SUMMARY OF DEPOSITION OF JAMES RILEY

Name: James W. Riley
Address: 2333 Woodstock Pl, Bloomington
Telephone -- Home 322-2522 Work 855-4846
Social Security Number 238-82-3918
Marital Status M
Spouse name
Christina Rosetti
Children names, ages, DOB
1. Philippa C Age 3
2. James R Age 2
Age 46
DOB Jan 23 1965
Occupation Clinical Professor
Employer Law School
Address Bloomington
Income (gross) $80,000
Education JD Duke 1981
Military No
Past jobs Deputy mayor of Blmgtn
Law School faculty
NYC prosecutor
McDonalds mgr
Business, social St Charles Catholic Church
civil orgs Safe City Task Force
Police Commission
Criminal record No
Traffic record Minor
Narrative of events
In early 1999, William Hunt was director of Human Resources at the City of Bloomington. He reported to JWR who was deputy mayor. JWR reported to mayor Sara Teasdale. JWR's duties included supervising city departments, acting as city's affirmative action and compliance officer, substituting for mayor when she was unavailable, screening requests to see the mayor, and handling public relations.
Based on what he's heard, Hunt hired Moore in January. He was having marital problems at the time. He started asking Moore out to lunch and on dates. Reports that Moore did go out with Hunt several times, and they ended up in a hotel room together in late March. Details unknown.
Whatever relationship there was between Hunt and Moore went sour after the hotel incident. Moore apparently ended the relationship. Hunt then gave Moore a bad performance review. At this point, JWR becomes involved for first time.
On approximately March 28, 1999, Moore went to JWR's office. She complained that Hunt had been harassing her. She said Hunt had asked her out on dates several times, beginning in January her first week on the job. She said the most recent incident was two weeks previous, but that he had mostly ignored her the last two weeks. She also complained that Hunt had promised to consider her for the position of Assistant Director of Human Resources, but that he had actually hired someone else and had never considered her a legitimate candidate. She further complained that she had received an unwarranted bad job performance review. JWR asked if she wanted to file formal charges against Hunt, she said "No," she just wanted it to stop. JWR said he'd look into it and talk to Hunt. Moore seemed satisfied at the informal steps he proposed.
JWR pulled Moore's personnel file that same day. It showed repeated absences and below average job skills. The date on the letter giving her a critical job performance was only a few days before she came to complain, so JWR believes the complaint was motivated by getting the poor evaluation. JWR's secretary tells him that the rumors going around the office are that Hunt and Moore are having an affair, and that they went away for the weekend together in mid-March.
Over the next few days, JWR looks for Moore to ask her about this rumor, but she is absent from work. The head secretary in Human resources (Amy) says she never called in, so they don't know why she is absent -- clear to JWR from tone that this has happened before.
Approximately April 3, JWR goes to talk situation over with mayor Teasdale. He tells her Moore has complained about Hunt asking her out, but that it is his guess that this was an office romance gone sour. Teasdale asks if a formal complaint has been filed, JWR says no. Teasdale says to wait a bit before doing anything more -- if it is an office romance, let's let it cool off a little. In the meantime, JWR is to keep an eye on Hunt, try to figure out whether they are or were having an affair. She says to fill her in in a couple of weeks when she gets back from the National Mayors' Conference in Denver.
A couple of days later, JWR mentions to Hunt that Moore was complaining about him and trying to make it sound like sexual harassment. He asked Hunt if she had any basis for claiming sexual harassment. Hunt says no, she's just mad because he gave her a negative evaluation.
Over the next 2 weeks or so, JWR consciously ducked Moore's attempts to see him -- didn't return phone calls and instructed secretary to tell her he was gone on business if she came by. He was waiting for Mayor to return from vacation. During this time, Moore made no attempt to file a formal complaint -- everything was still proceeding informally.
On approximately April 17, the mayor left for the National Mayor's Conference. A few days later, JWR got a phone call from a Bloomington Choice reporter (name unknown) who said she heard about sexual harassment of Moore by Hunt, and had heard that the city was doing nothing about it. JWR tells the reporter that he could not comment on specific allegations against Hunt because it was a pending matter. He said that the city always investigates and takes seriously any claim of harassment by an employee. In prior cases of this sort, however, they had discovered that a better more amicable resolution could be found if they gave the parties a couple of weeks to cool off and try to work out their differences between themselves before formal proceedings were begun, so the mayor had a policy that he was to proceed slowly at first, try to mediate, and become formally involved only if the individuals could not work things out themselves.
On April 26, the Choice printed a story about the allegations of sexual harassment, and made it sound like the city was doing nothing. JWR says that he was quoted accurately except that he did not recall referring to harassment complaints as "petty." JWR does not remember whether he told the mayor about the news story -- he called her every couple of days while she was away to consult over issues that arose. He is pretty sure he told her, but cannot remember what she said about it.
JWR was unaware that Hunt fired Moore after the story came out. He was still avoiding both Hunt and Moore as instructed by the mayor, waiting for her to return so she could decide what to do.
On Friday, April 28, Mayor Teasdale returned. She was angry at the story in the Choice because it hurt her politically among working women who had always been her primary supporters. She said, "I'm going to have to throw somebody to the wolves, Jim, and you're it." Then she fired JWR, saying he should never have talked to the press on a hot issue like this without talking to her first.
JWR gets his old job back at the law school, working in its clinical program. He has no further contact with anyone concerning Moore, Hunt, or this incident, until he was served with the complaint. He had no conversations with either Hunt or Teasdale about anything that he can recall.