Melinda Guzman

Direct Line: (916) 551-2906

mgm@gfsacto.com

May 26, 2016

VIA E-MAIL, FACSIMILE & FEDERAL EXPRESS

CONFIDENTIAL PERSONNEL MATTER

Charles F. Robinson, General Counsel

Office of the General Counsel
111 Franklin Street, 8th Floor
Oakland, CA 94607
Re: Chancellor Linda Katehi
Dear Mr. Robinson:
This law firm has been retained to represent Chancellor Linda Katehi in connection with
her employment as Chancellor and faculty member of the University of California, Davis. On
April 27, 2016, University of California (UC) President Janet Napolitano placed Chancellor
Katehi on paid administrative leave. Notice of this administrative leave came to me via
telephone call from Allison Woodall of your office and confirmed by letter sent to me by email
that evening at approximately 8:35 p.m. Immediately thereafter, the UC reported this action to
the news media and shared the confidential two page letter sent to me to the news outlets,
which resulted in numerous publications of the letter and reports of this personnel action. The
acts of President Napolitano and the UC were unsupported by facts, unprecedented,
outrageous and reckless and intended to cause Chancellor Katehi personal harm. Her
reputation has suffered irreparable harm, which prompts her to lodge this complaint in order to
protect her integrity and professional reputation.
This letter serves as a formal complaint on behalf of Chancellor Katehi pursuant to UC
personnel policies for the Senior Management Group. The letter is directed to you and not to
President Napolitano or the Board of Regents, because I have been in direct communication as
counsel with Ms. Woodall of your office and I understand that your office serves as counsel for
the President and the UC in this matter. Please ensure that a copy of this letter is served on
each member of the UC Board of Regents on behalf of Chancellor Katehi.
The general facts presented below support various legal claims on behalf of Chancellor
Katehi for breach of contract, violation of privacy rights and defamation, violation of
confidentiality rights, retaliation, constructive termination and discrimination due to gender.
455 University Avenue, Suite 330, Sacramento, CA 95825
TEL | 916.448.0448 ~ FAX | 916.448.8628 ~E-MAIL | mgm@gfsacto.com

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 2

Chancellor Katehi has served as a loyal steward and leader of the UC system, and she
prefers not to file a lawsuit against the very institution that she loves. However, President
Napolitano demonstrated a complete disregard for California employment laws when she
announced to the media and to the public the administrative leave and the alleged basis for
that leave. Indeed, her actions were cold, calculated, intentional and reckless given that the
alleged basis for the leave were incomplete facts and misleading statements, which President
Napolitano knew or should have known would cause the public to believe that the allegations
were true. Her actions were reckless and worse yet intentional and aimed at harming
Chancellor Katehi and her family. Her actions were wholly inconsistent with the mission and
values of the UC system.
Kindly contact me as soon as possible to acknowledge receipt of this claim and to
confirm a process to handle this complaint before an independent third party to review these
facts and to initiate resolution of these claims. Time is of the essence.
Synopsis of Relevant Facts
Chancellor Linda Katehi has served as a distinguished member of the academy for over
39 years. In 2009, UC President Mark Yudof appointed her to serve as the sixth Chancellor of
the University of California, Davis. She is the first and only woman to serve as Chancellor of UC
Davis. As discussed further below, on April 27, 2016, UC President Janet Napolitano placed
Chancellor Katehi on paid administrative pending an investigation into alleged violations of
University policies. The allegations are wholly without merit, have for the most part been
proven as false assertions by the UCD Academic Senate, and only underscore the bad faith
nature of President Napolitanos actions. Chancellor Katehis service to both the UC and to the
UC Davis campus has been unmatched by her peers. We welcome a fair, independent and
neutral investigation into the allegations, which we expect will fully vindicate her of the false
accusations.
Chancellor Katehi was born in Athens, Greece. Her family lived by modest means, and
after graduating from high school, she was admitted to the National Technical University of
Athens on scholarship. During college, she was one of two women in her class, and in 1977, she
graduated with a degree in Electrical Engineering. Her experience in college helped shape her
interest in serving as a mentor to women and to students from underrepresented and emerging
communities as they pursue careers in engineering and in the sciences.
After graduation, Chancellor Katehi worked as a researcher at the Ministry of National
Defenses Naval Research Lab in Athens. Thereafter, upon the encouragement of a mentor, she
applied for and was admitted to the University of California, Los Angeles to attend graduate
school. In 1981 and 1984, respectively, she earned her Masters Degree and Doctorate Degree

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 3

in Electrical Engineering from the UCLA Henry Samueli School of Engineering and Applied
Sciences.
Chancellor Katehis career as a professor, researcher and administrator began initially as
a lecturer at the National Technical University of Athens, Greece from 1977-78. After earning
her doctorate, she served as a Professor of Electrical Engineering and Computer Science at the
University of Michigan, Ann Arbor from 1984 2001, and as an Associate Dean of Academic
Affairs and Graduate Education in 1994. She then became the first female Engineering Dean at
Purdue University in 2002. In 2005, she became the first woman Provost and Vice Chancellor of
the University of Illinois at Urbana-Champaign. During these years, Chancellor Katehi
demonstrated a keen interest in mentoring students, increasing the diversity of both faculty
and students, and in continuing with her research. Her work as a researcher has been stellar.
She holds 19 patents in circuit design and antennas. And, in addition to her work as a
professor, researcher and administrator, she has served as a mentor to over 70 postdoctoral
fellows and has been author or co-author in over 650 papers published in referred journals and
symposia proceedings.
In 2009, Chancellor Katehi became the sixth Chancellor of the University of California,
Davis. She is the first and only woman to serve as Chancellor at UC Davis.
In addition to her service within the university, Chancellor Katehi has been active in the
community and has been honored with numerous public appointments. President George W.
Bush appointed Chancellor Katehi to the Committee on the National Medal of Science, for
which she served as Chair. She was also appointed to serve as a member and then Chair of the
Secretary of Commerces Committee for the National Medal of Technology and Innovation, the
FBIs National Security Higher Education Advisory Board and she was named a fellow of the
American Association for the Advancement of Science. She was also elected to the American
Academy of Arts and Sciences, as a member of the National Academy of Engineering, and a
founding member of the National Academy of Inventors, among numerous appointments.
Chancellor Katehi has received numerous awards and accolades for her leadership in
education, including the AHC Aristeio Award in Academics and a Gabby Award for her
achievements in education. In 2012, she was named one of Californias Leading Women in
STEM by the California STEM Learning Network. And, on October 4, 2015, the National
Academy of Engineering presented Chancellor Katehi with its Simon Ramo Founders Award
recognizing her extraordinary impact on the engineering profession and leadership in
engineering research and education. She is the first woman to receive this prestigious award
since its inception in 1963.

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 4

While at UC Davis, Chancellor Katehi has raised more funds for the campus than any
prior Chancellor. She raised over $1 billion for the campus one year earlier than projected. She
has increased student enrollment, she has diversified the students, staff and faculty, and she
has earned the campus a place in history by making it a STEM, food and sciences focused
campus. The 2013 UC Davis Innovation Institute for Food and Health is but one example of the
many significant contributions made by Chancellor Katehi to the campus, region, UC and the
State of California.
Significantly, Chancellor Katehi is one of few women to serve as Chancellor of a UC
campus, and she is the first and only woman to serve as Chancellor of the UC Davis Campus.
Her performance has been stellar, and she has led the UC Davis campus in pursuing its
advancement goals and laying the foundation for a successful comprehensive campaign, among
other important initiatives. She has been instrumental in pursuing additional funding for the
UC Davis campus and for leading efforts to improve financial accountability and sound budget
management.
On April 25, 2016, President Janet Napolitano demanded that Chancellor Katehi meet
with her at the UC offices in Oakland. When they met, President Napolitano immediately
demanded Chancellor Katehis resignation from the university, with no explanation and without
regard to Chancellor Katehis significant contributions to the campus, to the UC system and to
her faculty rights under her employment agreement.
President Napolitano demanded that she resign immediately. She threatened her,
telling her that she would involve Chancellor Katehis family in an investigation. President
Napolitanos ruthless demands left Chancellor Katehi shocked and distraught. She urged
President Napolitano to explain the basis for the request, but President Napolitano refused
telling her instead that she had no letter prepared. President Napolitano persisted in
demanding that she resign during that meeting and ignored Chancellor Katehis requests to
allow her to speak with her husband and family. Chancellor Katehi told her that she could not
resign without understanding the basis for the resignation and without speaking with her
family.
As Chancellor Katehi stood up to leave the meeting, President Napolitano demanded
that she return the next day by 10:00 a.m. with her written resignation in hand. Needless to
say, Chancellor Katehi was shocked and distressed by President Napolitanos demands, the
threats to her family and the lack of information provided.
The following morning, I spoke to Ms. Woodall by telephone and informed her that
Chancellor Katehi would not resign from the university. I also reminded her that she holds
faculty rights under her employment agreement. I requested a meeting to discuss Chancellor

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 5

Katehis future with the UC, and we eventually agreed to meet on Thursday, April 28 th at the UC
office in Oakland.
After my discussions with Ms. Woodall, I learned that UC government relations
representative Steve Juarez had informed legislators Tuesday and Wednesday that documents
would be produced which would lead to an investigation and a forced resignation of Chancellor
Katehi by that Thursday. I was stunned to learn from third parties that the UC was discussing a
forced resignation of Chancellor Katehi even before our agreed upon meeting. I informed Ms.
Woodall of this information on April 27th and called into question the UCs good faith intentions
to meet with us that Thursday as scheduled.
Later on April 27, 2016 at 8:31 p.m., Ms. Woodall telephoned me to inform that
President Napolitano had decided to place Chancellor Katehi on paid administrative leave, and
that a letter confirming that leave would be sent to me via email. She told me during our call
that the decision had been made because Chancellor Katehi had discussed President
Napolitanos meeting with her with members of the faculty and others, which called into
question Chancellor Katehis intentions. I reminded Ms. Woodall that the UC lobbyist had
reportedly informed legislators of a threatened investigation and resignation, which itself called
into question the UCs good faith intentions. I also informed her that we stood prepared to
defend Chancellor Katehis reputation and integrity. Ms. Woodall also confirmed that our
meeting for the next day was cancelled. Within minutes of our call, I received the letter placing
Chancellor Katehi on paid administrative leave and which outlined allegations for an
investigation. The issues included alleged nepotism, misrepresentations concerning social
media contracts and a whistleblower complaint involving misuse of student fees.
Later that evening, several television and news outlets, including the Sacramento Bee
newspaper announced that President Napolitano had placed Chancellor Katehi on paid
administrative leave. Most reports also included a copy of the two page letter sent to me
confirming the leave and the allegations and whistleblower complaint. Since that time, the UC
has also broadcast the allegations and alleged whistleblower complaint and offered statements
about the facts to the news media.
The UC also announced the appointment of Orrick, Herrington & Sutcliffe and attorney
Melinda Haag as the independent and neutral investigator. Upon my queries, Ms. Woodall
confirmed that the Orrick firm regularly represents the University of California in other matters
and that Melinda Haag represented Janet Napolitano as Secretary of the Department of
Homeland Security and the Department while she served as US Attorney for the Northern
District. We therefore objected to the appointment of attorney Haag and the Orrick firm as
independent and neutral investigators, due to conflicts, and urged the appointment of a
true independent and neutral investigator. Ive received no response to that objection, and it
appears the investigation continues.

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 6

This formal complaint follows.

Disparate, Discriminatory Treatment
The UC was applauded when former President Mark Yudof hired Chancellor Katehi. She
was seen as a star candidate, a loyal university servant and as an individual capable of
redefining the mission of the campus, of increasing diversity for faculty, staff and students, and
of renewing focus on the sciences. She was also complimented as an individual capable of
advancing the campus in science, engineering and STEM education, research and advancement
and in diversity. Since 2009, Chancellor Katehi has served as an icon for the campus
constituents, and she has served as a role model for all students, and in particular for minority
and women students. The UC, and in particular the UC Davis campus have a longstanding
reputation for failing to recruit and retain minorities and women in positions of executive
management. In fact, the UC Davis campus itself has a poor track record for recruiting,
advancing and retaining minorities at all levels, and those who have risen to senior
management positions have mysteriously been asked to leave or to resign. Chancellor Katehis
appointment as chancellor gave hope to many for the future of the campus.
Chancellor Katehis forced administrative leave is contrary to the past practices of the
UC. Other Chancellors, all men, received favorable treatment when transitioning from their
roles as UC Davis chancellors. Male chancellors have not been subjected to the harsh
administrative leave or constructive termination presented to Chancellor Katehi. Instead, they
were offered soft landings, have been allowed to announce retirements with nine months or
more notice, have been directed to transition positions within other departments, sent on
assignment to the UC office or they have been given paid leaves of absence for extended
periods of time. In comparison, Chancellor Katehis abrupt administrative leave with disclosure
of private and confidentiality information compels any objective observer to conclude that her
treatment is based upon the fact that she is a woman.
It is also clear that Chancellor Katehi has been treated differently in comparison to her
male counterparts as concerns other aspects of her employment. Although UC policy permits
Chancellors and senior managers to serve on corporate boards, Chancellor Katehi is the only
individual who was forced to donate money from her service on a corporate board to the
University. No other Chancellor or other senior executive has been forced to do so except
Chancellor Katehi. Again, the facts lead to the reasonable conclusion that Chancellor Katehi
was treated differently due solely to her gender.
The conduct of the University of California and of President Janet Napolitano in
discriminating against Chancellor Katehi because of her gender and providing her with false
reasons for the paid administrative leave to cover up the true, discriminatory motives was
willful, malicious, reckless, intentional, and in conscious disregard for her rights. Based upon

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 7

the manner in which President Napolitano carried out the administrative leave, the public
disclosure of confidential and private information, and the leaking of misleading or incomplete
information to the media, I have no doubt that if required to proceed to litigation or trial,
Chancellor Katehi will prove that the acts were carried out with oppression, fraud and/or
malice, thus exposing the University of California to punitive damages.
Violations of Right of Privacy and Defamation
As a UC employee, Chancellor Katehi is owed a right of privacy with regard to her
employment. The UC violated her privacy rights when President Napolitano placed Chancellor
Katehi on administrative leave and announced it essentially to the world by disclosing private
and confidential allegations to members of the media and making public the letter which
announced her leave. The act of disclosing her administrative leave and violating her privacy
rights was intentional and done with the intent to force Chancellor Katehi to resign out of
duress.
The conduct of the University of California and of President Janet Napolitano in violating
the Chancellors right of privacy was willful, malicious, reckless, intentional, and in conscious
disregard for her rights. Based upon the manner in which President Napolitano carried out the
administrative leave, the public disclosure of confidential and private information, and the
leaking of misleading or incomplete information to the media, I have no doubt that if required
to proceed to litigation or trial, Chancellor Katehi will prove that the acts were carried out with
oppression, fraud and/or malice, and with the intent to harm and defame Chancellor Katehi
thus exposing the University of California to punitive damages.
Violations of Confidentiality
California law is clear that whistleblower complaints are by definition confidential in
nature. The UC violated the confidential nature of a whistleblower complaint when President
Napolitano placed Chancellor Katehi on administrative leave and disclosed the whistleblower
complaint to members of the media and making public the letter which announced her leave.
The act of disclosing the whistleblower complaint violated the Chancellors confidentiality rights
as an alleged suspect in the complaint. The disclosure was intentional and was clearly done
with the intent to force Chancellor Katehi to resign out of duress. Again, I have no doubt that if
forced to file a lawsuit, Chancellor Katehi will prevail in obtaining an award for punitive
damages.
Retaliation
Chancellor Katehi became the subject of Public Records Act requests by the Sacramento
Bee and other media outlets earlier this year. The UC Office of the President refused to allow

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 8

release of records in response to the requests, and in fact, it appears that the UCOP continues
to withhold documents in response to the requests. For weeks, the UCOP allowed the media
and therefore the public to believe that the delay in disclosure was at the hands of Chancellor
Katehi, knowing full well that the UCOP and President Napolitano directly refused to allow
disclosure.
Certain of the documents eventually produced establish that President Napolitano was
aware of Chancellor Katehis board appointments, and that 49 chancellors and senior managers
hold outside corporate board positions consistent with UC policy. For weeks, the UCOP allowed
the media and therefore the public to believe that Chancellor Katehi was alone in her board
service, and allowed them to believe that Chancellor Katehi had never received approval for the
appointment on the Wiley Board from the Office of the President.
Upon learning the documents had been released to the media in response to the Public
Records Act requests by the UC Davis campus, President Napolitano became angry at
Chancellor Katehi. Clearly, she did not wish the documents to be released. At approximately
the same time period, Chancellor Katehi appeared before the editorial board of the Sacramento
Bee to discuss questions of nepotism and public records requested, which again, angered
President Napolitano.
Lastly, all of this also occurred at the same time periods that Chancellor Katehi had
complained to President Napolitano that the UC Davis campus had been seriously underfunded
by the UC given its ranking in the recruitment and retention of diverse students and faculty.
Research confirmed that in fact UC Davis was and is sorely underfunded in comparison to other
UC campuses, a fact which President Napolitano refused to resolve.
As a result of Chancellor Katehis efforts to comply with the Public Records Act requests,
and pointing out information concerning the vast underfunding of the UC Davis campus in
comparison to other campuses, she believes that the basis for any disciplinary actions against
her are pretextual and meant to disguise the discriminatory reasons for her treatment and the
violations of public policy in connection with her treatment. Indeed, the outrageous act of
President Napolitano in placing her on paid administrative leave, and making public the letter
which announced her leave violated the Chancellors confidentiality and privacy rights, and was
done in retaliation to Chancellor Katehis efforts to comply with the Public Records Act requests
and her complaints about the significant underfunding of UC Davis. I have no doubt that if
forced to file suit, Chancellor Katehi will recover punitive damages, in addition to other
damages.
Constructive Termination
On April 27, 2016, the UC violated public policy by constructively discharging Chancellor
Katehi in violation of her rights under California law. The actual reason for her constructive

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 9

termination was based upon, among other things, the fact that she was discriminated against
as a woman, her efforts to comply with the Public Records Act requests, and her complaints
that UC Davis had been seriously underfunded in comparison to other campuses. If forced to
file a lawsuit, Chancellor Katehi will prevail and will be awarded punitive damages, in addition
to other requested relief.
Defamation and Intentional Infliction of Emotional Distress
As a UC employee, Chancellor Katehi is owed a right of privacy with regard to her
employment. As noted above, the UC violated her privacy and confidentiality rights when
President Napolitano placed Chancellor Katehi on administrative leave and announced it to the
world by disclosing private and confidential allegations to members of the media and making
public the letter which announced her administrative leave. The act of disclosing her
administrative leave and violating her privacy rights was intentional and done with the intent to
force Chancellor Katehi to resign out of duress. The allegations referenced in the letter
concerning nepotism, questions concerning Chancellor Katehis role with social media contracts
and a whistleblower complaint regarding use of student fee income were drafted with
incomplete or inaccurate information. The allegations and the disclosure of said allegations
were intended to mislead the recipients into believing that Chancellor Katehi or her family
members violated university policies. Furthermore, following the administrative leave, UC
representatives continued to make statements to the media and public about Chancellor
Katehi, her employment, the allegations, her family and the personnel action of placing her on
administrative leave all with the intent to suggest to the media and to the public that
Chancellor Katehi had in fact violated UC policies. The UC failed to exercise any reasonable care
to determine the truth or the falsity of their statements, as is apparent by the fact that the UC
Davis Academic Senate quickly reviewed the issues and opined within days that the same were
false.
The conduct of the UC and of President Janet Napolitano in violating the Chancellors
right of privacy and confidentiality and engaging in defamation of her and of her family was
willful, malicious, reckless, intentional, and in conscious disregard for her rights and the rights
of her family members. Based upon the manner in which President Napolitano carried out the
administrative leave, the public disclosure of confidential and private information, and the
leaking of misleading or incomplete information to the media intended to defame Chancellor
Katehi and her family, I have no doubt that if required to proceed to litigation or trial,
Chancellor Katehi will prove that the acts were carried out with oppression, fraud and/or
malice, that they constitute actionable defamation with the intent to harm and inflict emotional
distress on Chancellor Katehi and her family thus exposing the UC to damages for the harm to
Chancellor Katehis professional, occupation and reputation, emotional distress and punitive
damages.

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 10

The Allegations Against Chancellor Katehi are Wholly Without Merit

President Napolitanos letter of April 27, 2016 informed Chancellor Katehi that she was
being placed on paid administrative leave for 90 days, during this time an independent
investigator would be charged with investigating alleged violations of university polity
concerning three general areas: (1) questions regarding employment of Chancellor Katehis
husband, daughter-in-law and son, (2) concerns regarding alleged misstatements concerning
Chancellor Katehis role in social media contracts, and (3) a whistleblowing complaint
concerning misuse of student fee revenues. The allegations are completely without merit, and
on their face establish the bad faith nature of the allegations of the entire handling of this
matter by President Napolitano.
Because these issues are the subject of a so-called independent and neutral
investigation, I will not refute each allegation in this letter. However, I understand that the UCD
Academic Senate provided written documentation and testimony to confirm the basis for its
opinions to attorney Melinda Haag and the Orrick firm that each of the allegations are without
merit.
Demand for Damages
Chancellor Katehi has been a dedicated, committed and loyal servant of the University
of California. She has been recognized for her work in the sciences and in engineering, for her
research and fundraising, for her work in mentoring students, and for her leadership as an
administrator. On April 27, 2016, she was constructively terminated contrary to objective
measures of success, her exceptional performance for UC Davis and for the UC system as a
whole, and in violation of her rights under California and Federal laws. The abrupt
administrative leave, the constructive termination of her employment as Chancellor, the public
disclosure of confidential and private information, and the reckless or intentional disclosure of
misleading or incomplete facts to the media and to the public threatens her continuing salary,
her rights as a tenured faculty member and her retirement, and her standing with the university
as a respected administrator, researcher and faculty member.
This constructive termination threatens her ability to apply for or accept comparable
employment given that the nature of her separation from the university and the outrageous
disclosure of information will undoubtedly be construed as a termination and always calling
into question her integrity and ethics. Chancellor Katehi has been irreparably harmed given the
very public and outrageous way in which the UC and President Napolitano carried out this
administrative leave. If these matters are not resolved in a timely manner, Chancellor Katehi
will have no choice but to seek compensation for lost salary, retirement benefits, and the
substantial and irreparable harm to her reputation and character. In addition, her family has
suffered as a result of these public allegations, which has also resulted in harm to them.

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 11

In addition to damages related to her professional reputation, salary and retirement,

Chancellor Katehi has also been damaged to her health. This abrupt administrative leave and
public defamation has caused her to suffer loss of sleep, panic attacks and depression. She has
been ill with the grief associated with the very shocking demand that she resign from the
university and the very public disclosure of the action to place her on administrative leave,
with disclosure of the letter and private and confidential information concerning the allegations
made public to the media and to the public. She is also worried about her husband, son and
daughter-in-law who have been slandered by the disclosure of incomplete, inaccurate
information which has harmed their professional reputation. If these matters are not resolved
in a timely manner, Chancellor Katehi will be forced to seek compensation for damages to her
health and reputation, in addition to other damages, which will be sought if this matter
proceeds to litigation.
Demand for Third Party Meeting
The Personnel Policies for Senior Managers and these egregious facts compel the
appointment of an independent third party to review facts, provide an opportunity to
Chancellor Katehi to present witnesses and evidence, and to submit a report of the facts to the
Board of Regents to resolve these claims. On behalf of Chancellor Katehi, I demand the
appointment of a mutually agreed upon, independent and neutral third party to resolve these
disputes. This appointment should be made within the next 15 days to ensure timely and good
faith efforts to resolve these claims.
President Napolitano demanded that Chancellor Katehi announce her resignation, and
she has now commenced the investigation to be conducted by attorney Melinda Haag and the
Orrick firm. As previously noted, I object to their appointment as the independent and neutral
investigators regarding the April 27, 2016 allegations. The Orrick firm regularly represents the
UC in legal matters. Ms. Haag also regularly represented Janet Napolitano as Secretary of the
Department of Homeland Security. Both the Orrick firm and Ms. Haag have conflicts of interest
in serving as independent or neutral investigators, especially where under the alleged facts,
President Napolitano is a witness.
As an alumna of the University of California, Davis, I am deeply disappointed that
President Napolitano has taken these offensive and unprecedented steps to terminate
Chancellor Katehi. As a former member of the Board of Trustees of the California State
University system, I strongly believe that this personnel matter was improperly managed by
President Napolitano. This letter provides the UC with an opportunity to in good faith reflect
on these actions and to engage in good faith discussions to resolve these claims and to avoid
unnecessary litigation. Under any objective standard, President Napolitanos actions against
Chancellor Katehi subject the UC to criticism and liability.

Charles F. Robinson, Esq.

Re: Chancellor Katehi
May 26, 2016
Page 12

Please contact me within seven (7) days to discuss this letter. I welcome an early
meeting to discuss these very important issues. While we wish to avoid filing a lawsuit, we will
not hesitate to file a lawsuit to protect Chancellor Katehis integrity as a respected engineer,
tenured faculty member and leader of the university based upon the egregious, offensive,
reckless and intentional acts of President Napolitano described in this letter.
I will await your timely response.

Very truly yours,

Melinda Guzman

MGM/slm