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Employer-Lawyer

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TRAIN INVESTIGATE DEFEND

Confidential Investigation Report


Attorney-Client Privileged
December 4, 2017

Jeffrey R Buhman, Utah County Attorney


100 East Center Street, Suite 2100
Provo, UT 84606

Dear Mr. Buhman:

On October 25, 2017, Utah County Deputy Attorney contacted my office and requested
a meeting to discuss a potential engagement of investigation services. On November l, 2017, I met
with - and at their office and discussed the scope of the proposed
investigation. At this meeting, it was agreed that an independent investigation would be appropriate
for internal complaints raised by a Utah County employee ("Claimant") against
("Respondent"). These complaints were expanded at a later date when Claimant submitted a complaint
with the Utah Antidiscrimination and Labor Division,

On November 7, 2017, the Utah County Commission approved the engagement of my office for
investigation services. I began the investigation by reviewing documents relating to Claimant's internal
complaints. I then conducted face-to-face (and telephonic) witness interviews with a total of 16
individuals, including Claimant and Respondent.

L Utah County Policy

Utah County Human Resource Rules and Regulations, Section VII (L), defines "sexual harassment"
broadly to include both "sexually oriented conduct that is severe or sufficiently pervasive to
unreasonably interfere with an employee's job performance or creates an intimidating, hostile or
offensive working environment" and "offensive behavior that is not clearly sexual in nature, but which
occurs only because of the victim's gender." Examples include "making... romantic advances toward
an employee", "touching.[an] employee in a way that is unwelcome" and "verbal conduct which
includes making jokes of a sexual nature, suggestive comments [or) sexual innuendoes."

Under this policy, county employees are expected to report any perceived harassing conduct to the
alleged harasser only "if they feel comfortable doing so" or to a supervisor in the employee's chain of

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command, including a supervisor in the employee's chain of command, the Director of Human
Resource Management, any County Commissioner, or the County Attorney. See Section VII (L)(5),
"Reporting and Investigating Claims." This Section also strictly prohibits any type of retaliation
against a county employee for making an internal complaint about harassment, regardless of whether
the underlying complaint is found to have any merit. Id.

n. Allegations of Disaiminatory Conduct

CLAIMANTS INTIAL ALLEGATIONS

Claimant alleges that Respondent engaged in certain unwelcome behavior toward her in the workplace.
These allegations were either reported internally to the County in writing on October 12, 2017 or were
disclosed during Claimant's interviews with the independent investigator, as follows:

April 21, 2017: Respondent summoned Claimant to his office late at night to make travel
arrangements for an out-of-state training that would be taking together. Claimant was
uncomfortable sitting along with Respondent in his office but did not verbalize her feelings. While
Respondent was on the phone with a hotel, he was told that the hotel had only one room available.
Respondent commented "Well, the single lady I am sitting with wouldn't like that too much."
Respondent later purchased airfare for trip and upgraded Claimant's ticket
(as well as his own) to first-class, despite Claimant's objections.

April 24, 2017: Claimant complained to Deputy Utah County Attorne that she was
uncomfortable with the first-class ticket upgrade.

April 26, 2017: Respondent told Claimant "you know I would buy you lunch anytime."

May 1, 2017: After Claimant told Respondent that she wanted to send to the
training meeting instead of him, Respondent left Claimant's office and, while walking down the
hall, told Witness 7 "[Claimant) messed with the wrong [persont"

May 4, 2017: While driving together in Respondent's vehicle to a golf event, Respondent told
Claimant about an individual who was fired from her last job due to "rumors that she had slept
with someone." Claimant commented, "How does that even happen?" Respondent replied, "That
would be like someone saying, I saw [Respondent) and [Claimant) having sex on the golf course."
Claimant objected, saying "Please don't spread rumors about me." While sitting together in a golf
cart, Respondent told Claimant a story about a time he was golfing with a realtor who took a short
break from the game to have sex with someone on the golf course, and that the realtor returned
shortly thereafter with "leaves in her hair." While on a putting green, Respondent told Claimant
that he was unhappy in his marriage, that he wanted to get divorced, and asked Claimant if she
dated "men who are divorced." Leaving the golf event in Respondent' vehicle, Respondent told
Claimant that "he could get sex anywhere" and boasted that women were "attracted to the power
he has [in his position]."

May5, 2017: Respondent complained to Claimant that he hates being married and that he "envied"
that Claimant- He then told Claimant that she was "uptight" and "there are things [she]

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could do to not be so uptight" and explained that ''sex relieves stress." He told Claimant that he
had an account on "Ashley Madison" but that he had never had an affair, and then commented
that he was "not trying to have an affair with IClaimanq"

May 8, 2017: Sometime during the week of May 8 - 12, 2017, Claimant complained again t
- about Respondent' behaviors. - responded that Claimant's
would be changed to a new Commissioner.

May8, 2017: Sometime during the week of May 8 -12, 2017, Respondent came to Witness 7's office
where Claimant, Witness 7, and Witness 4 were present. Respondent then ''lifted his jacket up, and
swung his bottom in !Claimant's] face saying, 'Kick it, it's the last time you're going to be able to.'"

May 9, 2017: was changed, and Claimant began reporting lo -

- June 23, 2017: Respondent told a county official that Claimant was not doing her job and that he
was upset with Claimant.

June 28, 2017: Respondent complained to a county employee about Claimant not answering her
telephone.

August 14, 2017: Respondent visited Claiman and told Claimant that he was offering
free tickets to the Utah County Fair. Claimant requested five total tickets.
At a later date, tickets were delivered to Witness 7 and Witness 8, but none were given to Claimant.

August-October 2017: Various allegations relating to her job performance timecard


review and concern that her step increase had not been received as of October 16, 2017.

October 4, 2017: Respondent reviewed Claimant's emails and retrieved a report relating to a
llml that was in "draft" form and was not to be shared in that form with
[Respondent] and his coworkers.

October 17, 2017: Respondent cancelled Claimant's keycard access to the office door located near
Respondent's office, but her access was restored after two days.

November 14, 2017: Claimant was excluded from a meeting in which Respondent and his coworkers
discussed During this meeting, Respondent accused Claimant of -

UALD COMPLAINT ALLEGATIONS

After the County contacted an independent investigator to investigate Claimant's internal complaints,
the County then received a complaint from the Utah Antidiscrimination and Labor Division
... In that document, Claimant states that she was (1) "harassed and discriminated against based
on my gender !female)" and (2) "subjected to unlawful retaliation" in violation of both state and federal
law, as follows:

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April 21, 2017: Respondent told Claimant he would "not date a- old" but that he would date
"someone like !Claimant] because !she) would be okay with the ages of his kids and would probably

April 21, 2017: Respondent told Claimant that she was "not hired for !her] looks, even though he
knows lsheJ must have been, at previous jobs."

May 4, 2017: While riding in a golf cart together, Respondent rubbed Claimant's leg above her
knee, and stated "Don't show it if you don't want it touched."

May 8, 2017: Claimant complained to "all upper management" about Respondent' behavior. One
of the members of upper management "rolled his eyes and said that [Respondent] was just trying
to ruffle some feathers."

UnQ
_s e_ cified
Date: Respondent became hostile to Claimant, made Claimant's work environment
hostile, and made "inflammatory, damaging comments" about Claimant and her work that are "not
based on actual job performance."

October 4, 2017: Respondent "[went) through !Claimant's] emails."

October 24, 2017: Utah County has failed to provide Claimant with her "step increase."

m. Investigation Process

As described in the introduction of this report, I interviewed a total of sixteen (16) individuals with
personal knowledge regarding the incidents described in Claimant's allegations. A brief summary of
each witness' statements are as follows:

Claimant: I interviewed Claimant on November 8, 2017, and again on November 14, 2017. Claimant
confirmed and clarified each of the specific allegations described above in this report.

Claimant described Respondent' conduct toward her before the May 9, 2017 as flirty,
teasing and inappropriate. She stated that Respondent' conduct was unwelcome, made her
uncomfortable, and that she viewed his conduct as "harassment." She acknowledged that she never
told Respondent that his conduct was unwelcome or that his conduct made her uncomfortable because
he was her ... ." However, she complained on various occasions to - andfor -
about the behavior and requested - switch in order to minimize her interactions with
Respondent. In her letter to -, datedjune 19, 2017, she referred to the "ongoing harassment
!that] I have previously discussed with you" and stated that Respondent had called and threatened one
of her subordinate employees as a form of "elevated level of harassment." After she complained to
- and the County Attorney's office, Claimant believes that Respondent learned about the
nature of her complaints and thereafter "really kicked up the harassment and retaliation."

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In addition to her inteiview statements, Claimant also submitted a written statement to County
Attorney Jeff Buhman, dated October 12, 2017, in which she describes many of the allegations detailed
above. She also submitted screen shots from her phone, telephone logs, emails, travel reservation
documents, copy of a reimbursement check, and other written information relevant to the claims in
her UALD complaint. Finally, Claimant confirmed that she has received her expected step increase
(on or about November 8, 2017) and she no longer had any concerns relating to this particular issue.

Witness 1: I inteiviewed Witness 1 on November 9, 2017. Witness 1 recalled that Respondent was very
supportive of Claimant when she was first assigned to his- However, he obseived Respondent'
behavior changed drastically in the spring/summer of 2017. Thereafter, Respondent was very negative
and "super derogatory" toward Claimant. He stated that the tension between Respondent and
Claimant makes the environment uncomfortable for everyone around them.

Witness 1 recalled an incident on October 13, 2017 when Respondent was upset about a late paycheck.
Respondent summoned Witness 1 to accompany him to Claiman While riding the
elevator together, Respondent expressed his anger about the paycheck, and state he was going to tell
the employees in Claiman "You fuck, and you fuck, and you fuck ... " Witness 1 warned
him not to do so. After exiting the elevator, Respondent entered Claimant's office area, began using
profanities, and accused employees of lying. He then stopped an employee outside the elevators and
warned her to "Tell that dumbass !Claimant] that she better get this fixed and I'm gonna get paid!"
Witness 1 recalled that, throughout this incident, Respondent was "loud, animated [and] angry" and
that his behavior "really crossed the line."

Witness 1 also recalled an incident when Respondent was pulled over by a sheriffs deputy for speeding.
Respondent claimed that he was only driving fast because he was late for a meeting with Witness 1.
However, Respondent did not have a meeting with Witness 1, and the excuse got him out of a speeding
ticket. Witness 1 summed up Respondent' behavior toward other county employees and officials to be
"very inappropriate, condescending and rude," "confrontive," and "really, very, very, very negative."

Witness 2: I interviewed Witness 2 on November 9, 2017. Witness 2 recalled that he had participated
in meetings where Claimant told him and others that she was concerned about Respondent' behavior,
that she felt "uncomfortable and bullied by him."

Witness 2 stated that he has obseived Respondent being "very inappropriate...calling people names,
putting them into fear." Witness 2 frequently warned Respondent "You can't do that stuff' or "Don't
threaten people's jobs" but despite these warnings, Respondent continued to "use bullying or control
tactics ... to get what he wants." Witness 2 described Respondent's behavior as "completely
unprofessional." Witness 2 stated that he was unaware of any continuing problems between Claimant
and Respondent following However, Witness 2 then recalled the details
surrounding Respondent' review of Claimant's email, and stated that he suggested to Respondent that
[Respondent and his coworkers] should have access to "all information that is necessary to the !their]
job." He told Respondent that someone in the Information Technology department should be able to
help him access the emails and information they needed.

Witness 2 also recalled the keycard issue, and stated that Respondent cancelled door access for
numerous individuals who were either no longer employed with the County or had no need for

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continued access. However, he stated that Claimant's access should not have been cancelled and he
believed that Respondent specifically targeted Claimant with the improper cancellation of her keycard
access.

Witness 3: I interviewed Witness 3 on November 9, 2017. Witness 3 confirmed that Claimant


complained to him that she was uncomfortable with Respondent' behaviors, including his comments
about sexual topics, and his touching of her knee while riding in a golf cart. Witness 3 stated there is
still a lot of tension between Respondent and Claimant, and he believes that tension is a result of
Claimant's complaints about Respondent' behavior.

Witness 3 described Respondent as "bombastic," "unable to keep confidences," "frequently offensive,"


and "disrespectful." He also stated, "I don't find anything he says to me to be trustworthy." Witness
3 also submitted two written statements, dated October 11 and 16, 2017, describing Respondent'
outbursts in when his paycheck was delayed. During that incident, he
heard Respondent yelling and use vulgar language, including referring to Claimant as a "worthless
piece of shit."

Witness 4: I interviewed Witness 4 on November 9, 2017. Witness 4 recalled a meeting where


Respondent put his clothed buttocks in the air and waived it around a group of employees . felt
his behavior was "inappropriate" and stated that all in attendance at the meeting "just fell into shocked
silence, but that's normal when we're around Respondent." Witness 4 stated that Respondent was a
great supporter of Claimant until the summer of 2017 when Claimant cancelled travel arrangements
for - training trip that Respondent was going to be taking with Claimant and other employees
on Claimant's staff. Since that time, Witness 4 described Respondent's behavior towards Claimant as
"It is retaliation, oh yeah!"

Witness 4 also submitted a written statement (undated) in which . described and confirmed the "butt
in (the] face" incident.

Witness 5: I interviewed Witness 5 on November 9 and 16, 2017. Witness 5 stated that because.
she was unable to answer
many o my questions. e in icate t at s e as seen Respon ent engage in poor behavior when
faced with a stressful situation. However, she is not aware of any actions by Respondent against
Claimant that would support the allegations of harassment and discrimination.

Witness 6: I interviewed Witness 6 on November 9, 2017. Witness 6 describes Respondent as "abusive,"


"demeaning" and "explosive," and "intimidating." Witness 6 recalled that Respondent spent a great
deal of time in Claimant's office back when they were "unified" before the summer of 2017.

Witness 6 recalled that Respondent confronted her on the day that his paycheck
was delayed. She also submitted a written statement, dated October 13, 2017, describing that particular
incident and Respondent' behavior toward her.

Witness 7: I interviewed Witness 7 on November 9, 2017, and conducted a follow up telephone


interview with. on November 17, 2017.

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Witness 7 recalled that Respondent and Claimant were very close professionally and on very "good
terms" in early 2017. However, around April 2017, Claimant began confiding to Witness 7 that she
was feeling uncomfortable around Respondent because of his behaviors. Specifically, she told Witness
7 that Respondent (1) put his hand on her bare knee while riding in a golf cart, (2) talked about his
unhappy marriage and how he wanted to get a divorce, and (3) stated that if he ever got remarried he
would want a woman like Claimant.

Around May 2017, Witness 7 recalled that Claimant declined to have Respondent accompany her on
-training trip. Following this decision, the relationship between Respondent and Claimant
made a "complete 180 degree change." Respondent angrily told Witness 7 that Claimant had "messed
with the wrong !person)" and, on a later occasion, threatened Witness 7 that it would be in his own
"best interest" to convince Claimant to return Respondent' phone calls. Witness 7 reported that
Respondent is "very intimidating" and "very threatening."

Witness 7 also provided a written statement in which he describes Respondent' effort to use bullying
tactics and negative information to "scare or intimidate" him.

Witness 8: I interviewed Witness 8 on November 9, 2017. Witness 8 recalled that Respondent and
Claimant got along well and were spending lots of time together early in 2017. However, that
relationship changed when Claimant removed Respondent from the-- Thereafter,
Witness 8 recalled hearing Respondent make numerous negative comments about Claimant, including:
"!Claimant] is so stupid, she doesn't even know how to budget" and "[Claimant] screwed up the budget
- your. is an idiot." Witness 8 also recalled hearing Respondent speak negatively about other
County personnel, including the IT department: "Get those assholes up here, they are so stupid."

Witness 8 also submitted a written statement, dated October 10, 2017, in which she describes additional
details about Respondent' behavior toward Claimant.

Respondent: I interviewed Respondent on November 13, 2017. During our investigation interview,
Respondent denied most of the factual allegations raised by Claimant. However, he did admit to a
few of the allegations, albeit with variations or explanations that are contradicted by himself or other
witnesses. For example, Respondent admitted that he stated on the phone to a hotel operator "I don't
think the single lady next to me would like that, or my wife." However, he claimed that he made this
comment while in the presence of Claimant, Witness 5 and Witness 7. However, neither Witness 5 nor
Witness 7 recall being present for this phone call or hearing Respondent make such a statement, and
Claimant credibly stated that the suggestive comment was made while she was alone with Respondent
late at night in his office.

Respondent also admitted that he "might have" made the commented to Witness 7, "You're
messed with the wrong Commissioner!" after Claimant asked him not to attend the -
trip. He justified his angry outburst by explaining that he was "livid" because he had "invested five
straight months" working with Claimant on preparing for the He then stated
that the reason he was upset about travel being cancelled is because he had tickets to a sporting event
that that he did not want to miss. However, he later suggested that he was not actually upset about
being asked by Claimant to skip the - and that he calmly replied to Claimant, "Fine, it's your

call" and later assured her, "I'm not mad at you."

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Aside from these few admissions, Respondent adamantly denied several allegations that were
confirmed by multiple other witnesses. For example, he denied that he ever raised his clothed buttocks
into the air and waived it around during a meeting. However, both Witness 4 and Claimant recalled
this situation clearly, and Witness 4 submitted a written statement (undated) confirming the details of
this incident.

Respondent also denied that he touched Claimant's knee while they were riding together in a golf cart.
In defending this answer, Respondent surprisingly claimed that the other golfers in his group were
always very near to his cart and would have seen any kind of touching. However, Witness 9 credibly
explained that Respondent and Claimant were often far away, "out of earshot," chasing their own golf
balls and that he would not have been able to see any kind of touching that might have happened in
the golf cart. Respondent also tried to divert attention away from the 'physical touching' question by
complaining to the investigator about what a bad golfer Claimant was, stating matter of-factly that
she could not hit a ball farther than the length of a conference table (approx. 10-15 feet). However,
Claimant confirmed that she had taken golf lessons in the past and was able to hit the ball out of the
tee area, and Witness 9 recalled that Claimant was often able to hit the ball 150+ yards.

Witness 9: I interviewed Witness 9 on November 13, 2017. Witness 9 recalled the golf event when he
and others joined Respondent and Claimant on the golf course. He stated that Respondent and
Claimant were riding in a golf cart together, so they were often far away and out of earshot while on
the course.

Witness 9 reports directly to coworkers. He stated that he tries to "do what


(Respondent] asks lhim) to do, to stay on his good side." He explained it is "best to please !Respondent]
if you can." He stated that Respondent' language is "pretty vulgar, [andl profanity laced."

Witness 10: I interviewed Witness 10 on November 13, 2017. Witness 10 recalled that Claimant came
to him to discuss some budgetary concerns relating to cancelled travel arrangements for a -
. At that time, Claimant told Witness 10 about Respondent' behavior which was making
rtable, and which caused her to remove him from them. Specifically, she explained that
Respondent called Claimant to his office late at night, that they were all alone and sitting together,
that he insisted that she ride first-class with him, and that he wanted them to stay in the same hotel.
Aside from Respondent' behavior, Witness 10 stated that he independently believes it would have been
inappropriate for Respondent, because of his position, to attend training for staff who would be
implementing and operating the county's new ( '-
Witness 10 observed that "since May 12017, Respondent] has looked for any chance to attack [Claimant]
and bring her judgment into question." Respondent has personally told Witness 10 on several
occasions, "If I could, I would fire her now." He stated that Respondent' should not have cancelled
Claimant's keycard access, and stated that Respondent' obvious efforts to criticize Claimant "in any
meeting, anytime" is "almost embarrassing."

Witness 10 stated that although he is frustrated with the Claimant's department right now and with
Claimant's management of the department, "you don't treat people the way !Respondent] treats them."

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He feels that Respondent' behavior "is an extreme example of unprofessionalism" and "100%
inappropriate."

Witness 11: I interviewed Witness 11 on November 13, 2017. Witness 11 recalled that Respondent was
very involved with Claimant in preparing for implementation of the . However,
his involvement and support for the program ''disappeared" after Claimant
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Witness 11 recalled that Respondent asked him to run a search for emails between Claimant and the
' Witness 11 ran the search and provided "anything from !Claimant] to-

Witness 12: I interviewed Witness 12 on November 13, 2017. Witness 12 recalled an incident when
Respondent was surprised to see Claimant in the hallway outside his office. He later told Witness 12
that he feels "uncomfortable" when Claimant is in the office area without his knowledge and that he
would ''prefer that she comes through the front door and be buzzed in." Shortly thereafter, he recalled
that Respondent got a list of all people with keycard access to the doors near his office and revoked
many authorizations, including Claimant.

Witness 12 stated that he feels uncomfortable being around Respondent, and described Respondent as
''a very dishonest person" who is "apt to fly off the handle." shared a personal example of
Respondent' dishonesty relating to a prior election when Respondent told one candidate for an office
(Candidate A) that he supported him, and then told the competing candidate (Candidate B) that he
supported him instead. He has also observed that Respondent is a ''bully to everyone" and that he
may not have ''singled out !Claimant] particularly." Witness 12 also recalled that, after Respondent
learned about Claimant's allegations against him, he told Witness 12 that he was "offended" by
Claimant's allegations and that he was ''not even attracted to her."

Witness 13: I interviewed Witness 13 on November 13, 2017. Witness 13 stated, "I generally try to hide
when !Respondent] comes around lour department]." finds Respondent's behaviors to be
"contentious", "negative", ''loud", and ''upsetting." Because of Respondent' behaviors, . often comes
to work "crying, sick, nauseated."

Witness 13 also submitted two written statements, one dated October 13, 2017 and the other undated,
describing confrontation with Respondent regarding - - and other
confrontations. Respondent was very angry and confrontational, upset that several departmental
employees were absent that morning, and ordered Witness 13 to "tell [Claimant] that she better have
her butt in here by BAM unless she has a different schedule approved by--" After this
incident, Witness 13 recalled that she was "shaking."

Witness 14: I interviewed Witness 14 on November 13, 2017. Witness 14 recalled that Respondent spent
a lot of time with Claimant in early 2017, including late nights at the office. However, after travel was
booked for - event, Respondent changed his behavior toward Claimant. He began
"hating her" and "logic was thrown out the widow," resulting in Respondent "just thinking straight
emotions, not logical, out to get everybody fired." observed that Respondent has made "lots of
accusations against county employees" and that. believes he is ''lying 90% of the time." In. best

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estimation, Respondent and Claimant ''are out to destroy each other, trying to take the county down
with them."

IV. Conclusions

The Utah County Attorney's Office specifically requested that I conduct a factual investigation of the
allegations made internally by Claimant, as well as the supplemental allegations contained in her
subsequent UALD complaint. I am not authorized to conduct any legal analysis regarding the merits
(or lack thereof) of the harassment and retaliation claims made in the UALD complaint.

Claimant appears to be a credible witness, and the evidence shows that she complained to several
county employees that Respondent' "harassing" behavior made her feel uncomfortable. Specifically,
she complained to Witness 3 and Witness 7 that Respondent touched her knee while riding in the golf
cart, and she complained to Witness 10 about Respondent pressuring her to get a first-class ticket to
the (so they could sit together) and wanting to stay in the same hotel with Claimant.
The fact that Claimant never told Respondent that she viewed his behavior as sexual and unwanted is
consistent with County Policy, which does not require the employee to confront the alleged harasser
unless the employee "feel[s] comfortable doing so."

Despite extensive interviews with multiple witnesses, I was unable to identify any eyewitnesses who
could either confirm or deny the various allegations of sexual or suggestive comments and behaviors
by Respondent, including: comments about his marriage, his dating preferences, Claimant's
attractiveness, touching Claimant's knee, comments about his sexual desirability, etc. Accordingly,
employing a "preponderance of the evidence" standard (i.e., more likely than not), I am unable to
conclude that Respondent engaged in any unwelcome sexual or suggestive behavior or conduct toward
Claimant.

Regarding the allegations of ''retaliatory" conduct, the majority of witnesses interviewed confirmed
that Respondent treated Claimant very well in early 2017, but that his behavior and conduct toward
Claimant changed dramatically around early May 2017 when Claimant asked him not to accompany
her o training trip. After that incident , Respondent
began treating Claimant in a very poor manner, waiving his buttocks in the air near her face, referring
to her as a "worthless piece of shit" and "stupid" and going out of his way to tell others (both in public
and in private) how he wanted her to be fired.

It is also important to note, based on statements from nearly all of the witnesses, that Respondent is
widely viewed as a workplace "bully", "dishonest," "demeaning," "intimidating," ''threatening,"
''explosive," and someone with whom personal interaction is to be avoided as much as possible.
Accordingly, under the ''preponderance of evidence" standard, I conclude that Respondent treated
Claimant in an unfair, demeaning and offensive manner after she asked him not to accompany her on
a - - and that this behavior was fully consistent with the way Respondent treats
many other employees of the County.

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Res pectfully submitted,
<
)
(Yt:)k,:
Spencer Phillips, Esq.
Date:

Independent Workplace Investigator

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