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RAKOW'S COMPLAINT LAYS OUT HER CASE AGAINST UND

The lawsuit filed by Lana Rakow seeking damages and reinstatement as director of the UND School of Communication sets out the events that, according to Rakow, led up to her dismissal.

The following are highlights, in rough chronological order, as spelled out in Rakow's complaint:

July 1, 1994 -- Rakow takes office and is charged by the university with winning reaccreditation for the communication school. Accreditation had been lost several years before Rakow was hired.

The School of Communication was moved from the College of Arts and Sciences to the College of Fine Arts.

The UND Television Production Center and Northern Lights Public Radio were added to the communication school. They had been reporting directly to the vice president for academic affairs, Marlene Strathe.

March 16, 1995 -- Rakow sent a memo to Bruce Jacobsen, dean of the College of Fine Arts and Communication, stating that Barry Brode, director of the Television Production Center, refused to report to Rakow, who was then Brode's supervisor.

April 10, 1995 -- UND President Kendall Baker told Rakow the university would not provide additional money for the communication school to achieve accreditation.

Spring 1995 -- Strathe said Baker was considering transferring the television center to the Division of Continuing Education.

Sept. 6, 1995 -- Rakow was called to a meeting with Baker, Jacobsen, Strathe and Brode. Rakow was ordered not to talk to Strathe's budget officer, and Jacobsen said the "pissing contest" between Brode and Rakow was over. "When (Rakow) ... expressed concerns about the impact on accreditation of moving (the television center), Baker responded he had more important things to do than get the School of Communication accredited. Baker made his comments in a belittling and disrespectful manner directed toward (Rakow)."

Sept. 18, 1995 -- Communication school faculty deliver a memo of support for Rakow to Strathe and Jacobsen.

Sept. 19, 1995 -- Jacobsen sent Rakow an e-mail note stating Baker had decided to transfer the television center.

Sept. 21, 1995 -- Communication school faculty sent a memo to Jacobsen and Strathe protesting that $90,000 had been cut from the school's budget and asking the funds be restored.

Sept. 22, 1995 -- Communication school faculty voted to reject a proposed agreement that was to govern interactions between the school and the television center.

Oct. 6, 1995 -- Rakow reprimanded verbally and in writing "for allegedly failing to lead the faculty to an agreement with (the television center) and to accept the budget situation at the school."

Oct. 23, 1995 -- An accreditation consultant visits the UND campus and submits his report a week later to Jacobsen.

Despite requests from Rakow and the communication school faculty, Jacobsen doesn't give Rakow a copy of the consultant's report until Jan. 2, 1996. The report finds the school is likely to meet accreditation standards in all areas except one: administration. The report attributes that likely failure to "ruptures" in the relationships between Rakow on one hand and Jacobsen and Strathe on the other.

Feb. 19, 1996 -- Rakow sent a memo to Jacobsen as follow-up to a meeting held at her request to talk about what must be done to win accreditation. "Jacobsen ignored (Rakow's) memo until ... June 5," when he sent an e-mail in response to complaints from a communication school advisory council made up of communication professionals from outside the university.

April 25, 1996 -- Rakow was awarded the fine arts college's award for creative research. Jacobsen presented the award and Strathe sent a letter of praise.

April 26, 1996 -- Bob Boyd, dean of continuing education, and Brode asked Rakow to approach "a certain individual" to ask if the person would be willing to donate $750,000 to pay for the television production center's move into a new building on the west end of campus. Rakow declined, saying that would not be in the best interest of the communication school.

May 6, 1996 -- Rakow met with Baker to discuss her concerns about the school's budget.

May 14, 1996 -- Rakow sent a memo to Jacobsen complaining about lack of communication and raising questions about budget and accreditation. Jacobsen sent an e-mail May 17 saying Rakow should proceed with a positive attitude.

May 20, 1996 -- Rakow sent a memo to Baker complaining about her relationship with Jacobsen and asking that the communication school be made a free-standing unit under the vice president.

May 23, 1996 -- Rakow's advisory council of industry professionals met and heard a report on progress toward accreditation. The council approved a resolution supporting independent status for the communication school.

Baker told individual members of the advisory council Rakow was a "personnel problem" that he was going to "take care of."

June 3, 1996 -- Rakow sent a memo to Jacobsen stating he had discriminated against her as a woman.

June 13, 1996 -- Baker told Rakow he was turning her complaint of sexual discrimination over to the university lawyer's office for an investigation.

June 15, 1996 -- Jacobsen sent an e-mail to Strathe stating, in part, "this is a matter for the new director." That was a week before Rakow was dismissed as director.

June 21, 1996 -- Rakow received her contract for the 1996-97 school year, which she signed and returned.

July 19, 1996 (a Friday) -- Baker reported he had received the report from the investigation and would act on it the following week. The report concluded Rakow's complaints of sexual discrimination were unfounded.

July 22, 1996 (the following Monday) -- Rakow received a hand-delivered letter dismissing her as director. She remains as a professor of communication.

Grand Forks Herald, October 19, 1996