo was non-black and hiring non-blacks in the Department of Medicine.
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Upon information and belief, Dr. Reed engaged in such concerted activity in order to pressure Dr. Heisler to resign as Chief of Medicine for MSM at Grady, an appointment made by the Chair of the Department of Medicine.
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In fact, Dr. Heisler resigned as Chief of Medicine for MSM at Grady on or about July 2005 and Dr. Reed was appointed to that position by Dr. Rose.