The form appointing Dr. Stretten described his appointment as being "for (the) duration of this training unless sooner terminated, and . . . subject to periodic review by resident review board." On August 13, 1973, Dr. Fishkin, Chief of Laboratory Services at Wadsworth, sent Dr. Stretten a memorandum informing him that his residency would be terminated in November 1973, the end of Stretten's first year as a resident. The memorandum made explicit that the termination was for unsatisfactory performance and "other considerations." The memorandum pointed out that several staff members had consulted with Dr. Stretten concerning his unsatisfactory performance during the period of his residency.