Defendant LR. Costanzo hired plaintiff on March 11, 1999. Plaintiff contends that she has been exposed to a sexually hostile work environment and has been subject to two forced sexual encounters with Defendant Michalek. In October 2001, plaintiff’s employer requested that she sign an arbitration agreement that would in effect cause her to give up her civil rights and the ability to complain to the Equal Employment Opportunity Commission (“EEOC”) or take the company to court. Plaintiff’s attorney notified the company on October 29, 2001 that she did not want to sign the agreement because of Michalek’s unwelcome sexual attention, unwelcome sexual conduct, sexual assault and because of the hostile work environment. On November 12, 2001, Costanzo placed plaintiff on twelve (12) weeks of unpaid leave. Michalek remains in a managerial position and has jurisdiction over everybody in the company. As a result, plaintiff remains fearful of returning to the company. On January 2, 2002, a psychiatrist advised her not to return. A more detailed explanation of the alleged facts is set forth infra where appropriate.
File:
Date:
Wednesday, September 10, 2003