Kalamazoo Public Schools Answer To Sexual Harassment Complaint

Case 1:16-cv-01382-RJJ-RSK ECF No. 14 filed 05/09/17 PageID.
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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
ALICIA CURRY, Case No.: 1:16-cv-01382
Plaintiff, Honorable Robert J. Jonker
v.
KALAMAZOO PUBLIC SCHOOL

SYSTEM and RODNEY PREWITT,
in his individual and official capacity,
Defendants.
____________________________/
Ben M. Gonek (P43716) Craig R. Noland (P30717)

GONEK LAW Amanda M. Zdarsky (P81443)
Attorneys for Plaintiff McGRAW MORRIS P.C.
500 Griswold Street, Ste 2450 Attorneys for Defendants
Detroit, MI 48226 300 Ottawa Avenue, N.W., Suite 820
(313) 963-3377/Fax (313) 963-9310 Grand Rapids, MI 49503
ben@goneklaw.com (616) 288-3700/Fax (616) 214-7712
cnoland@mcgrawmorris.com
azdarsky@mcgrawmorris.com
Joel B. Sklar (P38338)
LAW OFFICES OF JOEL B. SKLAR
Attorneys for Plaintiff
500 Griswold Street, Ste 2450
Detroit, MI 48226
(313) 963-4529
joel@joelbsklarlaw.com
DEFENDANTS, KALAMAZOO PUBLIC SCHOOLS AND RODNEY PREWITT,

ANSWER TO PLAINTIFFS FIRST AMENDED COMPLAINT
AND AFFIRMATIVE DEFENSES
NOW COME DEFENDANTS, Kalamazoo Public Schools (Referenced in the First
Amended Complaint as KPSS) and Rodney Prewitt, by and through their attorneys, McGraw
Morris, P.C. and in response to Plaintiffs First Amended Complaint states as follows:
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Case 1:16-cv-01382-RJJ-RSK ECF No. 14 filed 05/09/17 PageID.87 Page 2 of 20
1. This is an action to enforce civil rights arising out of Plaintiffs employment relationship
with Defendants and to vindicate Plaintiffs federally guaranteed First Amendment rights
to free speech pursuant to 42 USC 1983.
ANSWER: Defendants deny that they violated any of Plaintiffs constitutional
rights, or any rights under state or federal law.
2. Plaintiff Alicia Curry conducts business in Kalamazoo County, Michigan, which is
located in this District.
ANSWER: Defendants admit that Plaintiff is currently employed by the
Kalamazoo Public Schools.
3. Defendant Kalamazoo Public School System (KPSS) conducts business in Kalamazoo
County, Michigan which is located in this District.
ANSWER: Admitted.
4. Defendant Rodney Prewitt conducts business in Kalamazoo County, Michigan which is
located in this District. Defendant Prewitt is being sued in his individual and official
capacity.
ANSWER: Admitted.
5. At the time alleged in the Complaint, the actions of Defendants were intentional, illegal
and unconstitutional and constitute an intentional tort. As such no Defendant is entitled
to defense of governmental immunity.
ANSWER: The allegations are denied as untrue.
6. Plaintiffs First Amendment rights to free speech were clearly established and the
individual Defendants violation of her First Amendment rights was clearly unreasonable.
2
ANSWER: Defendants deny that they violated any of Plaintiffs First
Amendment rights.
7. Plaintiff has exhausted her administrative remedies and, received her right to sue letter
from the Equal Employment Opportunity Commission on or about April 18, 2017.
ANSWER: Defendants deny that Plaintiff has initiated or exhausted
administrative remedies concerning at least some of the claims set forth in the First
Amended Complaint.
8. The events giving rise to this action all took place in this District.
ANSWER: Defendants deny allegations as to events alleged in the First
Amended Complaint, as separately set forth in their responses.
9. This Court has subject matter jurisdiction over this matter pursuant to 28 USC 1331
and 28 USC 1337(a).
ANSWER: The allegations constitute legal conclusions of which no answer is
required. As set forth in the Affirmative Defenses, Defendants deny that the Court has
subject matter jurisdiction over at least some of the claims set forth in the First
Amended Complaint.
10. The amount in controversy exceeds the jurisdictional limit of this Court, exclusive of
costs, attorneys fees and interest.
ANSWER: The allegation contained in paragraph 10 of Plaintiffs First Amended
Complaint is neither admitted nor denied for the reason these Defendants are without
sufficient information to form a belief as to the truth thereof and therefore leaves the
Plaintiff to her strictest proofs.
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COMMON FACTS
11. Plaintiff is a certified school administrator, licensed professional counselor and licensed
school counselor.
12. In 2001, Plaintiff obtained a Bachelor of Arts degree in Psychology and Organizational
Studies from the University of Michigan.
13. In 2005, Plaintiff obtained a Master of Science degree in Professional Counseling from
Georgia State University and, in December of 2011, received a Master of Arts degree in
Educational Leadership from Western Michigan University.
14. On August 27, 2007, Plaintiff was hired by KPSS as School Counselor at Loy Norrix
High School.
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ANSWER: Defendants admit that Plaintiff was hired by Kalamazoo Public
Schools.
15. Plaintiff worked at Loy Norrix High School for nine (9) years and, due to her exemplary
performance, served in various positions including 1st Aspiring Administrators
Academy, Counselor Department Head, Mentor Teacher, Assistant Track and Cross-
Country Coach and Nova Net Instructor.
ANSWER: Defendants admit that Plaintiff is currently employed by Kalamazoo
Public Schools, and that her various employment positions are reflected in her
employment records. Allegations to the contrary are denied as untrue.
16. On or about July 1, 2013, Defendant KPSS hired Rodney Prewitt as the Principal of Loy
Norrix High School.
ANSWER: Admitted.
17. When Defendant KPSS hired Defendant Prewitt, they knew that he had been disciplined
by the State of Florida Educational Practices Commission for engaging in a pattern of
sexual harassment of female teachers and staff at his school. Respondent would ask the
individuals for sex, invite them to come over and do him and otherwise made
inappropriate and unprofessional sexual comments to female staff and teachers even after
he had been informed that the comments were not welcome. (Final Order, Exhibit A).
18. In or about the time that Prewitt assumed his position as Principal, he continued his
pattern of unlawful behavior documented by the State of Florida.
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19. In July of 2013, Defendant Prewitt sent Plaintiff a text message in which he stated I
know you want me.
ANSWER: The allegation is denied as untrue.
20. For a brief period of time, Plaintiff and Prewitt dated.
ANSWER: It is admitted there was a consensual relationship, and allegations to
the contrary are denied as untrue.
21. In or about December of 2013, Plaintiff told Defendant Prewitt that she had no romantic
interest in him.
22. After Plaintiff told Prewitt that she had no romantic interest in him, Defendant Prewitt
told Plaintiff that he had power in the School District and that his position was secure
because of his relationship with the Human Resources Director and Superintendent.
23. Despite Plaintiffs protestations, Defendant Prewitt continued to make unwelcome sexual
advances to Plaintiff, including commenting on her clothes, hair and appearance and
asking Plaintiff if she was romantically involved with someone new.
24. Plaintiff ignored defendant Prewitts advances in the hope that they would stop. They did
not.
25. On another occasion, Defendant Prewitt handed Plaintiff a post-it note with her best
friends address and phone number and stated that he was going to pursue Plaintiffs best
friend because he was under the impression that Plaintiff was courting someone else.
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26. This frightened and intimidated Plaintiff because her friend lived in Georgia and she had
no idea how Defendant Prewitt had obtained her phone number.
27. Afterward, Defendant Prewitt continued to make unwelcome sexual remarks and
advances, including I know you want me to go down (a suggestion of oral sex) and
lingering in Plaintiffs office. This also intimidated and frightened Plaintiff.
28. In January of 2014, after ignoring his advances, Plaintiff was removed from her position
as Nova Net instructor despite the fact that Plaintiffs position was already approved by
the Director of Secondary Education.
ANSWER: The allegations are denied as untrue. In further response, Plaintiff
did not have the requisite teacher certification, and she was not otherwise needed to fill
that position.
29. In February of 2014, Plaintiff learned from her immediate supervisor that his secretary
had complained that Prewitt had sexually harassed his secretary. This increased
Plaintiffs discomfort with Prewitts sexually predatory conduct.
30. In or about March of 2014, Plaintiff noticed that Defendant Prewitt was singling Plaintiff
for undeserved criticism in front of her colleagues. Plaintiff learned from other KPSS
employees that Mr. Prewitt dont like you for some reason.
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31. In or about May, 2014, Plaintiff met with Defendant Prewitt and informed him that she
found his conduct inappropriate, that he work environment was hostile and oppressive
and that she wanted it to stop.
ANSWER: The allegations are denied as untrue. In further response, Plaintiff
met with Mr. Prewitt and asked why he no longer talked to her like in the past. Mr.
Prewitt responded that he did not know what she was talking about.
32. Defendant Prewitt told Plaintiff I dont know what youre talking about and terminated
the meeting.
ANSWER: The allegations are denied as phrased. See response to No. 31 above.
33. After this meeting, Prewitt frequently belittled Plaintiff and singled her out for criticism
front (sic) of other employees in order to humiliate and punish her for objecting to his
sexual advances.
34. In June of 2015, Plaintiff applied for the Assistant Principal/Dean of Students position at
Loy Norrix High School.
ANSWER: Defendants admit that an application was made.
35. Plaintiff did not receive the promotion to the position of Assistant Principal/Dean of
Students despite the fact that she was more qualified than the person who received the
position.
36. Plaintiff was also more qualitied than the person who was appointed to the position of
Assistant Principal.
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37. Defendant Prewitt was on the interview panel for the Assistant Principal position.
ANSWER: The allegations are denied as phrased. In further response, it is
admitted that Mr. Prewitt was on the interview committee, which consisted of nine
members. Five candidates applied for the position. Each committee member
independently prepared a rating sheet for each candidate. Each member of the
committee rated another candidate as more qualified, and the Superintendent adopted
the committees recommendation. None of the other committee members, or the
Superintendent, were aware of Mr. Prewitts involvement with Plaintiff, and Mr.
Prewitts involvement had no bearing on the ultimate decision.
38. In August 2015, Plaintiff spoke with KPSSs Superintendent about what he was looking
for in an Assistant principal after she did not receive the promotion and was told that,
among other things, he relied heavily on the recommendation of the Principal, Defendant
Prewitt.
39. On or about August 26, 2015, Plaintiff submitted a formal complaint to KPSS Human
Resources Director, Sheila Dorsey Smith, about Defendant Prewitts unlawful conduct
what she believed to be sexual harassment and the create of a hostile work environment
based on sex.
ANSWER: It is admitted that a complaint was made, and that the complaint was
fully investigated. In further response, Defendants deny conduct constituting sexual
harassment, and deny that Defendants created a hostile work environment based on
sex.
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40. Defendant Prewitts conduct continued and became so difficult, pervasive and oppressive
that Plaintiff transferred to another school after nine years at Loy Norrix High School.
41. After Plaintiff submitted her formal complaint, at least one other female employee came
forward to report that Defendant Prewitt has sexually harassed her.
42. On March 28, 2016, despite Defendant Prewitts previous conduct and additional
complaints of unlawful conduct, Defendant KPSS advised Plaintiff that it had found no
wrong-doing and that this was a case of he-said-she-said.
ANSWER: The allegations are denied as untrue and incomplete. In further
response, at the conclusion of the investigation, Plaintiff was provided a letter dated
March 6, 206, summarizing the results of the investigation. Allegations to the contrary
are untrue.
43. Since Plaintiff filed her formal complaint, she has been denied promotion and career
advancement opportunities.
ANSWER: Defendants deny that Plaintiff was denied promotion and career
advancement opportunities as a result of making any complaints.
44. In May of 2016 and again on June of 2016, Plaintiff applied for the position of Assistant
Athletic Director at Kalamazoo Central High School.
ANSWER: Defendants admit that Plaintiff applied for the position of Assistant
Athletic Director at Kalamazoo Central High School.
45. Despite the fact that Plaintiff was the most qualified for the position, a male counsel for
from one of KPSSs middle schools received the job.
10
ANSWER: Defendants admit that a decision was made to select Mr. Moore to
serve as the Assistant Athletic Director, and otherwise deny that Plaintiff was the most
qualified candidate.
46. Plaintiff applied for the position of Assistant Principal/Dean of Students for Kalamazoo
Central High School.
ANSWER: Admitted.
47. Plaintiff was the most qualified for the position but did not receive the position.
48. Instead, two less qualified persons were hired for the job(s) that Plaintiff had applied for.
COUNT I:
VIOLATION OF MICHIGANS ELLIOTT-LARSEN CIVIL
RIGHTS ACT-SEXUAL HARASSMENT/CREATION OF A
SEXUALLY HOSTILE ENVIRONMENT
49. Plaintiff restates each of the above paragraphs for sentence and word for word.
ANSWER: Defendants incorporate by reference their prior responses.
50. Plaintiff was a member of a protected class for purposes of the Elliott-Larsen Civil Rights
Act (ELCRA), being MCL 37.2101, et seq.
ANSWER: Admitted.
51. Defendant KPSS is an employer covered by the ELCRA, being MCL 37.2201, et. seq.
ANSWER: Admitted.
52. Defendant Prewitt is an employer covered by the ELCRA.
53. Plaintiff was subjected to unwelcome sexual advances by Defendant Prewitt as set forth
above based on her sex.
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54. Plaintiff was subjected to unwelcome sexual conduct or communication.
55. The unwelcome sexual conduct or communication was intended to or did in fact
substantially interfere with Plaintiffs employment or created an intimidating, hostile or
offensive work environment.
56. Plaintiffs submission to Defendant Prewitts unwelcome sexual advances was an express
or implied condition for receiving job benefits or that the employees refusal to submit to
Prewitts sexual demands resulted in a tangible job detriment.
57. Defendant KPSS hired Defendant Prewitt knowing that he had a propensity to sexually
harass female employees and create a sexually hostile environment but took no measures
to protect its female employees from Defendant Prewitts predatory actions.
58. Defendant KPSS is responsible for Defendant Prewitts unlawful conduct under the
doctrines of respondeat superior/vicarious liability.
ANSWER: The allegations, including allegations of unlawful conduct, are denied
as untrue.
59. Defendants acts were intentional.
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60. Defendants discrimination of Plaintiff based on sex and sexual harassment of Plaintiff,
including quid pro quo harassment and creation of a sexually hostile environment, is a
violation of the ELCRA.
61. As a direct and proximate result of Defendants unlawful actions against Plaintiff as
described herein, Plaintiff has suffered, and will continue to suffer, injuries and damages,
including, but not limited to, lost earnings, loss of earning capacity, loss of career
opportunities, loss of reputation and esteem in the community, mental and emotional
distress, embarrassment, humiliation, fear, anxiety, outrage and loss of the ordinary
pleasures of life.
COUNT II:
RETALIATION IN VIOLATION OF THE ELCRA
62. Plaintiff restates each of the paragraphs set forth above word for word.
63. Plaintiffs complaints to Defendants about the violation of her civil rights is protected
activity under the ELCRA. MCL 37.2701.
required. Defendant deny any violation of civil rights.
64. Defendants retaliated against Plaintiff by among other things, creating a hostile work
environment, depriving her of career opportunities and promotions to positions for which
she applied and was qualified.
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65. Defendants actions were intentional and taken with reckless indifference to Plaintiffs
rights and sensibilities.
66. As a direct and proximate result of Defendants unlawful actions against Plaintiff as
described herein, Plaintiff has suffered, and will continue to suffer, injuries and damages,
including, but not limited to, lost earnings, loss of earning capacity, loss of career
opportunities, loss of reputation and esteem in the community, mental and emotional
distress, embarrassment, humiliation, fear, anxiety, outrage and loss of the ordinary
pleasures of life.
COUNT III:
VIOLATION OF TITLE VII-SEXUAL HARASSMENT AND
CREATION OF A HOSTILE WORK ENVIRONMENT
66(sic). Plaintiff restates the above paragraphs word for word.
67. Plaintiff is a person covered under Title VII of the civil Rights Act of 1964 since
amended, 42 USC 2000e et. seq.
ANSWER: The allegation constitutes a legal conclusion of which no answer is
required.
66(sic).Defendant KPSS is an employer covered under Title VII of the Civil Rights act, 42
USC 2000e et. seq.
required.
67. Defendant Prewitt was Plaintiffs boss and supervisor.
14
ANSWER: At all material times, Defendant Prewitt was the Principal of Loy
Norrix High School. In his role as supervisor, he had general supervisory
responsibilities over school employees and staff. He was not Plaintiffs immediate
supervisor. Allegations to the contrary are denied as untrue.
68. Plaintiff is a member of a protected class.
required.
69. Plaintiff was subjected to unwelcome sexual harassment.
70. The harassment to which Plaintiff was subjected was based on sex and is described
above.
71. The harassment unreasonably interfered with her work performance by creating a hostile,
offensive, or intimidating work environment for which Defendant KPSS is responsible.
72. Plaintiffs submission to the unwelcomed advances was an express or implied condition
for receiving job benefits and the rejection of Defendant Prewitts sexual demands
resulted in a tangible job detriment.
73. Defendant KPSS is liable for Defendant Prewitts unlawful conduct under respondeat
superior.
ANSWER: The allegation of unlawful conduct is denied as untrue.
15
74. Defendants actions were intentional, with reckless indifference to Plaintiffs rights and
sensibilities.
75. If Plaintiff had been a male, she would not have been treated in the manner described.
ANSWER: Defendants deny the allegations concerning the alleged treatment, and
otherwise deny all remaining allegations.
76. Defendant KPSSs discrimination of Plaintiff based on sex and sexual harassment of
Plaintiff, including quid pro quo sexual harassment and creation of a sexually hostile
environment, is a violation of Title VII.
77. As a direct and proximate result of Defendant KPSSs wrongful acts and omission,
Plaintiff has sustained loss of earnings, earning capacity, and fringe benefits and has
suffered mental anguish, physical and emotional distress, humiliation, outrage,
depression, anger, confusion, fear and embarrassment, and loss of professional
reputation.
ANSWER : The allegations are denied as untrue.
COUNT II (sic)
RETALIATION IN VIOLATION OF TITLE VII
78. Plaintiff restates the above paragraphs word for word.
ANSWER: Defendants incorporate their prior responses.
79. Plaintiff engaged in protected activity under Title VII when she complained that her civil
rights were being violated by Defendants.
required.
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80. After Plaintiff engaged in protected activity she was subject to adverse retaliatory
treatment by Defendant KPSS, including the creation of a retaliatory hostile environment
and depriving Plaintiff of career opportunities and promotions to jobs for which she
applied and was qualified.
81. A causal connection exists between Plaintiffs protected activity and the adverse
employment actions set forth herein.
82. As a direct and proximate result of Defendant KPSSs wrongful acts and omission,
Plaintiff has sustained loss of earnings, earning capacity, and fringe benefits and has
suffered mental anguish, physical and emotional distress, humiliation, outrage,
depression, anger, confusion, fear and embarrassment, and loss of professional
reputation.
COUNT IV
VIOLATION OF PLAINTIFFS FIRST AMENDMENT FREE SPEECH RIGHTS
PURSUANT TO 42 USC 1983
83. Plaintiff restates each of the above paragraphs word for word.
84. Plaintiff complained to Defendants concerning the unlawful discrimination and civil
rights violations described above.
ANSWER: Defendants admit that Plaintiff made a complaint which was fully
investigated. In further response, Defendants deny the allegations of unlawful
discrimination or any civil rights violations.
17
85. Plaintiffs complaints and reports of unlawful conduct constitute protected activity under
the Free Speech Clause of the First Amendment to the US Constitution.
ANSWER: Defendants deny unlawful conduct, and further deny the allegations
as untrue.
86. Defendant Prewitts and KPSSs adverse actions as described above caused Plaintiff to
suffer an injury that would likely chill a person of ordinary firmness from continuing to
engage in that activity.
87. The adverse actions described above were motivated at least in part as a response to
Plaintiffs exercise of her constitutional rights.
88. Plaintiffs complaints of Defendants violation of her civil rights touch on a matter of
substantial public concern.
89. Plaintiffs interest in commenting on matters of public concern outweigh the interest of
the State, as an employer, in promoting the efficiency of the public services it performs
through its employees.
90. As a direct and proximate result of KPSSs wrongful acts and omission, Plaintiff has
sustained loss of earnings, earning capacity, and fringe benefits and has suffered mental
anguish, physical and emotional distress, humiliation, outrage, depression, anger,
confusion, fear and embarrassment, and loss of professional reputation.
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WHEREFORE, Defendants each respectfully request that this Honorable Court enter an
Order dismissing Plaintiffs Complaint, and taxing all costs and fees, including attorney fees,
against Plaintiff. 42 U.S.C. 1988(b).
McGRAW MORRIS, P.C.

Attorneys for Defendants
Dated: May 9, 2017 BY: /s/ Craig. R. Noland

Craig R. Noland (P30717)
AFFIRMATIVE DEFENSES
NOW COME Defendants by and through their attorneys, McGraw Morris P.C., and
hereby affirmatively state as follows:
1. Plaintiffs Complaint fails to state a cause of action against either of the Defendants.
2. Plaintiffs Complaint fails to state a municipal liability claim, and Count IV against
Kalamazoo Public Schools should be dismissed.
3. Plaintiffs claims are barred in full or in part by the applicable statute of limitations.
MCL 600.5805(10).
4. Any allegations brought under Title VII falling outside the 300 day statute of limitations,
if any, should be dismissed. 42 U.S.C. Section 2000e-5(e)(1).
5. The Court does not have subject matter jurisdiction over any Title VII claims that were
not included in Plaintiffs Charge of Discrimination.
6. With respect to any Title VII or Section 1983 claims, if Plaintiff establishes that
gender/sex/protected conduct was a motivating factor underpinning the Defendants
alleged adverse actions, cause existed for Defendants actions and Defendants would
have taken the same actions regardless of Plaintiffs gender/sex/protected conduct.
7. Plaintiff unreasonable failed to take advantage of preventative or corrective opportunities

provided by Defendant to avoid harm and Defendant exercised reasonable care to prevent
and correct promptly any allegations of harassing or discriminatory behavior. Burlington
Indus., Inc. v. Ellerth, 524 U.S. 742 (1998).
8. The Complaint allegations brought against Defendant Prewitt in his official capacity are
redundant to claims brought against Defendant Kalamazoo Public Schools, and should be
dismissed.
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9. Plaintiffs Complaint against Defendant Prewitt in his individual capacity fails to state a
cause of action in avoidance of qualified immunity, or otherwise. Such claims are
otherwise barred by qualified immunity.
10. Plaintiffs state law claims against Defendants are barred by governmental immunity.
MCL 691.1407, et seq.
11. The substance of the allegations set forth in Counts I and II, despite their labels, reflect a
failed effort to assert tort claims in avoidance of governmental immunity, or otherwise.
All state law claims are strictly barred by governmental immunity. MCL 691.1407.
12. Plaintiffs allegations of injury or damages were caused by Plaintiffs failure to exercise
reasonable care in failing to timely notify Kalamazoo Public Schools of any alleged
inappropriate conduct. The failure to provide timely notification constitutes a failure to
mitigate alleged damages.
13. Plaintiff has otherwise failed to mitigate her alleged damages.
14. Defendants request the opportunity to supplement or amend their Affirmative Defenses
as warranted during pretrial discovery.
WHEREFORE, Defendants each respectfully request that this Honorable Court enter an
Order dismissing Plaintiffs Complaint, and taxing all costs and fees, including attorney fees,
against Plaintiff. 42 U.S.C. 1988(b).
McGRAW MORRIS, P.C.

Attorneys for Defendants
Dated: May 9, 2017 BY: /s/ Craig R. Noland

Craig R. Noland (P30717)
Amanda M. Zdarsky (P81443)
300 Ottawa Avenue, N.W., Ste. 820
Grand Rapids, MI 49503
Direct: (616) 288-3702
cnoland@mcgrawmorris.com
azdarsky@mcgrawmorris.com
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Case 1:16-cv-01382-RJJ-RSK ECF No. 14 filed 05/09/17 PageID.

UNITED STATES DISTRICT COURT

ALICIA CURRY, Case No.: 1:16-cv-01382

Plaintiff, Honorable Robert J. Jonker

KALAMAZOO PUBLIC SCHOOL

Ben M. Gonek (P43716) Craig R. Noland (P30717)

DEFENDANTS, KALAMAZOO PUBLIC SCHOOLS AND RODNEY PREWITT,

NOW COME DEFENDANTS, Kalamazoo Public Schools (Referenced in the First

to free speech pursuant to 42 USC 1983.

ANSWER: Defendants deny that they violated any of Plaintiffs constitutional

rights, or any rights under state or federal law.

2. Plaintiff Alicia Curry conducts business in Kalamazoo County, Michigan, which is

located in this District.

ANSWER: Defendants admit that Plaintiff is currently employed by the

Kalamazoo Public Schools.

3. Defendant Kalamazoo Public School System (KPSS) conducts business in Kalamazoo

County, Michigan which is located in this District.

4. Defendant Rodney Prewitt conducts business in Kalamazoo County, Michigan which is

and unconstitutional and constitute an intentional tort. As such no Defendant is entitled

to defense of governmental immunity.

ANSWER: The allegations are denied as untrue.

ANSWER: Defendants deny that they violated any of Plaintiffs First

ANSWER: Defendants deny that Plaintiff has initiated or exhausted

ANSWER: Defendants deny allegations as to events alleged in the First

Amended Complaint, as separately set forth in their responses.

and 28 USC 1337(a).

ANSWER: The allegations constitute legal conclusions of which no answer is

costs, attorneys fees and interest.

ANSWER: The allegation contained in paragraph 10 of Plaintiffs First Amended

Plaintiff to her strictest proofs.

ANSWER: The allegation contained in paragraph 11 of Plaintiffs First Amended

Plaintiff to her strictest proofs.

Studies from the University of Michigan.

ANSWER: The allegation contained in paragraph 12 of Plaintiffs First Amended

Plaintiff to her strictest proofs.

Educational Leadership from Western Michigan University.

ANSWER: The allegation contained in paragraph 13 of Plaintiffs First Amended

Plaintiff to her strictest proofs.

ANSWER: Defendants admit that Plaintiff was hired by Kalamazoo Public

performance, served in various positions including 1st Aspiring Administrators

Country Coach and Nova Net Instructor.

ANSWER: Defendants admit that Plaintiff is currently employed by Kalamazoo

employment records. Allegations to the contrary are denied as untrue.

Norrix High School.

by the State of Florida Educational Practices Commission for engaging in a pattern of

ANSWER: The allegations are denied as untrue.

pattern of unlawful behavior documented by the State of Florida.

ANSWER: The allegations are denied as untrue.

know you want me.

ANSWER: The allegation is denied as untrue.

20. For a brief period of time, Plaintiff and Prewitt dated.

ANSWER: It is admitted there was a consensual relationship, and allegations to

the contrary are denied as untrue.

ANSWER: The allegation is denied as untrue.

ANSWER: The allegations are denied as untrue.

asking Plaintiff if she was romantically involved with someone new.

ANSWER: The allegations are denied as untrue.

ANSWER: The allegations are denied as untrue.

ANSWER: The allegations are denied as untrue.

no idea how Defendant Prewitt had obtained her phone number.

ANSWER: The allegations are denied as untrue.

lingering in Plaintiffs office. This also intimidated and frightened Plaintiff.

ANSWER: The allegations are denied as untrue.