SUMMARY OF DEPOSITION OF WILLIAM HUNT

A. CASE
Section 1983 case in Southern District. Hunt has been served with complaint attached. Being sued by former secretary for sex harassment/discrimination when he was director of Human Resources.

B. BACKGROUND
William Hunt
631 Grandview Ave, Bloomington
331-1137
Self-employed consultant in personnel and human relations issues.
Prior job: Director of Human resources, City of Bloomington
Born on April 17, 1961
Married twice -- first to Helen Maria Fiske, then to Mary Coleridge. Both marriages ended in divorce. Hunt has custody of the three children from first marriage.

C. FACTS -- ROUGH CHRONOLOGY
Hunt started work as Director of Human Resources for the City of Bloomington, in 1994, and left when Mayor Teasdale did not run for reelection in November 1999. The Department had seven employees -- three secretaries, three professional staff, and one part-time counselor. Hunt administered the department, but was not part of the Mayor's policy making group. He had authority to hire and fire staff, but policies were determined by the Mayor.
During his tenure, two previous complaints were filed against him. The first was filed by Phyllis McGinley, a secretary. She was a chronic complainer -- about working conditions, seniority, and unions or lack of unions. When she quit in 1996, she filed an employment discrimination claim that she was paid less than the men in the department. The complaint never went anywhere -- the men she was comparing herself to had higher civil service classifications.
The second complaint was filed by another secretary named Mary Robinson. It also had to do with working conditions. She complained that she was being asked to do things outside her job description, like make coffee and run errands. She claimed it was because she was female, which is not the reason -- she was just the lowest ranking member of the staff, so she got stuck with the bad jobs. The complaint was dropped when she was transferred in December 1998 to Purchasing, which has a female department head.
Hunt states categorically that he never harassed or discriminated against these or any other women employees.
In January, 1999, Hunt hired Marianne Moore to fill a secretarial position. She appeared smart and had previous secretarial experience. She said she was a single mother and had been laid off from her previous job. She needed the work and had a recommendation from someone in the Democratic Party, so he hired her.
When Marianne started working in the department, Hunt made an effort to include her in group lunches. It was a common practice for a group from Human Resources to have lunch together about once a week. Hunt started this custom because he thought it would help the department work together as a team. Once in awhile they went out after work to celebrate somebody's birthday. Marianne was invited along with everyone else, but only went a few times.
There was one awkward occasion in February that Marianne could have misinterpreted. Hunt had organized an after-work get-togethers for a reason that he can no longer remember. Usually they walk over to a nearby bar as a group. This time there were a couple of people who canceled, and other people said they would meet Hunt there so Hunt and Marianne ended up walking over to the Malibu Grill by themselves. No one else ever showed up, so it was just the two of them. They had a pretty good time, but it was awkward because Hunt had just separated from his wife. He believes in retrospect that the office staff was trying to fix him and Marianne up together and deliberately left them alone at the bar.
Hunt admits being attracted to Marianne at the time. She was a few years younger than him, smart, and attractive. Hunt had enjoyed talking to her at the lunches and other group events. But he states emphatically that the fact that he was attracted to her doesn't mean that he did anything about it. Even though the city has no official policy against office romance, it seemed inappropriate to him, and he did not ask her out.
In March, Hunt attended a two-day conference on human resources in Indianapolis. He was surprised to see Marianne at the conference. He hadn't been aware that she was going to be there, and certainly did not suggest that she should attend. These conferences are designed for senior administrators. Hunt realized that she probably didn't know anyone, so he invited her to go with a group of people to dinner. She accepted. There were about seven of them -- four men and three women, he thinks. When they sat down, Marianne picked the seat next to him. After dinner, they said goodnight. Hunt says Marianne appeared to be flirting with him, but he's not really sure because it has been so long since he was single. Marianne said something like, "Thanks for everything, you've been very nice to me, and I hope I can do something nice for you at some point. I'll see you later." He says that she said "I'll see you later" so that it went slightly up in pitch at the end, like a question rather than a statement. He went to his room, and all of a sudden began to wonder if Marianne had made a subtle pass -- suggesting he see her later that night.
He didn't know what to do, not having dated in 15 years. He says he was always a bit of a nerd anyway. He went downstairs to the bar and had a couple of drinks. He asked the bartender for his advice, and the bartender advised that Hunt should ask her if she wants to have a drink. If she says yes, then he would know that she was interested in him, and if she said no, he would also know the answer. Hunt had another drink for courage, and went up to her room. He knocked on the door and asked her if she wanted to go have a drink with him. She looked startled and she said something about being married, and just stood there staring at him. He says he said something like, "I'm sorry -- I misunderstood," and then fled down the hall, very embarrassed. He had thought she was a single, and had not realized she was married.
Hunt vehemently denies touching her. He says he did not enter her room, but stood in the doorway. He did not kiss her, and he left as soon as it became clear that he had misinterpreted her interest in him.
Things were a bit tense around the office for a few days. Hunt had to give Marianne a critical evaluation of her first two months on the job late in the following week. It was balanced, but pointed out that she needed to improve on absenteeism and some below-average job skills. The evaluation was in the works before the conference and had nothing to do with the embarrassing incident at the hotel.
Hunt was not aware that Marianne had filed a sexual harassment charge against him until the end of April when he read about it in the newspaper. Neither she nor Deputy Mayor Jim Riley ever said anything to him directly. Hunt says there was nothing discriminatory in her negative evaluation. Half his staff is female, and he gave them good evaluations. The newspaper reported that he had harassed Marianne, pursued her, made sexual overtures to her, and had offered her a promotion in exchange for sex. Hunt was stunned to read this. The allegations were completely false.
Hunt says they had to fire her shortly thereafter. Marianne just never worked out. She was absent from work a lot. Her computer skills weren't very good and did not improve. Her attitude became increasingly withdrawn and sullen, and the absenteeism problem continued. The timing may make it look like retaliation for going to the press, but he states positively that it's not. City policy is that a new employee is on probation for four months, and then either fired or given a permanent position. Marianne's four months were up the first week of May, 1999.
As to her complaint that city officials conspired to give her bad references -- Hunt says that's ridiculous. He never got a single call asking for a reference -- he's certain she did not list him as a reference after what happened. He says he never talked to either Riley or Mayor Teasdale about her.
Except for the one incident with Marianne, Hunt says he has never asked a female employee or intern out on a date. He was married up until the spring of 1999. He never made a sexual proposition to or had any romantic affair with any female employee or intern.