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There was evidence that numerous other females had left the respondent’s employ

shortly after their hire, presumably (and in the complainant’s belief) because of similar

predatory activity. The complainant, when silent and clearly annoyed with Claywell, was

sent to small rooms for “make work” projects where she was then confronted and

harassed by him. It would not be an unwarranted stretch to conclude that the

complainant was hired for the singular reason that she was deemed by Claywell to be a

suitable target for sexual harassment, a seemingly strong component of the

respondent’s raison des etres.

Because of Claywell’s success in isolating, surprising and disabling the complainant in

advance of his groping and propositioning, he achieved maximum shock value, which

greatly heightened the degree of offensiveness and the intensity of complainant’s

internal

emotional

reaction.

These

reactions

could

only

have

been

exacerbated

by

Claywell’s throwing heavy books at her feet and legs while she sat helpless on the floor

  • actions he clearly felt were warranted because of the complainant’s “lowly” female

status and her previous rejections of his initiatives.

There are matters such as Claywell’s vindictive and unjustified summoning of the police

in his trespassing claim, and the concern and aggravation sustained by the complainant

in her assistance to the authorities in Claywell’s criminal prosecution, that a court might

well deem worthy of compensation in a civil action against Claywell, one that might

include claims for battery and false imprisonment. Without clear authority, however, to

consider such matters in an administrative hearing on employment discrimination

Page 11 of 14

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