SUMMARY OF DEPOSITION OF MARIANNE MOORE

Name: Marianne Moore.
Address: 430 Lee Street, Iowa City IA 52246
Former Address: 1033 Maxwell Ln, Bloomington
Phone: 319-358-4621
Family: husband Thomas Gray, no children
DOB: June17, 1970
Employment: Unemployed, former secretary, Bloomington Dept. Human Resources

MM used to be a secretary for the City of Bloomington Department of Human Resources. While working there, she claims she was sexually harassed by her department head, William Hunt. When she tried to complain about it to Deputy Mayor James W. Riley, he refused to take any action. Shortly thereafter, she was fired after speaking to a newspaper reporter about the harassment and the city's refusal to do anything. Since losing her job, MM says she has been unable to find a new one because she is being blackballed by City Hall. She has answered about 50 want ads and gotten nothing. She claims the whole thing was done with the knowledge and approval of the mayor, Sara Teasdale.
MM worked as a secretary for the city from January 9, 1999, through sometime in May, 1999. Throughout that time, William Hunt was the Director of Human Resources and her boss. The department had about six or seven people in it. Hunt appeared to have authority to do whatever he wanted, including hiring, firing and promoting his employees. James Riley was the deputy mayor. He was the person in charge of handling personnel complaints, including harassment and working conditions. Sara Teasdale was the mayor. MM was making a salary of $20,000.
During her first week on the job, MM thinks on Thursday, Hunt asked her to lunch. It was a social lunch, and some other people from the office were there also. The next week, he invited her again to lunch, only this time it was just the two of them. MM was then warned by other secretaries that Hunt has a history of hitting on the women in the office. He asked her again a week or so later, but MM said "no." A couple of weeks later, Mr. Hunt asked her if MM wanted to go for a drink after work with him and several other people from the office. MM agreed because he said other people were going. However, no one else from the office ever showed up. MM got very nervous and left after about 45 minutes.
In early March, Mr. Hunt stopped by the desk and told MM there was an opening for an Assistant Director and that he thought she should apply, but that she needed to quickly acquire some training in human resources and personnel issues. MM asked him how she would do that, and he said there was a weekend training course being offered in Indianapolis in two weeks that would cover a lot of the basics of human resources management and that she should go to that. He gave her a brochure with an application form and she called the number and registered for the Conference and got a hotel room at the conference site..
MM attended the conference on Friday. After dinner, she went back to her hotel room. She telephoned her husband, talked to him very briefly to tell him she was going to go to bed, and then she showered and put on a nightgown. She was getting ready to go to bed when there was a knock on the door. MM opened the door and Mr. Hunt was there. He pushed his way in, stepped up to her, grabbed her with his hands around her back, and said "I've been waiting for this for a long time." Then he pulled her towards him and kissed her on the mouth. MM started struggling and pushed him away and screamed. He took a step back and he gave her an evil look and he said "I must have misunderstood, I thought you wanted this promotion. Well, too bad for you." Then he left.
Next week at work, Mr. Hunt gave her a bad employee review. He said she had been absent from work too much, had poor computer skills, and had a hostile attitude. MM says there wasn't anything wrong with her computer skills or her attitude before she rejected his advances. It is clear to MM that this was retaliation.
MM went to see Deputy Mayor James Riley to file a sexual harassment complaint. Riley was hostile, asking why she hadn't complained earlier, why she had let Hunt into her room, and whether she had any witnesses. When MM insisted that she wanted something done, he said he'd look into it. But he never did anything about her complaint, and he wouldn't see her. MM would call him and leave a message, but he would not call me back. She tried to get an appointment and his secretary said that there was no appointment available or he was out of town. MM was later told that Mayor Teasdale had in fact ordered Hunt to stall the case and do nothing.
Towards the end of April, MM received a call from a reporter for the Bloomington Choice. The reporter said she had heard from an unnamed source about the sexual harassment and the refusal of the Mayor to take any action, and she wanted MM to confirm it. MM basically told her what had happened and that she'd complained and that she'd heard they were stonewalling it and that Riley wasn't doing anything about it. A few days later a story came out in the paper about the case -- the clipping is attached.
Next day, MM saw Jim Riley storm into Mr. Hunt's office and slam the door shut. She could hear their voices raised and heard Riley yell, "Fire that bitch -- this is straight from the Mayor herself." Shortly after that, Hunt came up to her and said "You're fired, clean out your desk" and he handed her a letter that said she was being fired for absenteeism and poor job performance.
Since early May, 1999, MM has been looking for a new job, but without any luck. They seem interested, and then they call back and say, "Sorry." She got very depressed, and says she found out that the reason was that Mayor Teasdale, Jim Riley and Mr. Hunt were deliberately blackballing her and had agreed together to give her bad references so she couldn't get another job. She was told by someone who overheard them saying they were going to "run her out of town" as payback for embarrassing the mayor's administration.
Since being fired, MM has become very depressed, and has started seeing a therapist at $75.00 per session. During the summer after she was fired, MM began to get severe migraine headaches -- up to three per week. She describes them as seeing flashing lights. She would simply have to stop wherever she was and sit down or lie down. They were completely incapacitating for up to 24 hours. She also says she suffered stress -- found herself crying at times with no explanation -- probably once a week. She began to fight periodically with her husband Tom. She lost 15 pounds in six months. MM had two problems with sleep. She'd fall asleep exhausted about 11 o'clock and would wake up at 2:30 or 3 o'clock with wild thoughts running through her head about never getting a job, and never being able to have children because they couldn't afford them. Her doctor (Eliot - Bloomington) prescribed various medication, but they were not very effective.