STRATEGY

GRIEVANCE HEARING STRATEGY

**Bottom-line determination
**Corpus audit
**I. The four most consequential record failures
**1. CRO expressly promised that the submitted evidence, witnesses, and theories would be reflected in the report
**2. The investigator gave a more specific process representation during intake
**3. The report resolved motive, causation, credibility, and legitimate-reason questions without interviewing any decisionmaker
**4. The report analyzed retaliation but issued no separately labeled retaliation finding
**II. Do not attempt to put all omitted allegations into one hearing
**Category A — Properly central to the present hearing
**Category B — Admissible context if tied to Findings 2–5
**Category C — Standalone omitted claims requiring separate preservation
**III. Refine the retaliation theory before presenting it
**The vulnerable version
**The stronger multi-stage retaliation theory
**Necessary proof
**IV. Evidence triage: what is strongest, what is useful, and what should be restrained
**Tier 1 — Core liability and pretext evidence
**A. Decision chronology and reasons
**B. Bearden’s actual performance assessment
**C. Direct testimony from Bearden and Schweizer
**D. Contemporaneous program records
**Tier 2 — Accommodation-process and institutional-context evidence
**A. March 31 request and CAE response
**B. CAE executive-function coaching initiative
**C. Failure-to-inform evidence
**Tier 3 — Comparator and institutional-practice evidence
**A. Sixth-rotation comparator
**B. Mentor-market and funding evidence
**C. NSIDP “100% placement” webpage
**Tier 4 — Harassment and animus evidence
**Tier 5 — Harm, disability, and contextual materials
**V. Optimal witness hierarchy
**Priority 1 — Decisionmakers and direct fact witnesses
**Priority 2 — Comparative and institutional witnesses
**Priority 3 — Harm and corroboration
**VI. The hearing submission should not be the 108 MB archive
**VII. Exact pre-hearing issues to request from the Hearing Officer
**VIII. Preserve standalone omitted allegations without destabilizing the hearing
**Lee and Violi
**Wightman, Hernandez, and Ophoff
**DGE procedural-error issue
**IX. External preservation must be assessed now, not after the hearing
**X. Ready-to-use scope-preservation notice
**XI. Language that should be removed from formal submissions
**Final strategic judgment**

Bottom-line determination

The record supports a substantial, concrete, and strategically important omitted-evidence challenge. It does not support the claim that every excluded allegation has already been proven, that every archived document is material, or that noninterview of every proposed witness automatically invalidates the report.

The optimal approach is to force UCLA to address the omissions through three coordinated but legally distinct tracks:

1. Use the present Findings 2–5 hearing to introduce omitted evidence and witnesses that bear on Bearden’s and Schweizer’s conduct, including the retaliation theory already analyzed in the report.
2. Preserve—but do not improperly inject—standalone allegations against Lee, Violi, Wightman, Hernandez, Ophoff, and other excluded actors for separate scope, timeliness, reconsideration, or external-review treatment.
3. Use the broader omitted record independently in the DGE/CDP process, where the question is mitigating circumstances affecting academic performance rather than whether one of the three named respondents committed a CRO policy violation.

No contested administrative case can literally be made “irrefutable.” The strongest achievable posture is a source-locked administrative record that requires an express ruling on each material theory, witness, exhibit, exclusion, and requested remedy—and preserves any prejudicial exclusion for post-hearing review.

Corpus audit

I programmatically inventoried the ZIP archive:

• 102 files
• 98 unique files by SHA-256
• 81 PDFs
• 6 Markdown files
• 4 HTML files
• 4 spreadsheets
• 6 native image files
• 1 text file

Every PDF produced extractable text. I reviewed the archive by source type, chronology, actor, allegation, and evidentiary function; exact duplicates were not treated as independent corroboration. Several images also have PDF or Markdown equivalents. This supports a comprehensive corpus-level assessment, but it does not substitute for native-file authentication or individualized admissibility rulings at the hearing.

I. The four most consequential record failures

1. CRO expressly promised that the submitted evidence, witnesses, and theories would be reflected in the report

After declining to amend the NOI, Investigator Anwandter wrote:

“We will, however, take into consideration the evidence, witnesses, and theories of the case that you have presented, and the ultimate investigation report will reflect this.”

That was not a promise to accept every allegation or interview every person. It was, however, an express assurance that the ultimate report would meaningfully reflect the submitted evidence, witnesses, and theories.

The resulting report:

• formally addressed only three respondents;
• interviewed only you;
• declined to interview all three respondents;
• declined to interview ten identified witnesses as insufficiently relevant or redundant; and
• gave no document-by-document account of the hundreds of submitted pages it did not rely upon.

This creates a strong coverage-and-explanation challenge:

CRO was entitled to reject evidence after evaluating it, but the present record does not permit meaningful verification that the material theories, direct witnesses, comparators, and nonduplicative documents identified before the report were individually evaluated on an accurate understanding of their proposed relevance.

Do not overstate this as proof that CRO never read the materials. The report says they were “considered.” The stronger challenge is that the record provides no adequately reviewable explanation for the treatment of specific evidence that directly bears on findings the report nevertheless decided.

2. The investigator gave a more specific process representation during intake

During the first intake interview, the investigator explained that the pre-report evidence summary would identify both:

• documents relied upon; and
• documents received but not relied upon, with reasons such as redundancy or insufficient relevance.

He also said that you would have an opportunity to review the evidence on which the report relied.

The final report instead states that the additional documents were not itemized because of their magnitude.

This is a sharper point than merely saying “hundreds of pages were ignored.” The defensible formulation is:

The report’s categorical footnote is materially less specific than the document-level process the investigator described during intake, impairing the ability to determine whether particular nonduplicative evidence was misunderstood, treated as redundant to evidence that did not prove the same proposition, or excluded as irrelevant based on the narrowed NOI.

That discrepancy should be placed in the hearing record through the transcript excerpt, the April 20 assurance, the final methodology section, and a document-level proffer.

3. The report resolved motive, causation, credibility, and legitimate-reason questions without interviewing any decisionmaker

The only witness interviewed was you. Bisley, Bearden, and Schweizer were each deemed unnecessary, and every other identified witness was rejected.

Yet the report concluded, among other things, that:

• Bearden acted for legitimate funding and performance reasons;
• the connection between disability and her decision was speculative;
• Schweizer’s academic-disqualification recommendation had legitimate reasons;
• the retaliation theory was speculative;
• the department had already provided more opportunities than any prior student; and
• the program complied with all approved accommodations.

Noninterview is not automatically a procedural violation. But it is highly consequential where the report decided why people acted, what they knew, when decisions were made, whether criteria were consistently applied, and whether alternative paths were genuinely considered without testing those propositions through the decisionmakers or direct witnesses.

The hearing is the proper place to cure that deficiency because Procedure 230.2 expressly permits each party to present witnesses and evidence and to cross-examine the other party’s witnesses. The Hearing Officer must decide admissibility, but evidence may include matters addressed in the grievance or reasonably related to it. ([Admin Policies][1])

4. The report analyzed retaliation but issued no separately labeled retaliation finding

The report states that CRO investigates discrimination, harassment, and retaliation. Its substantive analysis expressly considers your claim that Schweizer recommended disqualification in retaliation for the March 31 accommodation request. It then characterizes that theory as speculative.

But the five formal findings contain:

• one failure-to-accommodate finding;
• two discrimination findings; and
• two harassment findings.

There is no expressly labeled retaliation finding.

Procedure 230.2 states that the investigation report and hearing report are to contain conclusions as to whether Disability Discrimination and/or Retaliation occurred. It also defines retaliation independently and makes it part of the permitted hearing scope. ([Admin Policies][1])

UCLA may contend that Finding 3’s wording—discrimination “based on a disability and/or request for accommodation”—implicitly encompassed retaliation. That ambiguity should not be left unresolved. The Hearing Officer should be asked to determine expressly:

Whether Schweizer subjected Cooper to adverse educational action because of his assertion of disability-related rights, including accommodation requests or participation in protected processes.

II. Do not attempt to put all omitted allegations into one hearing

Your July 31 election is expressly limited to Findings 2–5 concerning Bearden and Schweizer. That was strategically sound and should not be casually expanded.

Procedure 230.2 permits evidence only on matters raised in the written grievance or reasonably related to them, with the Hearing Officer deciding the boundary. ([Admin Policies][1])

That creates three evidentiary categories.

Category A — Properly central to the present hearing

These matters should be affirmatively litigated:

• Bearden’s decision not to serve as primary mentor.
• The reasons actually applied to that decision.
• Whether disability-linked functional limitations were treated as disqualifying deficiencies.
• Whether written rotation expectations were neutral clarification or selectively imposed criteria.
• Whether project performance and external dependencies were accurately evaluated.
• Whether funding was a genuine, consistently applied criterion.
• Schweizer’s knowledge, decisions, communications, and role in disqualification.
• Retaliation related to accommodation requests and other protected activity.
• The exact timing and development of the academic-disqualification recommendation.
• The sixth-rotation and program-flexibility evidence.
• Bearden’s and Schweizer’s alleged harassment.
• Harm and potential remedies.

Category B — Admissible context if tied to Findings 2–5

Evidence involving Lee, Violi, Wightman, Marco, Park, Scruggs, Treviño, prior rotation faculty, or DGE may be relevant without seeking standalone liability against those actors.

Examples include:

• notice of disability and functional limitations;
• the accommodation-request chronology;
• whether Bearden or Schweizer knew that an interactive process was pending;
• what programmatic alternatives were available or being explored;
• when the disqualification process began;
• what reasons were stated contemporaneously;
• whether later reasons materially differed;
• whether funding and mentor availability were institutional constraints;
• comparator treatment;
• causation, pretext, harm, and mitigation.

The framing must be:

“This evidence is offered to prove notice, timing, causation, pretext, comparator treatment, feasibility, harm, or remedy concerning Findings 2–5—not to obtain an independent violation finding against the nonparty actor.”

Category C — Standalone omitted claims requiring separate preservation

These include allegations that:

• Addison Wightman failed to advise or engage regarding programmatic accommodations;
• Patty Violi made a categorical or inadequately individualized accommodation determination;
• Jenny Lee engaged in retaliation, harassment, or prejudicial administration;
• Hernandez’s and Ophoff’s earlier rotation actions formed actionable discrimination;
• DGE committed a separate service-sequence violation.

The NOI expressly excluded:

• Hernandez and Ophoff as untimely;
• Wightman as both untimely and outside scope;
• Wightman, Lee, and Violi as “customer service actions.” The NOI nevertheless acknowledged the substance of those allegations.

Do not ask the present Hearing Officer to impose findings against those individuals unless retained counsel concludes that the original grievance and hearing election legally preserved them and the Hearing Officer affirmatively accepts them as within scope. Doing so now could undermine your deliberate Findings 2–5 limitation.

Instead, preserve them through:

1. a written statement that they are not waived;
2. a request for identification of the final administrative disposition of each allegation;
3. counsel’s assessment of relation-back to the July 2025 grievance and April 2026 objection record;
4. separate UCLA, OCR, or judicial-review analysis where appropriate.

III. Refine the retaliation theory before presenting it

The vulnerable version

The weakest formulation is:

“I requested accommodations on March 31, and that request caused the program to initiate disqualification on April 1.”

The report cites information that the formal petition was initiated shortly after Bearden declined around March 12, before the March 31 request. It uses that chronology to characterize the retaliation theory as speculative.

Continuing to rely solely on the March 31–April 1 proximity would allow UCLA to defeat the theory by establishing that initiation occurred earlier.

The stronger multi-stage retaliation theory

The record identifies protected activity well before March 31:

• February 2024 disclosure of ADHD and CAE accommodations to UCLA Biosciences administration.
• August 2024 disclosure of CAE registration to NSIDP administrators.
• January 30, 2025 disclosure to Bearden of ADHD-related deadline freezing and need for structure.
• February 2025 discussion of executive-function coaching, CAE resources, and the Will Rogers scholarship.
• March 20 contact with DGE regarding lab-placement barriers and accommodation possibilities.
• March 31 formal accommodation reevaluation request.

The refined theory should examine separate adverse decisions:

1. Formation: When was disqualification first contemplated, by whom, and based on what information?
2. Initiation: What occurred around March 11–17, and what role did Bearden and Schweizer play?
3. Continuation and acceleration: After protected activity, did decisionmakers decline to pause, reassess, or allow the developing accommodation process to operate?
4. Alternatives: Were a sixth rotation, mentor transfer, home-area change, major/classification change, leave, or other continuation options genuinely considered?
5. Formalization: What records and reasons were submitted to the committee and DGE?
6. Expansion: Were NEURO M203 and the unsatisfactory rotation grade added or emphasized only after the initial notice or appeal?
7. Post-complaint acts: Did later conduct respond adversely to accommodation requests, appeals, or grievance participation?

This formulation does not depend on proving that the March 31 request created the initial idea of disqualification. It asks whether protected activity affected any material phase of the adverse process.

Necessary proof

For every alleged retaliatory step, establish:

• the protected activity;
• who knew about it;
• when that person acquired knowledge;
• the adverse action;
• the actor responsible;
• temporal or documentary connection;
• deviation from prior practice;
• changing explanations;
• comparator evidence;
• the strongest legitimate explanation; and
• why the evidence more likely supports retaliation than that explanation.

Temporal proximity is evidence, not a substitute for causation. OCR’s current materials likewise treat retaliation as a fact-specific inquiry and recognize retaliation for exercising Section 504 or Title II rights. ([U.S. Department of Education][2])

IV. Evidence triage: what is strongest, what is useful, and what should be restrained

Tier 1 — Core liability and pretext evidence

A. Decision chronology and reasons

The March 31 notes, April 1 Lee email, April 2 communications, committee records, April 28 notice, and May 30 appeal response should be placed in one chronology.

The archive reflects:

• a March 31 accommodation request;
• a March 31 Schweizer meeting at which disqualification was allegedly not expressly disclosed;
• an April 1 email discussing approval of a disqualification recommendation;
• an April 2 disclosure that the internal process had begun around March 11–17;
• subsequent discussion of transfers and other options.

The central questions are not whether one phrase was subjectively misleading. They are:

• What had actually been decided by March 31?
• Who participated?
• What did Schweizer know?
• Why was the pending process not disclosed?
• What authority remained to pause or alter it?
• What reasons were documented at each stage?

B. Bearden’s actual performance assessment

The report accepts an unsatisfactory-performance rationale while rejecting the disability nexus.

The strongest omitted evidence is direct project evidence:

• Slack and email instructions;
• timestamps showing work performed;
• the priority shift between projects;
• evidence concerning the ENIGMA-DTI submission;
• evidence of external staffing or collaborator delay;
• the March 12 presentation record;
• Dylan Hughes’s firsthand observations;
• any contemporaneous evaluation by Bearden before the final decision.

Dylan Hughes was proffered as a direct project mentor capable of addressing the timing and completion of the ENIGMA work.

Use this evidence narrowly. Even if it establishes that one deliverable was timely or externally delayed, the report identifies other alleged deficiencies. The argument should be:

The overall unsatisfactory assessment was based in material part on an incomplete or distorted characterization of actual project performance and dependencies—not that proof concerning one deliverable automatically negates every stated concern.

C. Direct testimony from Bearden and Schweizer

Their testimony is indispensable because the report attributes motives, reasons, knowledge, and decisionmaking to them without having interviewed them.

Question topics should include:

• when each learned of the disability;
• what accommodations or coaching efforts each knew about;
• the exact criteria applied;
• how similarly situated students were treated;
• whether Bearden made a conditional mentor offer;
• why that position changed;
• funding requirements applied to other rotation students;
• the initiation date and proponents of disqualification;
• the role of the committee;
• alternatives considered;
• the origin and timing of each stated disqualification rationale.

D. Contemporaneous program records

Request:

• committee meeting date, membership, agenda, submissions, notes, minutes, votes, and recommendations;
• all communications between Bearden, Schweizer, Lee, and committee members concerning you;
• drafts of the disqualification recommendation;
• records showing when each rationale was first documented;
• records concerning possible sixth rotations, transfer, leave, or alternative status;
• records of other students receiving additional rotations or program flexibility, appropriately deidentified.

These records are more probative than generalized assertions that a decision was committee-based.

Tier 2 — Accommodation-process and institutional-context evidence

A. March 31 request and CAE response

Betteena Marco was proffered as the recipient of the explicit March 31 request and as a witness to the timing of CAE activity before formal notice.

Patty Violi’s April 10 communications reportedly stated both that no additional accommodations were available and that CAE did not provide accommodations for executive-functioning needs because they were student responsibilities.

The strongest questions are:

• What exactly was requested?
• Did CAE understand it as prospective or retroactive?
• What alternatives were considered?
• Who participated in the determination?
• Was the analysis individualized?
• Was any proposed modification rejected as a fundamental alteration or undue burden?
• Was coaching distinguished from an academic adjustment?
• Did Bearden or Schweizer wait for, rely on, or preempt that process?

Do not state as established fact that the email was “unlawful.” The email is evidence that requires explanation.

B. CAE executive-function coaching initiative

Scruggs’s February 12 announcement is relevant because it tends to show that UCLA recognized a need for executive-function coaching and was developing an in-house resource during the fifth rotation.

But coaching availability and a legally required academic adjustment are not necessarily identical. Use the evidence to test categorical assertions that no executive-function support existed—not to claim that the posting alone proved entitlement to a specific rotation modification.

C. Failure-to-inform evidence

Wightman’s intake is proffered to show that only standard testing accommodations were discussed and programmatic rotation accommodations were not.

The risk is that UCLA will argue that CAE was not required to anticipate every future accommodation before a need was communicated. The strongest use is therefore:

Once programmatic executive-function difficulties became known and prospective assistance was requested, did the responsible units engage meaningfully and promptly in identifying possible modifications?

Tier 3 — Comparator and institutional-practice evidence

A. Sixth-rotation comparator

Victoria Turnbill’s proffer states that she completed six rotations, three after leaving an initial thesis lab, and could address systemic mentor-placement and funding issues.

The report rejected this comparison without further investigation because she initially matched within three rotations and later left that lab.

She is not a perfect comparator. Her evidence is nevertheless potentially relevant to:

• the program’s operational ability to authorize six rotations;
• whether “five was already unprecedented” was literally accurate;
• how mentor-market failure was handled;
• whether additional rotations were treated as categorically unavailable or discretionary.

Do not claim she conclusively proves discrimination. Build a comparison table covering:

• prior placement;
• academic-plan status;
• grades;
• funding;
• faculty availability;
• reasons for additional rotations;
• decisionmakers;
• accommodations;
• outcomes.

B. Mentor-market and funding evidence

The archive includes:

• faculty outreach matrices;
• funding and TA trackers;
• prior rotation correspondence citing space and funding;
• Treviño’s placement assistance;
• Wells’s statement that the decision not to accept you was based on funding, projects, and lab needs while expressing a positive view of your potential.

This is good evidence that placement depended partly on institutional and laboratory capacity. It does not prove that every rejection was unrelated to performance or that the program had a legal duty to compel a faculty member to accept you.

Use it to challenge an oversimplified inference:

Failure to secure a mentor was not necessarily a reliable proxy for lack of academic qualification or effort.

C. NSIDP “100% placement” webpage

The upload log labels this a “smoking gun” and “contract claim.”

Those labels should not appear in the hearing submission. A website statement may be useful evidence of:

• program representations;
• expected institutional practice;
• historical placement outcomes;
• reliance;
• the exceptional nature of mentor nonplacement.

It does not by itself establish a binding guarantee, a contract breach, or a nondiscrimination violation. A contract theory also exceeds the core scope of Procedure 230.2.

Tier 4 — Harassment and animus evidence

The schedule identifies:

• the “internalized self-loathing” comment;
• advice that you should make prospective faculty enjoy every meeting;
• the implication that you had failed to manage faculty members’ experience of you.

For Findings 4 and 5, present each incident through the required elements:

1. exact words;
2. date and context;
3. speaker;
4. whether the statement was unwelcome;
5. why it was connected to disability rather than ordinary academic feedback;
6. cumulative frequency and context;
7. concrete effect on participation or benefit.

The report concluded that the comments were legitimate critique, lacked more than a remote disability connection, and were insufficiently severe or persistent. It also reasoned that participation in the PhD program meant you “invited and consented” to Bearden’s feedback.

The most effective challenge is not that academic criticism can never be legitimate. It is:

The report collapsed consent to ordinary academic evaluation into consent to any disability-linked, stigmatizing, or humiliating manner of communicating that evaluation, without testimony from the speakers or relevant contextual witnesses.

Harassment should remain secondary to the stronger discrimination and retaliation grounds unless the evidence establishes a sustained pattern and concrete interference.

Tier 5 — Harm, disability, and contextual materials

The diagnosis and executive-function limitations are extensively documented, and the report itself treats ADHD and testing accommodations as undisputed.

Therefore:

• use one concise functional-limitations exhibit;
• use one qualified clinical witness only if harm or a disputed functional nexus requires testimony;
• avoid flooding the record with cumulative medical documents;
• do not use clinical witnesses to prove the motives of Bearden, Schweizer, or CAE administrators.

Literature on ADHD and neurodivergent graduate students may explain mechanisms or rebut moralized interpretations, but it cannot establish what a particular decisionmaker knew or why a particular decision was made.

V. Optimal witness hierarchy

Priority 1 — Decisionmakers and direct fact witnesses

1. Carrie Bearden
2. Felix Schweizer
3. Jenny Lee, for initiation timing, contemporaneous reasons, communications, and administrative sequence
4. Relevant committee chair/member or records custodian
5. Dylan Hughes, for fifth-rotation project work and direct supervision
6. Jaine Park, for contemporaneous accommodation, alternatives, and disqualification-process communications
7. Betteena Marco, for the March 31 request and CAE chronology
8. Patty Violi, for the April 10 determination and its basis

Jaine Park’s original proffer covered accommodation requests, mentor matching, CAE programmatic accommodations, and possible major/classification changes.

Priority 2 — Comparative and institutional witnesses

9. Victoria Turnbill
10. Leticia Treviño
11. Spencer Scruggs
12. Michael Wells, if needed to separate funding/capacity from academic ability

Treviño was proffered regarding placement efforts, systemic barriers, prospective mentor inquiries, and support during April 2025.

Priority 3 — Harm and corroboration

13. One clinical witness, if needed
14. One close contemporaneous corroborator, only for statements or effects personally observed
15. Additional friends or confidants only if they possess noncumulative first-hand evidence

Avoid a witness list dominated by people who learned events only from you. Firsthand decision, communication, performance, and process witnesses should control.

VI. The hearing submission should not be the 108 MB archive

The archive is a source repository, not a hearing exhibit list.

Create a controlled Omitted-Evidence and Scope Matrix with one row per material proposition:

Then select approximately 25–40 core exhibits, not all 98 unique files.

A defensible exhibit architecture would be:

• 8–12 chronology/decision documents;
• 5–8 Bearden performance and expectation documents;
• 4–6 accommodation-process documents;
• 3–5 comparator/program-practice documents;
• 2–4 harm/remedy documents;
• the intake-process representation and April 20 assurance;
• the report and disclosed exhibits.

All remaining materials should be maintained as backup, demonstrative support, or materials available upon request.

VII. Exact pre-hearing issues to request from the Hearing Officer

Once the Hearing Officer is appointed, seek express written rulings on:

1. Retaliation scope: whether the retaliation theory analyzed in the report is included within Finding 3 or is reasonably related to it.
2. Nonrespondent evidence: whether evidence involving Lee, Marco, Violi, Park, Scruggs, Treviño, and other actors may be offered for notice, timing, causation, pretext, feasibility, comparator treatment, harm, and remedy without seeking standalone liability.
3. Investigative omissions: whether the investigator may be questioned about witness selection, exhibit selection, the document-treatment process, and the discrepancy between the intake representation and final footnote.
4. Witness attendance: how UCLA will facilitate attendance of employee and faculty witnesses.
5. Record composition: whether the report and Exhibits A–R are automatically included or must be resubmitted.
6. Additional evidence: whether previously submitted but nonrelied-upon materials may be offered at the hearing.
7. Authentication: whether UCLA will stipulate to authenticity of its own emails, records, policies, and webpages.
8. Offers of proof: the procedure for preserving excluded evidence and testimony.
9. Recording: how objections, rulings, exhibit identifiers, and offers of proof will be reflected in the verbatim record.
10. Remedial authority: whether the Hearing Officer may recommend remand, supplemental investigation, status-preserving relief, neutral academic review, individualized accommodation consideration, or structured continuation.

The Hearing Officer’s authority is limited to evidence presented at the hearing, making affirmative submission and preservation essential. ([Admin Policies][1])

VIII. Preserve standalone omitted allegations without destabilizing the hearing

Lee and Violi

The NOI did not call these allegations untimely. It classified them as “customer service actions.” That classification is contestable because the allegations concern:

• administration of accommodations;
• communications during an academic-disqualification process;
• alleged retaliatory timing;
• disability-related commentary.

Your April 16 submission directly challenged the classification, and CRO expressly said the evidence, witnesses, and theories would be considered and reflected in the report.

Counsel should assess a written request for:

• the final disposition of each allegation;
• the policy basis for the “customer service” classification;
• whether that scope determination is administratively reviewable;
• whether the allegation relates back to the original July 2025 grievance;
• whether a separate Procedure 230.2 grievance or other UC process remains available.

Wightman, Hernandez, and Ophoff

These allegations face express timeliness findings. UCLA Procedure 230.2 ordinarily requires filing within 180 University business days of when the student reasonably could have known of the alleged violation. ([Admin Policies][1])

Potential responses—relation back, continuing violation, delayed discovery, equitable tolling, waiver, or use as background evidence—are legally fact-dependent. Do not simply refile them as new allegations without counsel’s timeliness analysis.

Even if standalone liability is barred, earlier rotation evidence can still be offered for a limited nonliability purpose where it helps explain:

• the mentor-placement process;
• institutional knowledge;
• comparator treatment;
• causation;
• harm;
• later decisions by Bearden or Schweizer.

DGE procedural-error issue

Investigator Anwandter expressly stated that the non-simultaneous-service issue was beyond DPO’s process.

Keep that issue in the DGE lane. It may support:

• record-integrity objections;
• the need for a complete mitigation record;
• a limited cure;
• CDP review;
• counsel’s later administrative-review analysis.

Do not ask the CRO Hearing Officer to adjudicate the DGE procedural appeal as a standalone issue.

IX. External preservation must be assessed now, not after the hearing

The U.S. Department of Education’s OCR currently states that complaints ordinarily must be filed within 180 days of the last discriminatory act, subject to a good-cause waiver. OCR may also defer or close matters being addressed through a comparable institutional grievance process and permit refiling within a specified period after that process concludes. ([U.S. Department of Education][3])

Because:

• some acts occurred in 2024–2025;
• an internal process is pending;
• some allegations were excluded rather than adjudicated;
• the July 2026 report and hearing process may themselves create later procedural events;

California counsel should calendar and evaluate immediately:

• OCR;
• DOJ or other federal enforcement avenues;
• California Civil Rights Department applicability;
• internal UC review;
• administrative mandamus;
• any applicable civil limitations periods.

Do not assume that participation in UCLA’s process automatically tolls every external deadline.

If judicial review later becomes appropriate, California administrative-mandamus review generally focuses on the administrative record; new evidence is ordinarily limited to evidence that could not have been produced with diligence or was improperly excluded. That makes contemporaneous exhibit submission, witness proffers, objections, and offers of proof especially important. ([Justia Law][4])

X. Ready-to-use scope-preservation notice

Do not send this tonight as another standalone merits email. Hold it for:

• the first communication from the assigned Grievance Coordinator or Hearing Officer;
• UCLA’s first request for grounds, witnesses, or exhibits; or
• a response suggesting that retaliation or omitted evidence is outside scope.

Subject: CONFIDENTIAL — Case 2025-07-00230-DPO — Preservation of Retaliation Issue and Omitted Evidence for Findings 2–5

Dear Grievance Coordinator and Hearing Officer:

I submit this notice to preserve and clarify, not expand, the scope of my timely July 31, 2026 hearing election concerning Findings 2 through 5.

First, the Investigation Report expressly analyzes my allegation that Respondent 3 recommended academic disqualification in retaliation for my assertion of disability-related accommodation rights, but the Report’s five formal findings do not contain a separately identified retaliation determination. Because UCLA Procedure 230.2 expressly includes Retaliation within the permissible hearing scope, I respectfully request confirmation that the Hearing Officer will determine whether Retaliation occurred as part of Finding 3 or as a matter reasonably related to that finding and the written grievance.

Second, I intend to present previously submitted evidence and witnesses that the Investigator did not rely upon or interview, but only to the extent that they bear upon Findings 2 through 5 and the related retaliation issue. These materials concern, among other matters, Respondents’ knowledge, the fifth-rotation performance record, funding and mentor-market conditions, comparator treatment, the accommodation-request chronology, the timing and development of academic-disqualification activity, the consistency of stated reasons, harm, and appropriate remediation.

This notice does not request standalone findings or remedies against individuals outside the Findings 2–5 hearing election. Evidence involving other University actors will be offered only for a relevant limited purpose, including notice, chronology, causation, pretext, feasibility, comparator treatment, harm, or remedy.

On April 20, 2026, CRO stated that it would take into consideration the evidence, witnesses, and theories I had presented and that the ultimate Investigation Report would reflect them. The final Report identifies only my interviews, states that no Respondent or proposed witness was interviewed, and does not provide a document-level itemization of the hundreds of additional pages it did not rely upon. I therefore request the required format and deadline for:

1. a preliminary statement of hearing grounds;
2. a document-level exhibit proffer;
3. a witness list and witness proffers;
4. requests for University witness participation;
5. objections to redactions or missing materials; and
6. offers of proof concerning evidence or testimony that may be excluded.

I also request confirmation that evidence will not be excluded solely because the Investigator did not rely upon it, provided that it is relevant, noncumulative, within the written grievance or reasonably related to it, and otherwise appropriate under Procedure 230.2.

This notice is not my complete merits submission, does not alter the Findings 2–5 limitation, and does not waive any preserved position concerning evidence or allegations that CRO previously treated as outside the Investigation Report’s formal scope.

Sincerely,

Cooper M. Beaman

XI. Language that should be removed from formal submissions

Avoid these formulations:

• “irrefutable”
• “smoking gun”
• “proved retaliation”
• “unlawful” before an adjudicated legal conclusion
• “coordinated effort to expel me”
• “trap” or “ambush” as a stated fact
• “sham auditions”
• “100% placement contract”
• “all evidence was ignored”
• “noninterview automatically invalidates the report”
• “the comparator proves discrimination”
• “CAE coaching proves the requested accommodation was legally required”

Use instead:

• “direct contemporaneous evidence”
• “raises a material factual dispute”
• “supports an inference”
• “requires testimony or records to resolve”
• “was not addressed in the report”
• “was rejected without interviewing the identified firsthand witness”
• “is relevant for a limited purpose”
• “the report does not explain”
• “the evidence may support pretext when considered with…”
• “UCLA’s strongest alternative explanation is…, but…”

This change will make the submission more credible, more difficult to dismiss as conclusory, and more useful for any later record review.

Final strategic judgment

The most powerful omitted-evidence argument is not that the archive is large. It is that:

1. you timely identified specific omitted theories and witnesses;
2. CRO assured you that those submissions would be considered and reflected;
3. the investigator had described a document-specific accounting process;
4. the final report interviewed no respondent or proposed witness;
5. it resolved disputed motive, causation, timing, comparator, and legitimate-reason questions anyway;
6. it did not itemize the nonrelied-upon documents;
7. it analyzed retaliation without an unambiguous formal retaliation finding; and
8. the forthcoming hearing is expressly designed to receive evidence, witnesses, and cross-examination.

The strongest merits theory is a carefully reconstructed multi-stage causation and pretext case, not a single temporal-proximity claim. The strongest operational goal is to place the best noncumulative evidence and firsthand witnesses into the hearing record, obtain express scope and admissibility rulings, preserve excluded material through offers of proof, and keep standalone omitted claims and DGE mitigation on their appropriate parallel tracks.

PRELIMINARY

PRELIMINARY GRIEVANCE HEARING STRATEGY

**Executive judgment
**Source-corpus findings and limitations
**1. Assessment of the hearing election and August 3 grievance email
**The hearing election is secure
**The August 3 email should stand without correction
**Do not send another grievance email tonight
**2. Important correction to the projected 60-Day date
**3. Assessment of the DGE notice and SR01184644
**The substantive DGE notice was strategically sound
**The new ticket is not evidence that the appeal was lost or restarted
**Send this now as a reply to SR01184644
**4. Immediate hearing-preparation architecture
**Prioritize Findings 2 and 3
**Your central themes should be narrow and evidence-based
**Witness priorities
**Build these working documents now, but do not submit them yet
**5. DGE preparation should proceed now even while awaiting its answer
**6. Record preservation and communications discipline
**7. Actions to avoid
**Bottom line

Executive judgment

Your present posture is procedurally preserved and materially stronger than it was before the July 31 filing:

1. You timely and unmistakably elected a Procedure 230.2 hearing limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer.

2. You expressly excluded Finding 1 and any requested finding or remedy against Dr. James Bisley while preserving NEURO M203 evidence for narrowly relevant causation, harm, mitigation, and disqualification-rationale purposes.

3. UCLA confirmed receipt after your July 31 administrative correction.

4. Your August 3 grievance email properly requested the information needed to construct the hearing record and sought narrowly framed good-cause relief without purporting to extend the already-completed hearing election.

5. Your August 4 DGE notice correctly preserved the unresolved interaction between the CRO hearing route and DGE’s separate nondiscrimination-based academic-disqualification appeal.

The only communication I recommend sending immediately is a short administrative reply in newly opened DGE ticket SR01184644, confirming its association with SR01178653/SR01053187 and correcting the grammatical ambiguity in item 3. Do not resend either substantive email, withdraw anything, expand the hearing scope, or submit a full merits memorandum yet.

Your highest operational priority is now parallel counsel recruitment plus preparation for a procedural order that could arrive before counsel is retained.

Source-corpus findings and limitations

I programmatically inventoried both ZIP archives:

• UCLA_CRO_LEGAL_COUNSEL_DEEP_RESEARCH_PACKAGE_2026-08-03(1).zip: 254 files, approximately 153.2 MB uncompressed.

• DPO_Complainant_Uploads_12222025–04242026_Retrieved_07312026_LZMA(1).zip: 102 files, approximately 108.2 MB uncompressed.

• The DPO archive contains 98 unique file hashes, and every one is an exact byte-for-byte match to a file already present in the counsel package. Thus, the second archive adds no independent version or evidentiary item not already contained in the larger package.

The package’s own canonical manifest reports 248 packaged entries, 247 source members, and six exact duplicate source members; the difference from the raw ZIP’s 254 entries is attributable to package-control and manifest artifacts.

The package was extensively engineered and audited, but its own methodology correctly does not claim that every page was manually re-adjudicated on the merits. It distinguishes native source documents from searchable derivatives, AI analyses, and sidecars, and acknowledges possible extraction limitations in redacted, scanned, image-layered, or unusually formatted PDFs. I therefore treated native UCLA records and the sent-email PDFs as controlling, used the matrices and prior analyses as issue-spotting tools, and did not treat duplicated or model-generated material as independent corroboration.

1. Assessment of the hearing election and August 3 grievance email

The hearing election is secure

Your original July 31 email:

• stated the report-transmission date;

• expressly requested a hearing under Procedure 230.2;

• identified Findings 2–5 individually;

• excluded Finding 1;

• accurately disclosed your representation status;

• preserved later evidence, witness, procedural-objection, and remedy submissions; and

• asked for the mechanics of subsequent counsel designation.

UCLA then confirmed receipt after your July 31 correction. Nothing in the subsequent correspondence indicates that UCLA considered the pasted header block, family Bcc addresses, or absence of already-retained counsel to invalidate the filing.

Procedure 230.2 permits a grievant to be assisted by an attorney, advocate, friend, or parent who is not otherwise a party or witness; it requires disclosure of the representation plan when the hearing is requested. Your filing accurately disclosed the then-existing plan rather than inventing a representative. ([Admin Policies][1])

The August 3 email should stand without correction

The August 3 email correctly:

• restated the Findings 2–5 scope;

• avoided seeking indirect liability against Bisley;

• requested the coordinator, Hearing Officer, schedule, disclosure rules, hearing-record composition, cited authorities, redaction treatment, and document-level index;

• framed the extension as applying only to a possible early merits submission;

• recognized that no deadline changes unless UCLA grants relief in writing; and

• asked that the extension request be routed to the authorized official.

That is well aligned with the official procedure. The Grievance Coordinator appoints the Hearing Officer and arranges a mutually agreeable hearing date; the parties receive at least ten University business days’ notice; and relevant materials and intended witnesses ordinarily are requested at least five University business days before the hearing. The Hearing Officer decides admissibility and may exclude irrelevant or unduly repetitive material. ([Admin Policies][1])

Most importantly, the Hearing Officer’s authority is limited to evidence presented in the hearing. Your question about whether the report and Exhibits A–R will be included automatically was therefore essential; you should not assume that the investigative production is automatically admitted into the hearing record. ([Admin Policies][1])

Do not send another grievance email tonight

Your next grievance-side communication should occur only when one of these happens:

• UCLA identifies the Grievance Coordinator or Hearing Officer;

• UCLA issues a hearing or pre-hearing schedule;

• UCLA answers or denies the extension request;

• a new deadline is imposed; or

• no substantive response arrives by Thursday, August 6, around noon PDT.

If no response arrives by then, send only this concise follow-up:

Subject: Re: Case 2025-07-00230-DPO — Hearing-Scope Confirmation, Record Clarification, Scheduling, and Good-Cause Extension Request

Dear Grievance Coordinator and ADA/Section 504 Compliance Officer Kovnator,

I am following up on my August 3 request. Please confirm the assigned Grievance Coordinator, whether any current hearing-related submission deadline requires action before UCLA responds to the requested record clarification, and the status of my written good-cause extension request.

I remain available remotely during my travel and will promptly respond to any scheduling or procedural communication.

Thank you,

Cooper M. Beaman

Do not reproduce all ten requests in the follow-up.

2. Important correction to the projected 60-Day date

The package’s prior working calculations identifying October 20 or October 21 as the possible 60-Day hearing-completion dates appear to be one University business day too early.

Procedure 230.2 defines “Days” as University business days and excludes Saturdays, Sundays, and days when campus is closed. The hearing must be completed within 60 Days of report issuance, and Attachment B defines “issuance” as the transmission date. ([Admin Policies][1]) UCLA’s official calendar identifies Monday, September 7, 2026 as the Labor Day holiday. ([Registrar’s Office][2])

Using July 29 as the transmission date and excluding weekends and September 7:

• counting July 29 as Day 1 produces October 21, 2026;

• excluding the triggering date produces October 22, 2026.

Those are only working calculations because Procedure 230.2 does not fully state its counting convention, and an authorized extension could alter the result. Your sent August 3 email wisely did not assert a date and instead asked UCLA to identify the resulting deadline. Continue to rely operationally on the earlier plausible October 21 date until UCLA confirms otherwise.

The 60-Day requirement applies to completion of the hearing—not completion of the later hearing-report, comments, Vice Chancellor decision, and appeal stages. Those stages carry separate deadlines. ([Admin Policies][1])

3. Assessment of the DGE notice and SR01184644

The substantive DGE notice was strategically sound

Your August 4 notice accurately quoted DGE’s earlier confirmation that the nondiscrimination-based appeal remained active and that DGE would review appropriately redacted CRO materials. It then:

• documented the report transmission and hearing election;

• preserved NEURO M203’s possible DGE relevance without reopening Finding 1;

• quoted the governing abeyance and Investigation Materials language;

• identified the unresolved meaning of “process completed”;

• declined to concede that the DGE 30-day period had begun;

• requested identification of received and anticipated materials;

• requested clarification of the completion trigger and clock;

• preserved the service record; and

• maintained the distinction between CRO liability findings and DGE mitigation.

That distinction is correct. The current Standards say DGE holds the appeal decision in abeyance while the investigatory office processes the allegations. Once that process is completed, the office provides appropriately redacted written investigation reports—defined as “Investigation Materials”—and DGE determines whether they reflect substantive mitigating circumstances that could have affected academic performance. DGE then has 30 calendar days from receipt of the Investigation Materials either to deny the appeal or refer it to CDP.

The Standards do not expressly say whether a timely hearing, the hearing report, the Vice Chancellor decision, or the Chancellor appeal are part of the investigatory office’s “process.” Your non-concession and request for a definitive interpretation were therefore appropriate—not an overstatement of settled policy.

The new ticket is not evidence that the appeal was lost or restarted

The automated response opened SR01184644, but its subject expressly identifies it as:

“Reopened from SR01178653: Reopened from SR01053187…”

It also says the request will be routed to a DGE staff member and may be updated by replying to that message.

That strongly suggests ServiceNow retained some linkage. However, the automated “original service request” portion displays the old initial appeal-form description rather than your August 4 status update. That does not prove that the new text is missing from DGE’s internal view, but it creates enough ambiguity to justify one short administrative clarification.

Send this now as a reply to SR01184644

Use Reply to the automated SR01184644 acknowledgment. Do not start another email, alter the subject, attach documents, copy your personal Gmail, or Bcc family members.

Dear Division of Graduate Education,

Please associate SR01184644 with my active nondiscrimination-based academic-disqualification appeal previously tracked as SR01178653, reopened from SR01053187, and treat my August 4, 2026, 5:10 p.m. PDT message as a status update in that existing appeal—not as a new appeal or duplicate filing.

Please preserve all three service-request numbers in the record and confirm that the complete text of my August 4 status update, including its seven numbered requests, is visible to the assigned reviewer.

For clarity, item 3 of my August 4 message should read:

“identify each item DGE has received from CRO or anticipates receiving from CRO as Investigation Materials, including the corresponding title or description, version, sender, and date and time of receipt;”

This administrative clarification does not alter the substance of my August 4 notice or any requested relief.

Thank you,

Cooper M. Beaman UID: 105692562 SR01184644 / SR01178653 / SR01053187

The correction is warranted because your sent item 3 currently reads:

“identify each item DGE has received or anticipates receiving CRO’s transmittal…”

The intended meaning is inferable, but the revised version removes the missing prepositional relationship and clearly distinguishes received materials from materials expected later.

Do not correct the phrase “isolated policy conclusions” separately. “Formal policy conclusions” would have been preferable, but the existing wording does not materially alter your request and is not worth another correction.

4. Immediate hearing-preparation architecture

Prioritize Findings 2 and 3

The package’s strongest structured analysis correctly treats:

• Finding 2—Bearden disparate treatment/mentorship decision as critical;

• Finding 3—Schweizer discrimination, retaliation, and academic-disqualification conduct as critical;

• Finding 4—Bearden harassment as important but secondary;

• Finding 5—Schweizer harassment as supporting rather than the central case.

Do not distribute hearing time equally across four findings. The strongest route is to establish the causation, process, comparator, motive, and chronology evidence surrounding Findings 2 and 3, then use Findings 4 and 5 to demonstrate disability-linked conduct and harm where the specific elements can be satisfied.

Your central themes should be narrow and evidence-based

Prepare the record around these issues:

1. Motive and credibility without respondent interviews. The report made material findings about Bearden’s and Schweizer’s reasons, knowledge, intent, and decisionmaking even though the package records that the investigator did not interview Bisley, Bearden, or Schweizer. This is not automatically a policy violation, but it is a strong basis to test the reliability and completeness of those findings through live testimony.

2. Contemporaneous versus later-expanded disqualification rationales. Separate what was stated before and at the initiation of disqualification from reasons appearing later in program submissions or the report.

3. Timing and decision formation. Establish who initiated or recommended disqualification, when the decision was materially formed, which records were before decisionmakers, and whether later committee action was independent or confirmatory.

4. Mentor, funding, and rotation criteria. Require precise testimony and documentation concerning the actual standards applied to the fifth and possible sixth rotation, funding expectations, mentor availability, and any comparator treatment.

5. Conditional continuation or mentor-placement representations. Resolve any discrepancy between offers, possible pathways, later denials, and how those representations affected your actions.

6. Retaliation as a separate theory. Do not allow retaliation to be submerged within a general discrimination narrative. Tie each asserted protected activity, knowledge event, adverse action, temporal sequence, and stated reason to documentary evidence.

7. Harassment statement by statement. Avoid arguing that every adverse academic criticism was harassment. Identify the precise statement or conduct, disability nexus, unwelcome character, severity/persistence/pervasiveness, and resulting interference.

Witness priorities

Your provisional witness list should prioritize:

• Carrie Bearden;

• Felix Schweizer;

• the investigator/report author, if the Hearing Officer permits methodology and evidentiary-treatment testimony;

• appropriate NSIDP records or decision custodians;

• a directly involved CAE participant where the interaction and notice evidence are materially relevant;

• a DGE or program witness capable of authenticating the disqualification chronology and contemporaneous rationale;

• you, with a tightly structured direct examination.

Bisley should not be a default merits witness. Use him only if counsel identifies a narrow, reasonably related factual point that cannot be established more efficiently through documents or another witness. Procedure 230.2 restricts the hearing to matters in the written grievance or reasonably related to them, as determined by the Hearing Officer. ([Admin Policies][1])

Build these working documents now, but do not submit them yet

• Findings 2–5 element matrix.

• Provisional witness list and one-paragraph proffer for each witness.

• Exhibit master list with source, date, author, recipient, authentication route, finding supported, and exact proposition.

• Chronology limited to material events.

• Redaction and missing-record log.

• One-page requested-remedy ladder.

• One-page objections and offers-of-proof checklist.

• DGE mitigation crosswalk maintained separately from the hearing merits matrix.

Because the Hearing Officer reviews evidence presented at the hearing, every indispensable document should have an identified path to submission and authentication. ([Admin Policies][1])

5. DGE preparation should proceed now even while awaiting its answer

Do not wait for DGE to resolve the completion issue before preparing the mitigation crosswalk. DGE could take the position that its 30-calendar-day period began when it received the initial report, even though your notice preserves the contrary interpretation. The policy language is genuinely ambiguous on that inter-process question.

Use August 14 as an internal readiness date—not a claimed UCLA deadline—for a concise draft crosswalk containing:

• exact report page and exhibit citation;

• whether the item is a formal finding, undisputed fact, party account, documentary fact, or contested proposition;

• the disability-related circumstance;

• the effect on academic performance;

• the causal pathway;

• the requested DGE treatment;

• whether the point remains contested in the hearing.

The crosswalk’s purpose is not to prove CRO liability. Its purpose is to demonstrate that even an adverse report contains evidence of possible substantive mitigating circumstances. The Standards use that separate threshold before CDP referral.

Do not submit the full crosswalk until DGE identifies the proper channel or a deadline, unless counsel determines that silence creates a greater risk than early submission.

6. Record preservation and communications discipline

Immediately preserve:

• native .eml or equivalent message files with complete headers;

• the rendered PDF copies;

• attachments exactly as sent or received;

• SHA-256 hashes;

• ServiceNow acknowledgment numbers;

• a single chronological docket log.

For every future event, record:

• date and exact time;

• time zone;

• sender and recipients;

• subject;

• case and service-request identifiers;

• attachments;

• requested action;

• any operative deadline;

• whether receipt was confirmed.

Do not overwrite earlier drafts or sent-message records. Add corrections as new docket entries.

If evidence or testimony is excluded later, make a clear offer of proof identifying what the evidence would establish and why it is relevant. Preserve rulings, access disputes, witness nonappearance, redaction issues, and objections on the hearing recording. Those are among the package’s highest record-preservation priorities.

7. Actions to avoid

Do not:

• resend or “replace” the August 3 or August 4 emails;

• expand the hearing to Finding 1;

• characterize documents as ignored when the report says they were considered but not relied upon;

• assert that UCLA has already violated federal law as an established fact;

• make the hearing primarily a critique of investigative methodology rather than an element-by-element merits presentation;

• submit the full historical archive unsolicited to counsel or UCLA;

• assume the extension request was granted;

• assume DGE’s clock has or has not begun;

• assume the report and exhibits automatically enter the hearing record;

• threaten a writ, federal lawsuit, agency filing, or public disclosure without California counsel;

• sign a release, settlement, confidentiality provision, non-disparagement term, academic-status waiver, or covenant not to sue without legal review;

• designate William Beaman as representative until determining whether he may be needed as a witness.

The package correctly warns that witness and representative roles may conflict and that external-litigation deadlines and settlement releases should not be handled without California counsel.

Bottom line

Send the brief SR01184644 linkage and item-3 clarification now. Send nothing further to the grievance side until UCLA responds or Thursday noon passes. Contact Hathaway, Kosnett, and Leigh in parallel immediately. Prepare—but do not yet submit—the Findings 2–5 witness/exhibit package and DGE mitigation crosswalk. Treat October 21 as the conservative working hearing-completion endpoint, with October 22 as the alternate calculation, pending UCLA’s written confirmation.

Your sent communications have preserved the core rights and distinctions. The next phase should shift from additional broad explanatory emails to disciplined counsel retention, hearing-record construction, and separate DGE mitigation preparation.

COUNSEL

Legal Counsel

Counsel recruitment: optimal current strategy

The merged counsel document contains three partly conflicting research reports. The updated, more disciplined ranking—not the older or Gemini-derived tables—should control:

1. Mark Hathaway / Hathaway Parker
2. James Kosnett / Kosnett Education Law Firm
3. Mandy Leigh / Leigh Law Group
4. Shanon Trygstad / Trygstad, Schwab & Trygstad
5. David German / Vanaman German, as a reserve or specialist rather than presumptive lead.

That ranking is methodologically preferable because it separates:

• California lead-hearing and writ capability;
• limited-scope affordability;
• disability-law depth;
• specialist-only roles;
• unresolved availability, conflict, and recent higher-education experience.

Hathaway Parker currently represents that it handles university investigations, formal hearings, grievances, appeals, and writ-of-mandate litigation, including discrimination and retaliation complaints. ([Hathaway Parker][3]) Kosnett’s California Bar profile is active, as are Mandy Leigh’s and Shanon Trygstad’s. Leigh Law Group expressly describes higher-education administrative-hearing and disability-accommodation work. ([leighlawgroup.com][4])

These public statements do not establish availability, competence for your specific matter, affordability, or lack of conflicts. Confirm all four directly.

Contact the top three in parallel

Do not wait for sequential responses. Send conflict-check/intake messages to Hathaway, Kosnett, and Leigh immediately, with Trygstad and German as parallel reserves. The package correctly identifies a procedural order arriving before counsel retention as the most important immediate operational risk.

Request:

a fixed-fee or capped Phase I of approximately $2,000–$4,000 for report triage, grounds refinement, witness/exhibit architecture, procedural communications, record preservation, and continuation-remedy strategy, with hearing appearance priced separately.

That structure is superior to an open-ended full retainer before UCLA has supplied a Hearing Officer, hearing date, or procedural order.

Updated five-document initial packet

After conflict clearance and secure-transfer instructions, send:

1. A new two-page current-case and representation brief dated August 4 or 5.
2. Notice of Outcome.
3. Searchable redacted Investigation Report.
4. One combined PDF containing the July 31 hearing request, correction, UCLA receipt confirmation, and August 3 grievance follow-up.
5. One combined PDF containing the August 4 DGE notice and SR01184644 acknowledgment.

Do not initially send:

• the complete 153 MB archive;
• all raw medical documentation;
• every historical AI analysis;
• every duplicate evidence file;
• all 119 exhibit pages without explanation;
• family communications.

After the lawyer clears conflicts and confirms the engagement scope, send Exhibits A–R, the contradiction matrix, omitted-evidence matrix, witness plan, and DGE mitigation crosswalk. The package likewise recommends a minimal first packet and controlled second-stage production.

RESEARCH

UCLA Procedure 230.2 Legal-Counsel Identification, Recruitment, and Representation Strategy

**Overview
**Decision, posture, and source coverage
**A. Executive decision
**Optimal lead-counsel strategy
**Optimal limited-scope or hybrid fallback
**Optimal pro bono or nonprofit lane
**Same-day contact order and parallelization
**Most important immediate risk
**Required work within the next seventy-two hours
**B. Verified current case posture
**C. Attachment coverage matrix
**Readability and review limitations
**Counsel architecture and candidate market
**D. Counsel-needs profile
**E. Exclusion, prior-contact, and conflict ledger
**F. Candidate universe
**G. Top five ranked lead-counsel recommendations
**Mark M. Hathaway — Hathaway Parker
**James Victor Kosnett — Kosnett Education Law Firm
**Mandy G. Leigh — Leigh Law Group
**Shanon D. Trygstad — Trygstad, Schwab & Trygstad
**David W. German — Vanaman German LLP
**H. Ranked specialist, nonprofit, and referral alternatives
**Specialist or co-counsel options
**Nonprofit, pro bono, and legal-aid options
**Certified referral channels
**Clinics
**I. Prior shortlist audit
**Recruitment, outreach, and intake materials
**J. Same-day outreach wave
**Wave One: private California lead candidates
**Wave Two: specialists and limited-scope options
**Wave Three: nonprofit, clinic, and referral channels
**Method and follow-up
**Outreach tracker fields
**Travel
**K. Tailored ready-to-send outreach
**Universal conflict-check and intake email
**Personalized email for Mark Hathaway
**Personalized email for James Kosnett
**Personalized email for Mandy Leigh
**Personalized email for Shanon Trygstad
**Personalized email for David German
**Forty-five-second voicemail
**Live intake-call script
**Nonprofit or pro bono request
**Certified lawyer-referral request
**Follow-up after one to two business days
**Graceful decline or hold message
**L. Minimal attorney intake packet
**Do not send unsolicited
**Second-stage secure packet
**Retention, cost, and formal designation
**M. Consultation agenda and retention questions
**Highest-priority questions
**Red flags and deal-breakers
**N. Cost-minimization and fee negotiation
**Model A — full hearing representation
**Model B — capped Phase I plus separately priced appearance
**Model C — coaching and drafting without formal appearance
**Fee-negotiation script
**Fee recovery distinctions
**O. Representation designation and sequencing
**Textual interpretation of Procedure 230.2
**Sequence after retention
**Copying counsel
**Behind-the-scenes counsel
**University counsel participation
**Retention near a deadline
**Attorney-designation notice
**Good-cause extension request
**Execution and fallback planning
**P. Sixty-day action plan
**Q. No-counsel fallback
**Limited-scope attorney
**Non-attorney representative
**Self-representation
**William Beaman as representative
**Consulting attorney who does not appear
**Highest record-preservation priorities
**Tasks not advisable without California counsel
**Final synthesis
**R. Final decision matrix
**Evidence gaps requiring direct intake confirmation
**Claims from prior research rejected or downgraded
**One-page decision table

Overview

Controlling research date and time: Monday, August 3, 2026, 3:21 p.m. PDT

Matter: UCLA Civil Rights Office Case 2025-07-00230-DPO

Research subject: Cooper M. Beaman

Central objective: Preserve or restore UCLA graduate-student status through continued enrollment, reinstatement, remand, structured continuation, program or mentor transfer, individualized accommodation, neutral academic review, or another durable academic-access remedy.

This report is a legal-market and procedural-strategy analysis, not legal advice or a prediction of outcome. Attorney availability, conflicts, fees, willingness to undertake limited-scope work, and access to the internal hearing must be confirmed directly before reliance.

The complete source inventory, duplicate map, candidate universe, scoring worksheet, and outreach tracker are available here:

Download the counsel-research workbook

Download the attachment coverage matrix as CSV

Decision, posture, and source coverage

A. Executive decision

Optimal lead-counsel strategy

The strongest practical strategy is to retain one California attorney who can own the internal hearing, witness examination, administrative record, negotiations, and California writ-preservation issues, while permitting discrete disability-law consultation or drafting support from a second specialist. The first three private contacts should be:

Hathaway Parker publicly describes representation of students, faculty, and staff in campus investigations, hearings, grievances, and appeals, and reports experience in hundreds of campus matters. The firm also has demonstrated California administrative-writ litigation involving university proceedings.

Kosnett’s published practice description is unusually well matched to a cost-controlled first phase: graduate and university matters, disability issues, hearing preparation, appeal drafting, attorney coaching, and writ or court remedies. The firm advertises a free initial consultation, although the precise scope, staffing, and fees must be confirmed.

Leigh Law Group expressly identifies higher-education dismissal, academic issues, disability accommodations, ADA and Section 504 claims, retaliation, and administrative-hearing work. Its publicly described sliding-scale or reduced-fee possibilities make it especially important within the stated budget.

Optimal limited-scope or hybrid fallback

The preferred fallback is:

1. California lead attorney under a capped Phase I engagement of approximately $2,000–$4,000 for immediate record triage, hearing-scope confirmation, designation, preservation requests, grounds refinement, witness and exhibit architecture, and a continuation-remedy proposal.

2. A separately priced hearing-appearance option, activated only after UCLA supplies the Hearing Officer, schedule, procedural order, and disclosure deadlines.

3. Behind-the-scenes specialist consultation from Jason J. Bach, Mary C. Vargas, Catherine Cabalo, or another disability/higher-education specialist only where the specialist’s contribution is discrete and California counsel remains responsible for California law and writ preservation.

Jason Bach’s practice is highly relevant to graduate, professional, and medical-school dismissal and disability disputes, but his publicly identified admissions do not establish California admission. He should therefore be treated as a strategy, drafting, or co-counsel candidate unless UCLA permits his proposed internal role and California-law needs are separately covered.

Optimal pro bono or nonprofit lane

The best nonprofit sequence is:

1. Disability Rights California, because it operates California’s protection-and-advocacy system, accepts disability-discrimination inquiries, and has a structured intake process. It cannot accept every matter, and direct representation is discretionary.

2. DREDF, for possible disability-law consultation, co-counseling, referral, or systemic-case assessment. Its public materials support litigation and co-counseling capability but do not promise individual internal-hearing representation.

3. Disability Rights Advocates, only if the matter can credibly be framed as presenting a broader systemic disability-access issue. DRA expressly prioritizes cases affecting substantial groups rather than isolated disputes involving only a few people.

Same-day contact order and parallelization

The first outreach wave should occur in parallel rather than sequentially:

• Send conflict-check emails and submit intake forms to Hathaway, Kosnett, Leigh, Trygstad, and German.

• Telephone Hathaway, Kosnett, and Leigh immediately after the written submission.

• Contact Jason Bach for a possible discrete strategy consultation.

• Begin Disability Rights California intake during its next published intake period.

• Submit one precise referral request to a State Bar-certified lawyer-referral service and to the San Francisco–Marin disability-rights panel.

Most important immediate risk

The most important immediate risk is a procedural order arriving before counsel is retained, creating short witness, exhibit, Hearing Officer, or pre-hearing deadlines. Procedure 230.2 contemplates at least ten University business days’ notice of the hearing, but witness and evidentiary materials ordinarily must be submitted at least five University business days before the hearing. “Days” means University business days.

That risk is intensified by the investigation record’s volume, redactions, unindexed submitted materials, and the investigator’s decision not to interview the respondents identified in the report. Package sources:

02_CORE_POST_REPORT_CASE_AND_POLICY_RECORD/01_ACTUAL_INVESTIGATION_MATERIALS/COOPER_BEAMAN_Investigation Report FINAL_Redacted.md, lines 123–161 and 225–239;

00_START_HERE/02_CURRENT_OPERATIVE_CASE_AND_COUNSEL_SNAPSHOT.md, lines 3–13.

Required work within the next seventy-two hours

B. Verified current case posture

Procedure 230.2 limits the hearing to the allegations and grounds properly placed before it; the hearing is not a general retrial of every dispute. It provides for testimony, witness questioning, documentary submissions, a Hearing Officer report, comments, a Vice Chancellor decision, and a narrow internal appeal.

C. Attachment coverage matrix

The package contains 248 canonical packaged entries in the manifest. The source index records 247 source members, and the duplicate map identifies six exact duplicate source members that were excluded from being counted as independent corroboration. The downloadable workbook contains one row per canonical packaged entry, with packaged path, provenance, source role, type, date inference, actors, readability, limitations, SHA-256 value, duplicate status, and reliance status.

Readability and review limitations

The package was technically extracted and inventoried. Native text, Markdown, CSV, JSON, and searchable sidecars were readable. The principal official PDFs were reviewed through native text extraction and searchable derivatives where available. Some PDFs contain redactions, embedded scans, image layers, or formatting that can limit extraction. The investigation archive was not treated as though every page or token had been manually merits-reviewed. The central task was counsel selection, procedural readiness, and representation design.

No transcription, OCR derivative, prior AI analysis, or sidecar was treated as superior to the corresponding native UCLA document. Duplicate materials were not treated as independent corroboration.

Counsel architecture and candidate market

D. Counsel-needs profile

This matter does not call merely for a general “education lawyer” or a federal civil-rights litigator. It requires a coordinated set of functions:

California administrative mandamus generally focuses on the record developed before the agency or public body, which makes contemporaneous objections, offers of proof, authentication, and procedural requests important now rather than after the hearing.

The functions that should not be fragmented are hearing strategy, witness examination, record preservation, and settlement authority. Disability-law research, chronology assembly, document coding, first-draft witness outlines, and a federal-litigation assessment can be divided to control cost.

E. Exclusion, prior-contact, and conflict ledger

The Gmail result is necessarily bounded: the accessible search found a DeNiro thread but no direct correspondence with the six benchmark firms. Absence from that search does not conclusively prove that no contact occurred through another email account, telephone, web form, or unconnected system.

F. Candidate universe

The universe below separates serious advances from specialist, nonprofit, referral, reserve, and reject categories. “Advance” means contact for conflict and intake screening; it does not mean the person is available, affordable, conflict-free, or willing to accept the case.

G. Top five ranked lead-counsel recommendations

Mark M. Hathaway — Hathaway Parker

Verified license: California State Bar record identifies Mark M. Hathaway as an active California lawyer, bar number 151332. No adverse discipline item was identified in the retrieved public profile; the official record should be rechecked immediately before engagement.

Score: 82/100

Strongest fit: Hathaway Parker’s stated practice squarely covers campus hearings, grievances, appeals, academic and disciplinary matters, and related writ litigation for individuals. Its published UC-related writ result demonstrates attention to evidentiary reliability and procedural record defects.

Likely role: Full lead counsel or capped Phase I lead with separately priced hearing representation.

Shortcomings and risks: Public materials do not establish the same depth in ADA Title II and Section 504 academic-accommodation claims as Leigh Law Group or a specialist disability firm. Fees, immediate availability, willingness to accept an internal disability hearing, and willingness to offer a $2,000–$4,000 first phase are unknown.

Conflict questions: Current or recent representation of UCLA, the Regents, any UCLA department, Carrie Bearden, Felix Schweizer, James Bisley, the Neuroscience Interdepartmental Program, DGE, or a witness; representation of an adverse student or employee in a materially related matter.

Cost hypothesis: Likely above the preferred budget for full hearing representation. A tightly defined record-triage and pre-hearing Phase I may be possible, but this is an intake hypothesis, not a published fee.

Best channel: Telephone at 213-529-9000 immediately after emailing the firm’s current general intake address.

Personalized opening angle: “Your campus-hearing and California university-writ work appears directly relevant because the immediate need is to prepare a narrowed UCLA administrative hearing while preserving the evidentiary record and continuation remedies.”

Send after conflict clearance: Two-page current case brief; Notice of Outcome; searchable Investigation Report; hearing request plus receipt confirmation; immediate-action command sheet.

Acceptance likelihood: Low-to-moderate, principally because availability, economics, and matter fit are unknown—not because of any identified disqualifying issue.

Why first: Hathaway has the strongest verified combination of internal university procedure and California writ-record capability. Kosnett may be more flexible and affordable, but Hathaway’s publicly substantiated campus-hearing and writ experience is stronger.

James Victor Kosnett — Kosnett Education Law Firm

Verified license: The official California State Bar profile identifies James Victor Kosnett as active, bar number 71542. No adverse disciplinary item was identified in the retrieved public profile; recheck before retention.

Score: 80/100

Strongest fit: Public materials expressly address graduate-level disputes, university hearings, disability matters, appeal drafting, attorney coaching, ghostwriting, and writ or court remedies. That breadth is unusually compatible with phased representation.

Likely role: Limited-scope or full lead; particularly suitable for rapid Phase I triage, written grounds, hearing preparation, or coaching.

Shortcomings and risks: The breadth of the website claims is not matched by publicly located recent UC or UCLA doctoral-dismissal case records. Confirm who will personally perform the work, current caseload, trial or cross-examination experience, and whether the lawyer will appear rather than only advise.

Conflict questions: UCLA, Regents, named respondents, DGE or CDP personnel, investigator or Hearing Officer, and any materially related UCLA matter.

Cost hypothesis: Better-than-average prospect for unbundled work because coaching and drafting are publicly described, and a free consultation is advertised. The actual cap and hearing-appearance fee remain unknown.

Best channel: Call 310-445-5900 or 877-959-2937 after submitting the web intake.

Personalized opening angle: “Your published graduate-student, disability, hearing, appeal-drafting, and coaching work appears suited to a phased UCLA matter where a timely hearing request is already pending.”

Acceptance likelihood: Moderate, because the practice affirmatively advertises consultation and unbundled functions, though current capacity is unknown.

Why second: Kosnett offers a closer publicly stated graduate-dispute and limited-scope fit than Hathaway, but Hathaway has stronger externally corroborated campus-hearing and UC writ credentials.

Mandy G. Leigh — Leigh Law Group

Verified license: California’s official profile identifies Mandy G. Leigh as an active California attorney, bar number 225748. No adverse discipline item was identified in the retrieved public profile; recheck before engagement.

Score: 79/100

Strongest fit: Leigh Law Group’s public materials expressly combine higher-education dismissal and academic issues with disability accommodation, ADA, Section 504, retaliation, and due-process hearing work.

Likely role: Integrated disability and higher-education lead, or disability merits lead paired with a writ-focused California lawyer.

Shortcomings and risks: The publicly visible case descriptions and practice materials are substantially weighted toward K–12 special education. Confirm recent graduate or professional-school matters, UC internal hearings, administrative mandamus, and cross-examination experience.

Conflict questions: UCLA and the Regents, named individuals, any CAE or DGE personnel, and any current institutional or employee-side representation.

Cost hypothesis: More promising than most candidates because the firm advertises free intake and possible sliding-scale or reduced-fee arrangements. That does not establish that this matter qualifies or that full representation falls within budget.

Best channel: Email the published intake address and call 800-424-5297.

Personalized opening angle: “The matter combines a narrowed higher-education hearing with disability accommodation, retaliation, and academic-continuation issues, which matches your published higher-education and ADA/Section 504 work.”

Acceptance likelihood: Moderate, subject to capacity and confirmation that the firm accepts graduate-level public-university matters.

Why third: Leigh has stronger disability depth and potential fee flexibility than the first two candidates, but the public record shows less exact UC writ and doctoral-hearing experience.

Shanon D. Trygstad — Trygstad, Schwab & Trygstad

Verified license: California’s official profile identifies Shanon D. Trygstad as active, bar number 173834. No adverse disciplinary item was identified in the retrieved profile; recheck before retention.

Score: 65/100

Strongest fit: The firm describes substantial administrative-hearing, education, disability, trial, and appellate work and identifies matters involving universities and UCLA. Shanon Trygstad’s biography emphasizes disability and education rights.

Likely role: Hearing counsel, California administrative-procedure reserve, or co-counsel.

Shortcomings and risks: The firm’s visible practice appears substantially centered on educators, employees, and K–12 matters. Exact student-side graduate-program dismissal, CRO-style grievance, and continuation-remedy experience must be established before advancement.

Conflict questions: Current UCLA or UC employee matters, union or faculty representations involving relevant departments, current adverse-party relationships, and any role for the firm opposite or aligned with a named witness.

Cost hypothesis: Unknown. The firm describes active consultations and transparent billing but does not publish usable rates or caps.

Best channel: Call 310-552-0500 and submit the web intake.

Personalized opening angle: “Your administrative-hearing and disability-rights background, including UCLA-facing work, may fit a time-sensitive student grievance that requires witness examination and California record preservation.”

Acceptance likelihood: Low-to-moderate, because exact student-side fit and capacity are not yet established.

Why fourth: Trygstad offers more demonstrated administrative-hearing capability than German but less exact graduate-student and accommodation fit than the top three.

David W. German — Vanaman German LLP

Verified license: California’s official profile identifies David W. German as active, bar number 252394. No adverse discipline item was identified in the retrieved profile; recheck before engagement.

Score: 59/100

Strongest fit: German has extensive disability due-process, evidentiary-hearing, and trial experience and has taught education law at UCLA.

Likely role: Disability-hearing specialist, limited-scope strategist, or provisional lead only after confirming higher-education and writ competence.

Shortcomings and risks: The practice is predominantly K–12 and IDEA-focused. That is materially different from a UCLA doctoral-program matter governed by university policy, Title II, Section 504, California public-law principles, and academic-deference doctrines.

Conflict questions: UCLA teaching or professional relationships; current representations involving UCLA, the Regents, CAE, or the named individuals; whether any institutional consulting creates an issue.

Cost hypothesis: Unknown. Request a discrete consultation or capped disability-hearing review before discussing full representation.

Best channel: Call 818-990-7722 or email the published attorney address.

Personalized opening angle: “Your disability due-process and hearing experience may be valuable in a UCLA graduate matter involving accommodation, causation, and witness-examination questions, provided your firm handles higher-education internal proceedings.”

Acceptance likelihood: Low-to-moderate as lead; moderate as a limited disability/hearing consultant if the firm accepts higher-education matters.

Why fifth: German offers stronger disability-hearing depth than the remaining California reserves, but his K–12 concentration keeps him below Trygstad and makes this a provisional rather than fully gate-cleared lead recommendation.

H. Ranked specialist, nonprofit, and referral alternatives

Specialist or co-counsel options

Nonprofit, pro bono, and legal-aid options

Certified referral channels

1. State Bar of California certified lawyer-referral directory. Request a California lawyer with all four of these characteristics: public-university administrative hearing experience, student-side higher education, ADA/Section 504, and administrative mandamus. Certified services refer to insured lawyers in good standing and commonly provide a reduced-fee or no-fee initial consultation.

2. San Francisco–Marin Lawyer Referral and Information Service disability-rights panel. It expressly lists disability rights and publishes a modest consultation charge, though Los Angeles appearance capacity must be confirmed.

3. San Fernando Valley Bar Association Attorney Referral Service. It is geographically practical and listed among Los Angeles-area certified services; request education, disability, administrative, and appellate or writ screening rather than a generic civil-rights referral.

Clinics

No located law-school clinic can presently be characterized as a likely source of full representation for this UCLA doctoral grievance.

Loyola’s Center for Conflict Resolution may be useful only if both sides are willing to engage in conciliation or mediation; it is not a substitute for hearing counsel.

Loyola’s Youth Justice Education Clinic is oriented toward youth and school-pushout work, not graduate higher education.

Berkeley Law and EBCLC warrant a narrowly framed inquiry, but geography, client eligibility, mandate, and the University of California affiliation create significant practical and conflict uncertainties.

I. Prior shortlist audit

Recruitment, outreach, and intake materials

J. Same-day outreach wave

Wave One: private California lead candidates

Send substantially simultaneous conflict-check submissions to Hathaway, Kosnett, Leigh, Trygstad, and German. The first three should receive both email or intake-form submissions and same-day telephone calls.

Do not wait for one candidate to decline before contacting the next. Counsel conflicts, availability, and economics are independent constraints, and sequential outreach would unnecessarily consume the pre-hearing period.

Wave Two: specialists and limited-scope options

Contact Jason Bach for a tightly scoped consultation addressing:

• hearing grounds and framing;

• graduate or professional-program dismissal strategy;

• disability and mental-health accommodation issues;

• continuation-remedy architecture; and

• what work can be performed without a formal appearance.

Contact Catherine Cabalo or Peiffer Wolf only through a conflict-check-first message that identifies UCLA and the Regents before transmitting any substantive record.

Wave Three: nonprofit, clinic, and referral channels

Begin Disability Rights California intake first. Contact DREDF second. Contact DRA only with a candid description of both the individual dispute and any genuinely supportable systemic dimension. Submit a certified-referral request in parallel.

Method and follow-up

Outreach tracker fields

Record candidate, firm, date and time, channel, person reached, conflict status, consultation date, fee, proposed responsible lawyer, scope, Phase I cap, appearance fee, availability, secure-transfer instructions, next follow-up, and disposition. A blank tracker is included in the workbook.

Travel

State affirmatively that Cooper will be traveling August 5–11 but remains available for remote consultation by telephone or video. Do not imply that travel delays the matter or prevents document review.

K. Tailored ready-to-send outreach

Universal conflict-check and intake email

Subject: Time-sensitive UCLA graduate-student grievance hearing — conflict check and consultation request

Dear [Attorney Name],

I am a UCLA neuroscience Ph.D. student seeking counsel for a formal hearing under UCLA Procedure 230.2 and a related but distinct graduate academic-disqualification process.

The hearing request was timely filed on July 31, 2026 and UCLA confirmed receipt on August 3. The requested hearing is expressly limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer. Finding 1 concerning Dr. James Bisley is not being submitted for hearing review, and I seek no finding or remedy against him. No hearing date, Hearing Officer, pre-hearing conference, or disclosure schedule has yet been provided.

Before I provide confidential documents, could your office please check conflicts involving:

• The Regents of the University of California and UCLA;

• UCLA Civil Rights Office Case 2025-07-00230-DPO;

• Dr. Carrie Bearden;

• Dr. Felix Schweizer;

• Dr. James Bisley;

• UCLA’s Neuroscience Interdepartmental Program;

• UCLA Division of Graduate Education; and

• Cooper M. Beaman.

The matter involves higher-education administrative procedure, disability discrimination and accommodation, retaliation and harassment allegations, academic-disqualification issues, witness and evidentiary preparation, continuation or reinstatement remedies, and preservation of the California administrative record.

My preferred initial engagement is a fixed-fee or capped Phase I of approximately $2,000–$4,000, with hearing appearance separately priced if necessary. I am also open to limited-scope, sliding-scale, payment-plan, or hybrid arrangements.

The complete record will be provided only after conflict clearance and receipt of secure-transfer instructions. I will be traveling August 5–11 but remain available remotely.

Thank you,

Cooper M. Beaman

[telephone]

[email]

Personalized email for Mark Hathaway

Subject: UCLA Procedure 230.2 hearing — campus-hearing and writ counsel inquiry

Dear Mr. Hathaway,

I am contacting you because Hathaway Parker’s work in university investigations, hearings, grievances, appeals, and California writ proceedings appears closely aligned with my immediate need: preparing a narrowed UCLA administrative hearing while preserving evidentiary objections, witness issues, continuation remedies, and a reviewable record.

The hearing request was timely filed on July 31 and confirmed received by UCLA on August 3. It is limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer; Finding 1 concerning Dr. James Bisley is not submitted for review, and no remedy is sought against him. No hearing date, Hearing Officer, or disclosure schedule is yet known.

Would your office conduct a conflict check using the parties and entities listed below and advise whether you could offer either full lead representation or a capped Phase I covering record triage, grounds refinement, designation, witness and exhibit planning, and preservation strategy? My preferred first-phase budget is approximately $2,000–$4,000, recognizing that hearing appearance would likely require separate pricing.

I will provide the full record only after conflict clearance and secure-transfer instructions.

[Insert conflict list and signature from universal email.]

Personalized email for James Kosnett

Subject: UCLA graduate hearing — graduate-dispute, disability, and limited-scope inquiry

Dear Mr. Kosnett,

Your published work involving graduate and university disputes, hearings, disability issues, appeal drafting, coaching, and writ remedies appears unusually well suited to a phased engagement in my UCLA matter.

A timely Procedure 230.2 hearing request was filed July 31 and confirmed received August 3. It is limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer. Finding 1 concerning Dr. James Bisley is not being challenged, and no remedy is sought against him. UCLA has not yet identified the Hearing Officer or schedule.

I am seeking either lead representation or a capped first phase addressing immediate procedural communications, record review, grounds refinement, witness and exhibit preparation, continuation remedies, and preservation for possible California review. My preferred Phase I budget is approximately $2,000–$4,000, and I would welcome an unbundled option if full representation is not feasible.

Please conduct a conflict check before I send confidential materials. The complete record will be shared only through your approved secure method after clearance.

[Insert conflict list and signature.]

Personalized email for Mandy Leigh

Subject: UCLA higher-education disability grievance — consultation and conflict check

Dear Ms. Leigh,

I am seeking counsel because my matter combines a higher-education dismissal or continuation dispute with ADA and Section 504 accommodation, retaliation, and administrative-hearing issues—areas reflected in Leigh Law Group’s published practice.

The UCLA Procedure 230.2 hearing request was timely filed July 31 and confirmed received August 3. The hearing is expressly limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer. Finding 1 concerning Dr. James Bisley is not submitted for review, and no finding or remedy is sought against him. No hearing date or disclosure schedule has been provided.

I would like to discuss full or limited-scope representation, including a fixed or capped Phase I of approximately $2,000–$4,000, possible sliding-scale treatment, and separately priced hearing appearance. The immediate priorities are procedural preservation, disability and causation analysis, witness preparation, continuation or reinstatement remedies, and coordination with a separate UCLA graduate-education process.

Please conduct the conflict check below before I transmit the record. I will use your secure-transfer process after clearance.

[Insert conflict list and signature.]

Personalized email for Shanon Trygstad

Subject: UCLA administrative hearing and disability-rights matter — counsel inquiry

Dear Ms. Trygstad,

I am contacting you because your administrative-hearing, education, disability-rights, trial, and UCLA-facing experience may be relevant to a time-sensitive UCLA graduate-student grievance requiring witness examination and preservation of a California administrative record.

My Procedure 230.2 hearing request was timely filed July 31 and confirmed received August 3. It is limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer. Finding 1 concerning Dr. James Bisley is not submitted for hearing review, and no remedy is sought against him. UCLA has not yet issued the Hearing Officer assignment or schedule.

Could your office confirm whether you represent graduate students in internal public-university disability or academic-dismissal hearings and whether you could offer a capped Phase I in the approximately $2,000–$4,000 range? Full appearance can be separately assessed once the schedule and hearing order are known.

Please complete the conflict check below before I provide confidential records.

[Insert conflict list and signature.]

Personalized email for David German

Subject: UCLA graduate disability hearing — limited-scope or hearing-counsel inquiry

Dear Mr. German,

Your disability due-process, evidentiary-hearing, and education-law experience may be valuable in a UCLA graduate matter involving accommodation, causation, witness preparation, and an academic-continuation objective.

A timely UCLA Procedure 230.2 hearing request was filed July 31 and confirmed received August 3. It is limited to Findings 2–5 concerning Dr. Carrie Bearden and Dr. Felix Schweizer. Finding 1 concerning Dr. James Bisley is not being challenged, and no remedy is sought against him. No hearing date, Hearing Officer, or disclosure schedule is yet known.

Before proceeding, I would appreciate confirmation that your firm handles higher-education internal hearings and related California public-law preservation, rather than only K–12 special-education matters. I am interested in either a capped Phase I of approximately $2,000–$4,000 or a discrete disability/hearing consultation, with appearance separately priced.

Please conduct the conflict check below before I send the record.

[Insert conflict list and signature.]

Forty-five-second voicemail

Hello, this is Cooper Beaman. I am a UCLA neuroscience Ph.D. student seeking time-sensitive counsel for a formal UCLA Procedure 230.2 grievance hearing and a related graduate academic-disqualification process. The hearing request was timely filed and UCLA confirmed receipt today. It is limited to Findings 2 through 5 involving two faculty respondents, and no hearing date has yet been assigned. I am seeking either lead representation or a capped initial phase focused on hearing preparation, disability issues, continuation remedies, and record preservation. I have emailed a conflict list and will not send confidential records until clearance. My number is [number]. Again, this is Cooper Beaman at [number]. Thank you.

Live intake-call script

“Thank you for speaking with me. Before discussing confidential details, can you confirm that the office can run a conflict check for UCLA, the Regents, Carrie Bearden, Felix Schweizer, James Bisley, the UCLA Neuroscience Interdepartmental Program, DGE, and me?”

After clearance:

“The immediate matter is a UCLA Procedure 230.2 hearing. I timely filed on July 31, and UCLA confirmed receipt August 3. The hearing is limited to Findings 2–5 concerning Bearden and Schweizer. Finding 1 concerning Bisley is not challenged and I seek no remedy against him. No Hearing Officer or schedule is known.

“The desired outcome is continued student status through reinstatement, remand, structured continuation, transfer, accommodation, or neutral academic review—not merely damages. A separate DGE academic-disqualification process must be coordinated but not conflated with the CRO hearing.

“Could you tell me:

1. whether the lawyer personally handling the matter has represented graduate students in university hearings or academic dismissal cases;

2. whether that lawyer has handled ADA or Section 504 accommodation and retaliation issues;

3. whether the lawyer will conduct witness examination and preserve the record for a California writ;

4. what can be accomplished under a capped $2,000–$4,000 Phase I; and

5. whether hearing appearance can be separately priced?”

Nonprofit or pro bono request

Subject: Disability-rights intake — UCLA graduate-student hearing and continuation matter

I am a UCLA neuroscience Ph.D. student with a timely pending internal grievance hearing involving disability accommodation, discrimination, retaliation, and academic-continuation issues. UCLA confirmed receipt of the hearing request on August 3, but no schedule has been issued.

The requested hearing is limited to Findings 2–5 involving two faculty respondents. A separate graduate academic-disqualification process is also pending. The principal requested outcome is continued or restored student status through an individualized and nondiscriminatory academic process.

I understand your organization cannot accept every individual matter. I am requesting intake screening for direct representation, limited advice, co-counseling, or referral. I will provide confidential records only after conflicts and secure-transfer procedures are addressed.

Certified lawyer-referral request

I need a California attorney who represents students—not universities—in public-university administrative hearings and has meaningful experience in all or most of the following: graduate or professional-school academic dismissal, ADA Title II and Section 504 accommodation or retaliation, witness examination, university grievance procedure, California administrative mandamus under Code of Civil Procedure section 1094.5, and negotiated reinstatement or continuation remedies.

The hearing request is already timely filed and confirmed received. No hearing date is known. I prefer a lawyer offering a fixed-fee or capped first phase, limited-scope services, sliding scale, or payment plan.

Follow-up after one to two business days

I am following up because UCLA has confirmed receipt of the hearing request but has not yet supplied the Hearing Officer or schedule, and counsel must be prepared to respond quickly when those deadlines issue. Please let me know whether the conflict check can be completed and whether a brief remote consultation is available.

Graceful decline or hold message

Thank you for your time and consideration. I have retained another lawyer for the immediate phase and will not be proceeding with an engagement at this time. Please preserve the confidentiality of the intake information and confirm whether your office will retain or delete any materials already transmitted under its normal policy.

L. Minimal attorney intake packet

The optimal initial packet remains five items, but the first item should be newly created rather than drawn from a long operational memo:

The fifth item may be replaced with the more attorney-oriented handoff document if it is shorter and current:

04_FINAL_POST_REPORT_HEARING_AND_DGE_SYSTEM/05_COUNSEL_AND_EXTERNAL_REVIEW/24_COUNSEL_HANDOFF_AND_EXTERNAL_REVIEW_READINESS.md

Do not send unsolicited

Do not send any of the following before conflict clearance and secure-transfer instructions:

• the full Exhibits A–R production;

• the full evidence archive;

• medical or psychological records;

• disability documentation beyond what is needed for initial issue identification;

• raw email, Slack, text, or messaging exports;

• records containing third-party personally identifying information;

• hundreds of additional pages not relied upon by the investigator;

• unredacted witness information;

• family communications; or

• documents subject to uncertain confidentiality restrictions.

Second-stage secure packet

After conflict clearance, send:

1. Exhibits A–R and Exhibit List;

2. Procedure 230.2 and Attachment B;

3. DGE and CDP policy and operative correspondence;

4. concise contradiction, omission, witness, and mitigation matrices;

5. selected accommodation and interactive-process records;

6. a dated chronology;

7. witness contact and availability information;

8. proposed continuation remedies;

9. a complete archive index; and

10. additional underlying files only on counsel’s request.

Retention, cost, and formal designation

M. Consultation agenda and retention questions

Highest-priority questions

1. Exact experience: “Identify two or three matters in which you personally represented a graduate, medical, doctoral, or professional student in an academic dismissal, disability, or internal university hearing.”

2. Personal responsibility: “Who will review the report, draft submissions, prepare witnesses, attend the hearing, and communicate with UCLA?”

3. Hearing plan: “Do you anticipate calling witnesses, cross-examining respondents, making offers of proof, challenging redactions, or seeking authentication?”

4. Disability competence: “What ADA Title II, Section 504, accommodation, interactive-process, retaliation, or disability-harassment matters have you handled in higher education?”

5. UC and UCLA: “Have you represented UCLA, the Regents, a UC campus, or anyone connected to the listed actors?”

6. Dual-lane architecture: “How would you coordinate the CRO hearing with the separate DGE or CDP academic process without conflating jurisdiction or remedies?”

7. Record and writ: “What objections and submissions must be made now to preserve a possible California administrative-mandamus challenge?”

8. Remedies: “What continuation, remand, reinstatement, transfer, accommodation, or neutral-review terms would you pursue?”

9. Availability: “Can you act before an unexpected witness or exhibit deadline, including during August 5–11?”

10. Scope: “What exact deliverables can be completed under a $2,000–$4,000 cap?”

11. Appearance: “What would the hearing appearance cost, and does that include preparation, travel, post-hearing comments, or settlement discussions?”

12. Billing: “What are the retainer, replenishment trigger, hourly rates by timekeeper, minimum increments, administrative charges, travel charges, and unused-retainer refund policy?”

13. Alternative fees: “Do you offer fixed fees, hard caps, limited-scope work, reduced rates, sliding scale, payment plans, deferred amounts, hybrid arrangements, or a pro bono allocation?”

14. Communication: “What response time and update cadence will apply, and who is the day-to-day contact?”

15. Settlement authority: “Will you pursue academic continuation and status-preserving terms rather than treating monetary damages as the only meaningful outcome?”

16. Insurance: “Do you maintain current professional-liability insurance?”

17. Termination: “What work product is delivered if either party terminates, and how are unused funds handled?”

18. Security: “What secure portal, encryption, retention, and deletion practices apply to medical and academic records?”

Red flags and deal-breakers

• Guaranteed outcome or categorical statement that UCLA “will lose.”

• Advice to threaten publicity, criminal consequences, licensing action, or unrelated claims as leverage.

• Refusal to conduct a conflict check before receiving the full archive.

• Request to send medical records or the entire confidential production through ordinary email before clearance.

• Inability to distinguish the CRO hearing from DGE or CDP authority.

• Exclusive focus on damages with no plan for continued enrollment or reinstatement.

• No witness or cross-examination plan despite a contested hearing.

• No California-law competence and no proposed California co-counsel.

• No plan to preserve excluded evidence and objections.

• Unclear identity of the lawyer doing the work.

• Uncapped hourly engagement without budget alerts or change-control provisions.

• Retainer terms permitting substantial nonrefundable charges without defined deliverables.

• Inability to act before likely pre-hearing deadlines.

N. Cost-minimization and fee negotiation

Model A — full hearing representation

Deliverables: Complete record review; hearing theory; procedural correspondence; witness interviews and preparation; subpoenas or attendance requests where available; exhibits; direct and cross-examination; opening and closing; settlement negotiations; post-hearing comments; Vice Chancellor submission; coordination with DGE or CDP; preservation for external review.

Tradeoff: Best continuity and lowest execution risk, but almost certainly exceeds the preferred $2,000–$4,000 initial budget.

Major cost drivers: Ten-million-byte-plus report and attachments; hundreds of additional pages; number of witnesses; redaction disputes; hearing length; expert consultation; travel; post-hearing briefing; DGE work; emergency scheduling.

When rational: Counsel offers unusually favorable pricing, nonprofit support, a payment plan, or the hearing issues can be tightly narrowed.

Model B — capped Phase I plus separately priced appearance

Recommended model.

Phase I deliverables:

• conflict and procedural review;

• targeted review of Notice, report, hearing request, and core exhibits;

• UCLA designation and schedule communications;

• hearing-ground and jurisdiction matrix;

• record and redaction preservation request;

• witness and exhibit plan;

• preliminary direct and cross outlines;

• continuation-remedy proposal;

• DGE coordination advice; and

• budget and go/no-go assessment for appearance.

Target: Hard cap of approximately $2,000–$4,000, with no overage without written approval.

Separately price: Hearing preparation after scheduling, witness interviews, appearance, travel, post-hearing comments, and internal appeal.

Tradeoff: Requires disciplined client document organization and may leave a second retention decision shortly before the hearing.

When rational: Almost always in this posture, because the schedule, Hearing Officer, and duration are unknown.

Model C — coaching and drafting without formal appearance

Deliverables: Two or three attorney conferences; written issue outline; edits to hearing statement; witness and exhibit plan; cross-examination questions; mock hearing; objections checklist; post-hearing comment template; writ-preservation checklist.

Tradeoff: Lowest cost but highest execution risk. Cooper or a non-attorney representative must manage live examination, objections, time, record preservation, and settlement decisions.

When rational: No suitable lawyer will appear, the hearing is short or document-centered, or the available evidence can be presented clearly without complex witness disputes.

Fee-negotiation script

“My available initial budget is approximately $2,000–$4,000. I would like to avoid asking you to underprice undefined work, so could we structure a written Phase I with specific deliverables and a hard cap?

“I would like the consultation fee credited against the engagement. Please identify what can be handled as a fixed fee, what remains hourly, and what would trigger a written change order.

“Could the retainer be phased rather than fully funded at the outset? I would also like to discuss any reduced rate, sliding scale, payment plan, deferred portion, limited pro bono allocation, or hybrid structure the firm offers.

“Please price hearing appearance separately and state whether it includes witness preparation, travel, post-hearing comments, settlement negotiations, and DGE coordination.

“I would also like the engagement letter to preserve the ability to seek attorney-fee reimbursement as a settlement term without representing that fees are automatically recoverable.”

Fee recovery distinctions

Procedure 230.2 does not appear to create an automatic internal entitlement to attorney fees. A negotiated UCLA resolution could nevertheless include reimbursement of some or all fees as an express settlement term.

The ADA authorizes discretionary attorney-fee awards in qualifying actions or administrative proceedings, and the Rehabilitation Act incorporates remedies that can include fee shifting in qualifying external proceedings. Those provisions do not establish that this UCLA internal grievance itself automatically produces a fee award. Statutory entitlement, prevailing-party status, causation, recoverability, and forum must be evaluated by counsel in the context of an actual external action.

A plaintiff-side disability firm may consider contingency or a hybrid arrangement for a viable damages or injunctive action, but that does not imply willingness to finance an internal hearing whose principal remedy is academic continuation.

O. Representation designation and sequencing

Textual interpretation of Procedure 230.2

Procedure 230.2 permits a grievant to be assisted by a representative and contemplates identifying the representative and supplying any required release. The summary provisions also state that when an attorney represents the grievant and the University is a subject of the grievance, the University will have legal counsel.

The existing hearing request most likely preserved later attorney retention because it:

• truthfully stated that no attorney had agreed to represent Cooper;

• stated an intent to obtain attorney assistance;

• promised prompt supplementation after retention; and

• did not waive representation.

This is the stronger textual interpretation. The procedure does not, however, appear to state an express “late-designation” process or guarantee that designation may occur without scheduling consequences at any time. That residual uncertainty warrants prompt supplementation once counsel is retained.

Sequence after retention

1. Conduct conflict check.

2. Complete consultation.

3. Receive and negotiate written scope and fee agreement.

4. Confirm the exact responsible attorney.

5. Sign the engagement agreement.

6. Sign a narrowly tailored release or authorization permitting UCLA communications and record access.

7. Obtain counsel’s preferred wording for appearance or designation.

8. Send UCLA the designation notice.

9. Ask UCLA to direct future substantive and scheduling communications to both Cooper and counsel.

10. Ask counsel to verify the Hearing Officer process, disclosure deadlines, record access, redactions, and any needed good-cause relief.

Copying counsel

Formally appearing counsel should ordinarily be copied on all communications involving scheduling, evidence, witnesses, procedure, settlement, DGE interaction, or substantive hearing issues. Cooper should remain copied unless counsel directs otherwise.

Behind-the-scenes counsel

An attorney who only advises, drafts, or coaches and does not communicate with UCLA, receive protected records directly from UCLA, or appear at the hearing may not need to be formally designated. Procedure 230.2 does not expressly resolve this distinction. Confirm with the attorney and UCLA before relying on nondisclosure of the consulting relationship.

University counsel participation

Once Cooper is formally represented by an attorney, the policy’s summary language indicates that the University will have legal counsel when the University is the subject of the grievance.

That factor should not deter retention, but it may make proceedings more lawyer-driven and increase the need for clear scope, evidentiary preparation, and procedural discipline.

Retention near a deadline

If counsel is retained shortly before a disclosure or hearing deadline:

• designate counsel immediately;

• comply with everything reasonably possible by the existing deadline;

• identify the exact additional work that cannot reasonably be completed;

• request only the minimum necessary extension;

• explain that the hearing request was timely, UCLA had not supplied the schedule when counsel was sought, and the extension supports a fair and efficient record;

• avoid implying that retention automatically stays the proceeding.

Procedure 230.2 permits extensions for good cause but does not guarantee one merely because counsel was newly retained.

Attorney-designation notice

Subject: Case 2025-07-00230-DPO — designation of attorney representative

Dear ADA/Section 504 Compliance Office and Grievance Coordinator,

I write to supplement my timely July 31, 2026 hearing request.

I have retained [Attorney Name], [Firm], as my attorney representative for the Procedure 230.2 hearing concerning Findings 2–5 involving Dr. Carrie Bearden and Dr. Felix Schweizer.

Attorney contact information:

[Name]

[Firm]

[Email]

[Telephone]

[Address]

Please copy both counsel and me on all future communications concerning the Hearing Officer, scheduling, pre-hearing procedures, witnesses, exhibits, record access, settlement, and the hearing. Attached is [the requested authorization or release], limited to this matter.

This designation does not alter the hearing scope stated in my July 31 request. Finding 1 concerning Dr. James Bisley remains outside the requested hearing review, and no finding or remedy is sought against him.

Please confirm receipt and advise of any additional form required by Procedure 230.2 or Attachment B.

Sincerely,

Cooper M. Beaman

Good-cause extension request

Subject: Case 2025-07-00230-DPO — narrowly tailored good-cause scheduling request

Dear [Coordinator or Hearing Officer],

I respectfully request a [number]-University-business-day extension of the [identify precise deadline] for good cause.

My hearing request was timely filed on July 31, 2026 and confirmed received on August 3. At that time no Hearing Officer, hearing date, or disclosure schedule had been provided, and I accurately disclosed that I was seeking attorney assistance. I retained [Attorney] on [date], after receiving the schedule on [date].

Counsel requires the requested limited period to [review the redacted Investigation Report and designated exhibits; conduct necessary witness interviews; prepare the required witness or exhibit submission; address newly disclosed redactions; or another precise task]. We will complete all unaffected requirements by their existing deadlines.

The requested extension is limited to what is reasonably necessary, does not alter the hearing’s Findings 2–5 scope, and is intended to promote an orderly and complete record. Please advise promptly whether the request is granted or whether an alternative schedule is available.

Sincerely,

Cooper M. Beaman

[Attorney signature if appropriate]

Execution and fallback planning

P. Sixty-day action plan

Exact dates below are used only where established. Other events are tied to procedural triggers because UCLA has not supplied the Hearing Officer or schedule.

Procedure 230.2 states that the hearing generally should be scheduled within sixty University business days and provides subsequent periods for the Hearing Officer’s report, party comments, the Vice Chancellor’s decision, and internal appeal. The exact projected end date cannot be fixed without UCLA’s business-day calendar, campus closures, extensions, and the procedure’s counting convention.

California Code of Civil Procedure section 1094.6 contains a ninety-day rule for certain local-agency decisions, but it should not be assumed to govern the Regents or this matter. California counsel should identify the applicable limitations and exhaustion framework immediately after any final decision.

Q. No-counsel fallback

Limited-scope attorney

The best fallback is still to purchase targeted California legal work even if no lawyer appears. Priority deliverables are:

• one procedural and record-preservation memorandum;

• hearing-scope and grounds review;

• witness and exhibit plan;

• cross-examination questions;

• review of the continuation proposal;

• mock hearing;

• review of post-hearing comments; and

• limitations and writ-preservation advice.

Non-attorney representative

Procedure 230.2 appears to permit assistance by a representative who need not be an attorney, subject to policy conditions and designation requirements. A non-attorney can organize exhibits, conduct questioning if permitted, monitor time, take notes, and help Cooper maintain focus. That person cannot provide legal advice, hold himself out as counsel, or cure a lack of California legal analysis.

Self-representation

If self-represented, Cooper should use a narrow hearing architecture:

1. jurisdiction and requested relief;

2. concise grounds for Findings 2–5;

3. witness-by-witness proof plan;

4. exhibit authentication;

5. accommodation, causation, retaliation, or harassment evidence tied to each finding;

6. procedural omissions and offers of proof;

7. academic-continuation remedy; and

8. explicit preservation of objections without argumentative repetition.

William Beaman as representative

William Beaman may be a plausible non-attorney representative only if he is not a party, fact witness, likely rebuttal witness, or source of material evidence. If he has substantive firsthand knowledge, authored relevant communications, participated in events, or may need to testify, combining witness and representative roles could create credibility, sequestration, and practical complications. Determine his witness status before designation.

Consulting attorney who does not appear

A consulting attorney can remain behind the scenes for drafting, coaching, and mock examination. Confirm whether UCLA requires disclosure when the attorney does not appear or receive records directly. The policy does not appear to expressly answer that question.

Highest record-preservation priorities

• Make timely scope and procedural objections.

• Submit all material evidence permitted by the hearing order.

• Make an offer of proof when evidence or testimony is excluded.

• Identify redaction or access problems in writing.

• Request rulings on disputed procedural questions.

• Authenticate documents and identify their source.

• Preserve witness nonappearance and requested attendance efforts.

• Ensure the recording captures objections and rulings.

• Submit focused post-hearing comments.

• Preserve the distinction between the CRO hearing and DGE lane.

Tasks not advisable without California counsel

• Filing or threatening a writ petition.

• Calculating the controlling judicial-review deadline.

• Waiving or settling federal or state claims.

• Signing a release, confidentiality clause, non-disparagement clause, academic-status waiver, or broad covenant not to sue.

• Issuing litigation holds or preservation demands framed as legal process.

• Communicating with opposing counsel about external litigation.

• Making public accusations intended as leverage.

• Engaging an expert whose role may affect privileges, disclosure, or admissibility.

Final synthesis

R. Final decision matrix

Evidence gaps requiring direct intake confirmation

The following remain unknown and should be resolved during the first consultation:

• Each lawyer’s actual availability before UCLA’s first material deadline.

• Whether the lawyer has a current UCLA, Regents, respondent, witness, or related-party conflict.

• Whether UCLA permits the proposed role of a non-California specialist.

• Which lawyer will personally perform the work.

• Exact graduate or doctoral academic-dismissal experience for Trygstad and German.

• Exact UC writ and public-university experience for Leigh.

• Recent UCLA or UC case experience for Kosnett.

• Whether Hathaway will offer a capped or limited-scope first phase.

• Whether any top candidate will accept $2,000–$4,000 for a meaningful Phase I.

• Hearing duration, Hearing Officer, witness authority, remote appearance rules, recording format, and disclosure schedule.

• Whether UCLA requires a specific designation or release form.

• Whether behind-the-scenes counsel must be disclosed.

• Whether DGE will hold academic-disqualification action in abeyance.

• Which continuation remedies each decision-maker has authority to grant.

• Applicable external limitations and exhaustion rules.

• Whether any nonprofit regards the case as within current priorities.

Claims from prior research rejected or downgraded

• A nationally prominent disability lawyer is not automatically a better internal-hearing lead than a California campus-procedure lawyer.

• Active litigation against UCLA or the Regents does not prove either a conflict or an advantage; it creates a conflict-screen issue.

• K–12 special-education hearing experience is transferable but not equivalent to graduate public-university academic-disqualification experience.

• “Education law” alone is not sufficient without student-side orientation, hearing capability, disability competence, and record preservation.

• A non-California lawyer should not be described as lead California counsel without resolving authorization, UCLA participation, and local-law coverage.

• Publicly advertised contingency work in civil litigation does not imply contingency representation for an internal grievance.

• Attorney fees are not automatically recoverable in the UCLA hearing.

• The ninety-day local-agency writ period should not be assumed to govern the Regents.

• The adverse investigation report does not itself eliminate the DGE mitigation or continuation lane.

• Finding 1’s exclusion from hearing review does not necessarily make every Bisley-related fact irrelevant to Findings 2–5, but it prevents using the hearing to seek a finding or remedy against him.

One-page decision table

Bottom line: The optimal first choice is Mark M. Hathaway for combined campus-hearing and California writ-record competence. The optimal second choice is James Victor Kosnett, particularly if a capped or unbundled engagement is necessary. Mandy G. Leigh is the strongest integrated disability-law alternative and may offer the best affordability pathway among the top three. The preferred hybrid is a California hearing lead plus a discrete Jason Bach, Mary Vargas, or other disability-specialist consultation, with the California lawyer retaining control of procedure and writ preservation. The primary pro bono lane is Disability Rights California, followed by DREDF for referral or specialist support.

The immediate sequence is to contact Hathaway, Kosnett, Leigh, Trygstad, and German in parallel; call the first three; begin DRC and certified-referral intake; obtain written capped Phase I proposals; and designate retained counsel immediately after engagement without altering the Findings 2–5 hearing scope.

EMAILS

GRIEVANCE HEARING EMAILS

Table of Contents

**1. Formal Grievance Hearing Request — Case 2025-07-00230-DPO
**2. Case 2025-07-00230-DPO — Hearing-Scope Confirmation, Record Clarification, Scheduling, and Good-Cause Extension Request
**3. SR01184644 Opened: Reopened from SR01178653: Reopened from SR01053187: Cooper Beaman [105692562] Academic Disqualification Appeal**

1. Formal Grievance Hearing Request — Case 2025-07-00230-DPO

From: ADA/504 Compliance Office adaoffice@ucla.edu
To: cooper beaman cooperbeaman@gmail.com, ADA/504 Compliance Office adaoffice@ucla.edu
Cc: Grievance grievance@saonet.ucla.edu, adaoffice@ucla.edu
Sent: Mon, Aug 3, 2026 at 2:50 PM

Dear Cooper,

Confirming your request for a hearing has been received. Someone will be in touch soon with next steps.

In the interim,

Do not hesitate to reach out if you have additional questions.

Thank you.

Best,

Yonit

Yonit Kovnator, JD (she/her/hers) ADA/Section 504 Compliance Officer Office (213) 238-3495

From: cooper beaman cooperbeaman@gmail.com
Sent: Friday, July 31, 2026 6:09 PM
To: ADA/504 Compliance Office adaoffice@ucla.edu
Cc: Grievance grievance@saonet.ucla.edu
Bcc: Dad wbeaman1@gmail.com, Mom coopsdaddy1@aol.com

Dear ADA/Section 504 Compliance Office and Grievance Coordinator,

I would like to correct a minor formatting error in my formal grievance hearing request sent at 5:00 PM today.

The initial “To / Cc / Bcc / Subject / Body” section was inadvertently retained in the email body. The Bcc line should be disregarded as a drafting artifact. The Bcc’d addresses (wbeaman1@gmail.com and coopsdaddy1@aol.com; coopsdaddy1@gmail.com is inaccurate and was not copied) are owned by my father, William Beaman, who served as my advisor during the DPO intake interview period, and were copied so he could retain a record of my outgoing request.

At present, I have not designated William, nor any other non-attorney as my representative for the formal grievance hearing. My representation-status detailed in the hearing request remains accurate. I have not retained or designated an attorney, and no attorney has agreed to represent me at this time. If I later designate retained counsel or William Beaman as a non-attorney representative, I will promptly notify the Grievance Coordinator in writing, identify whether the representative is an attorney, and complete any required authorization or release.

Please add this administrative clarification to the Case 2025-07-00230-DPO record. No response is necessary regarding this clarification.

Sincerely,

Cooper M. Beaman

Best,

Cooper

From: cooper beaman cooperbeaman@gmail.com
To: ada@saonet.ucla.edu
Cc: Grievance grievance@saonet.ucla.edu
Bcc: Dad wbeaman1@gmail.com, Mom coopsdaddy1@aol.com
Sent: Fri, Jul 31, 2026 at 5:00 PM

Dear ADA/Section 504 Compliance Office and Grievance Coordinator,

I received the Notice of Outcome, redacted Investigation Report, and redacted exhibits in Case 2025-07-00230-DPO on July 29, 2026, at 01:39 PM PDT.

I disagree with Findings 2 through 5 of the Investigation Report concerning Dr. Carrie Bearden and Dr. Felix Schweizer, and I hereby timely request a formal grievance hearing under UCLA Procedure 230.2 limited to those findings.

For clarity, I dispute the findings that:

1. Respondent 2 did not discriminate against me based on disability;
2. Respondent 3 did not discriminate against me based on disability and/or a request for accommodation;
3. Respondent 2 did not harass me based on disability; and
4. Respondent 3 did not harass me based on disability.

I am not requesting hearing review of Finding 1 concerning Dr. James Bisley, and I do not seek a finding or remedy against Dr. Bisley. Any reference during the hearing to NEURO M203 or related events would be offered only to the extent relevant to Findings 2 through 5, including the program’s stated academic-disqualification rationale, causation, harm, or mitigation.

Representation status: At the present time, I plan to receive assistance from an attorney at the hearing if I am able to retain counsel. I have not yet retained or designated an attorney, and no attorney has agreed to serve as my representative. Accordingly, there is no representative name or authorization form to provide at this time. If counsel is retained, I will promptly provide the attorney’s name, firm, contact information, attorney status, and any required written authorization. Please confirm the procedure and required form for supplementing my representative designation after this timely hearing request.

This email constitutes my timely hearing election as to Findings 2 through 5 and preserves my disagreement with those findings and with the material factual and analytical conclusions supporting them. I intend to present focused grounds, evidence, witnesses, procedural objections, and requested remedies in accordance with the schedule and procedures established by the Grievance Coordinator and Hearing Officer.

This hearing request is not intended to waive any favorable factual admission, request for additional record access or less-redacted materials, DGE/CDP position, post-hearing comment or appeal right, or other remedy available with respect to the findings at issue.

Please confirm receipt and that this hearing request has been recorded as timely. Please also:

1. confirm that the requested hearing scope is Findings 2 through 5 and advise whether any additional action is required to effectuate this scope limitation;
2. confirm the assigned Grievance Coordinator;
3. provide the Hearing Officer appointment and challenge procedure;
4. provide the proposed scheduling process;
5. identify the deadlines and required format for witness, exhibit, and other pre-hearing submissions; and
6. confirm the procedure for subsequently designating retained counsel.

I will be traveling from August 3 through August 11, 2026, and may not be available during that period. If an in-person proceeding is required, I would like to request mutually agreeable scheduling after August 11. This scheduling request does not alter, extend, concede, or waive any applicable deadline.

Sincerely,

Cooper M. Beaman

2. Case 2025-07-00230-DPO — Hearing-Scope Confirmation, Record Clarification, Scheduling, and Good-Cause Extension Request

From: cooper beaman cooperbeaman@gmail.com
To: Grievance grievance@saonet.ucla.edu
Cc: ada@saonet.ucla.edu, adaoffice@ucla.edu
Bcc: Dad wbeaman1@gmail.com, Mom coopsdaddy1@aol.com
Sent: Mon, Aug 3, 2026 at 4:56 PM

Dear Grievance Coordinator and ADA/Section 504 Compliance Officer Kovnator,

Thank you for confirming today that my hearing request has been received and that someone will contact me regarding next steps.

On Friday, July 31, 2026, at 5:00 p.m. PDT, I submitted a formal grievance hearing request under UCLA Procedure 230.2 limited to Findings 2 through 5 of the Investigation Report concerning Dr. Carrie Bearden and Dr. Felix Schweizer.

I am not requesting hearing review of Finding 1 concerning Dr. James Bisley and do not seek a finding or remedy against Dr. Bisley. Any reference during the hearing to NEURO M203 or related events would be offered only to the extent relevant to Findings 2 through 5, including the program’s stated academic-disqualification rationale, causation, harm, or mitigation.

This clarification and extension request does not condition, withdraw, postpone, or otherwise alter my timely hearing election or the scope stated in that election.

Please confirm:

1. that my July 31, 2026 hearing request scope is Findings 2 through 5; and that no further action is presently required to effectuate that limited scope;
2. the identity and contact information of the assigned Grievance Coordinator;
3. whether UCLA requires or permits a separate focused statement of hearing grounds before the hearing and, if so, the required format and deadline;
4. the process and anticipated timing for appointment of the Hearing Officer and any good-cause challenge to that appointment;
5. the proposed hearing-scheduling process, including whether remote participation is available;
6. the deadlines and required format for witness identification, witness proffers, exhibits, evidentiary objections, and other pre-hearing submissions;
7. the complete index of materials that will be provided to or otherwise made available to the Hearing Officer, including whether the Investigation Report and Exhibits A through R will be included automatically and whether any other material will form part of the hearing record;
8. whether the 2020 Kang memorandum, UCOP materials, CAE webpage material, PACAOS 140 material, APM provisions, and any other outside authority cited or materially relied upon in the Investigation Report will be supplied as part of the hearing record;
9. whether the Hearing Officer will receive less-redacted or unredacted materials and what procedure is available, under an appropriate confidentiality arrangement, for obtaining access to information necessary for a meaningful response; and
10. whether UCLA can provide a document-level index of the “hundreds of pages” of additional documents that “[t]he Investigator did not rely on,” identifying each document, any disposition assigned to it, and the basis for that determination, including whether the document was deemed insufficiently relevant, redundant to other evidence, or treated on another stated ground, without disclosing legally protected information (Investigation Report at 7 n.4).

To the extent UCLA requires a focused grounds supplement or any comparable early merits submission before the hearing, I request a reasonable good-cause extension through August 26, 2026, or ten University business days after UCLA substantially provides the requested record clarification, whichever is later. Please treat this paragraph as a written extension request under Section VI.D of UCLA Procedure 230.2 and route it, if necessary, to the official authorized to decide it.

Good cause exists because the July 29 production includes a 44-page report file and 119 pages of disclosed Exhibits A through R; contains material redactions; refers to hundreds of additional pages without a document-level index; cites or materially relies upon outside authorities that were not included within Exhibits A through R; and requires reconciliation with the underlying administrative record. I am also traveling from August 3 through August 11, 2026, although I remain available remotely and will continue preparing during that period.

This request concerns only a focused grounds supplement or any comparable early submission that UCLA requires. I am not requesting an extension of the already-completed hearing election. I understand that this request does not toll or change any deadline unless UCLA grants an extension and confirms the revised deadline in writing.

If the requested date cannot be granted, please provide the longest reasonable period available, identify the resulting deadline, and state whether any corresponding adjustment of the hearing schedule or Procedure 230.2’s 60-Day hearing-completion period requires action by the Hearing Officer or another authorized decisionmaker.

Thank you. Please confirm receipt of this follow-up request and provide written responses for each item above.

Sincerely,

Cooper M. Beaman

UCLA

3. SR01184644 Opened: Reopened from SR01178653: Reopened from SR01053187: Cooper Beaman [105692562] Academic Disqualification Appeal

From: Cooper Beaman cobeaman@g.ucla.edu
To: UCLA Division of Graduate Education ucla@service-now.com/ucla@service-now.com
Cc: cooper beaman cooperbeaman@gmail.com/cooperbeaman@gmail.com
Bcc: coopsdaddy1@aol.com, wbeaman1@gmail.com
Sent: Tue, Aug 4, 2026 at 5:10 PM

Dear Mr. Bailey,

On May 4, 2026, you confirmed that my “academic disqualification appeal regarding alleged violations of university non-discriminatory policies is still active and the DGE Dean will review any (appropriately redacted) investigated materials the UCLA Civil Rights Office produces.” You also requested that I “keep [DGE] updated on the status of the investigation.” This notice provides a formal status update regarding the UCLA Civil Rights Office (CRO) investigation (Case No. 2025-07-00230-DPO) pertaining to my academic disqualification appeal based on non-academic criteria in violation of UCLA nondiscrimination policies (Service Request No. SR01178653).

On July 29, 2026, at 1:39 PM PDT, CRO transmitted “the outcome letter, redacted investigation report, and redacted exhibits in the above-referenced matter.”

On Friday, July 31, 2026, at 5:00 PM PDT, I submitted a formal grievance hearing request under UCLA Procedure 230.2 limited to Findings 2 through 5 of the investigation report concerning Dr. Carrie Bearden and Dr. Felix Schweizer. On August 3, 2026, at 2:51 PM PDT, ADA/Section 504 Compliance Officer Yonit Kovnator confirmed my “request for a hearing has been received” and that “[s]omeone will be in touch soon with next steps.”

This limited hearing scope should not be understood to remove the NEURO M203 chronology or related materials from DGE’s separate academic-disqualification review to the extent those materials bear upon the program’s stated disqualification rationale, academic performance, causation, or substantive mitigating circumstances. Nor is my decision not to seek a hearing on Finding 1 concerning Dr. Bisley intended as agreement with every factual characterization or analytical statement therein.

The Standards and Procedures for Graduate Study at UCLA provide that:

[w]hile an investigatory office is processing the allegations, the Division of Graduate Education will hold the appeal decision in abeyance until that process has completed. … Once the investigatory office completes its process, said office will notify the Division of Graduate Education of the outcome, including providing appropriately redacted versions of any written investigation report (hereafter “Investigation Materials”). Based on the Investigation Materials, the Division of Graduate Education will determine whether the report reflects substantive mitigating circumstances that could have affected a disqualified student’s academic performance. (Standards and Procedures for Graduate Study at UCLA, “Student Appeals Process – Grounds other than Procedural Error,” p. 33)

Because I have timely requested a formal grievance hearing, the above-quoted provision does not expressly establish whether the investigatory process is defined as complete upon:

• transmission of the initial investigation report;
• completion of the grievance hearing;
• issuance of the hearing report;
• issuance and finality of the Vice Chancellor’s decision; or
• completion of any timely appeal and resulting Chancellor decision.

This notice therefore does not concede that the investigatory process has completed nor that any DGE 30-calendar-day period has begun.

Please:

1. confirm that my academic disqualification appeal based on non-academic criteria in violation of UCLA nondiscrimination policies remains active;
2. confirm the continued abeyance of my appeal decision pending the outcome of the formal grievance hearing, including any timely post-hearing comment and appeal process, or specify any divergent interpretation of “complete” regarding CRO’s investigatory process as procedurally prerequisite to DGE’s determination of substantive mitigating circumstances affecting academic performance, as reflected by the Investigation Materials;
3. identify each item DGE has received or anticipates receiving CRO’s transmittal of Investigation Materials, including corresponding title or description, date and time of receipt, version, and sender;
4. specify whether DGE presently considers any 30-calendar-day period to have begun and, if so, provide the triggering event, the date and time DGE received the operative Investigation Materials, the first counted day, and the resulting deadline;
5. specify whether DGE will defer its substantive determination until the Procedure 230.2 hearing route has concluded and whether DGE expects to receive or consider the hearing report, the parties’ post-hearing comments, the Vice Chancellor’s decision, and any timely appeal and resulting Chancellor decision;
6. preserve this notice, the July 29 transmittal information, all materials received from CRO, and the complete SR01178653 service record; and
7. provide advance written notice before DGE treats the investigatory process as complete or issues a decision on the nondiscrimination-based academic-disqualification appeal while these sequencing and Investigation Materials questions remain unresolved.

The investigation report’s policy findings do not independently address DGE’s determinative question regarding substantive mitigating circumstances affecting academic performance. However, the report documents disability-related functional limitations, University knowledge, academic effects, program and mentor-placement constraints, accommodation-process chronology, and the timing of academic-disqualification activity that may be relevant to DGE’s separate determination, irrespective of the report’s isolated policy conclusions.

Please confirm that this status update has been added to SR01178653 and provide the requested sequencing, Investigation Materials, and clock information.

Sincerely,

Cooper M. Beaman

UID: 105692562

Service Request: SR01178653