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complainant between the chair and the desk in his office whereupon he put his hands

around

the

complainant’s

waist

and

slid

them

down

and

rubbed

her

thigh.

The

complainant objected and the incident ended when they were interrupted by

respondent’s

bookkeeper,

Barbara

Mangesi

(Barbara).

A

day

later

(September

15,

2004), annoyed that the complainant was not speaking to him, Claywell threw books at

the complainant’s feet as she was trying to pack them. On September 15, 2004 after

the complainant had expressed her displeasure with Claywell for berating her unfairly,

Claywell suggested that he bring in a bottle of liquor so that they might drink together

and she (complainant) could then go home and have “sex with men.” The complainant

objected to this line of conversation but Claywell persisted. On September 20, 2004,

Claywell rubbed his arm up against the complainant’s chest and grabbed her breast as

she attempted to access the copy machine. He told the complainant to loosen up and

relax and again put his hands on the complainant in a controlling manner. Told to stop,

he did so, but again started talking about alcohol and sex. On September 22, 2004,

while the complainant was cleaning up old blue prints, Claywell commented about the

complainant’s “muscles” and “great body.” Claywell touched the complainant on the

arm and she left the premises in protest.

The complainant then decided she must leave the respondent’s employ and after a

library computer search, determined that Claywell had previously been charged with

criminal sexual misconduct, and found guilty on two occasions. The complainant issued

a letter of resignation on or about September 24, 2004 by certified mail, which was

refused and unclaimed.

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