Obviously, I have a great fear of making this formal complaint while I am still employed as an Assistant Prosecuting Attorney. This does not mean that assistants, division chiefs and others in management or Human Resources were unaware of this harassment. Mr. Allen's conduct toward me was so conspicuous that a significant number of employees were well aware of this harassment.

Mr. Allen engaged in numerous acts of unwelcome physical and verbal advances toward me. His actions and comments created a hostile work environment for me and other female employees. I will attempt to depict here the sexual harassment I have suffered over the past several years at Mr. Allen's hands, but note that no such correspondence could comprehensively reflect each instance of harassment.

I began working for the office in June 1999 as an intern prior to my completion of law school and appointment as a full-time assistant prosecutor with the Office of the Hamilton County Prosecuting Attorney. On or about June 21, 1999, during the course of my employment with the office as an intern, Mr. Allen contacted me and asked me to go to lunch; I agreed to go to lunch with him and went to the Plaza 600 restaurant in Cincinnati a few days later. At the lunch Mr. Allen asked me if I wanted to be a judge and said that most of the judges come from the prosecutor's office, and that I 'should stick around.' Mr. Allen began to tell me a story about his military service in the Judge Advocate General's office, then stopped and said, 'Well, that's a story I'll have to tell you over a beer sometime.' Mr. Allen subsequently admitted to me in the context of our eventual relationship that he had tried at this luncheon to make me laugh so he could look at my breasts and that he was glad I didn't 'catch' him looking.

In early December 1999, shortly after both my grandfather and father had died, Mr. Allen telephoned me and insisted on coming to see me at my apartment, and on December 16, 1999, Mr. Allen came to my apartment, was under the influence of alcohol, made sexual overtures to me, and refused to leave until I had intercourse with him. From that point forward, Mr. Allen used his significant power and authority by virtue of his office, political influence, and superior age, experience, and economic advantage to insist upon and maintain a sexual relationship with me. From that point on to the present, Mr. Allen has used his disparate power and economic influence over me to obtain and/or attempt to obtain sexual favors and companionship from me, and withheld promotional and other employment benefits and opportunities from me. It can be clearly demonstrated that Mr. Allen sent me numerous letters, gifts, food, flowers, cards, and candy at the office as well as at my residence. From December 1999 through January 2004, Mr. Allen would frequently summon me to his office for the purpose of engaging in sexual intercourse.

From December 1999 through the present, Mr. Allen repeatedly made unannounced unsolicited visits to my office, to the point that I would sit in my office with my door closed and locked. For more than four years, Mr. Allen has made numerous unsolicited phone calls to my office phone, my home phone, and my cellular phone, to the point that I would no longer answer. Mr. Allen has thwarted me in my career path by discouraging me from taking other positions, and interfering in the offering of other positions to me. For example, in January 2003 I was told by Thomas Longano, First Assistant Prosecuting Attorney, that I could advance directly to the Municipal Division or Common Pleas Division from my position in the Appellate Division. Because I was interested in the opportunity and excited about the fact that I was apparently being permitted to 'skip' Juvenile Division, the normal next step, I informed Mr. Allen of the opportunity. Mr. Allen was concerned that he would be seen as favoring me, and thus blocked this promotion and forced me to accept a position in the Juvenile Division.

In April 2004, Mr. Allen forced me to accept a position in the Civil Division instead of the Municipal Division, the usual next step for my career path, because of his fear that his wife, a Municipal Court judge, would discover our relationship. Mr. Allen has entered my residence numerous times without my knowledge or consent, causing me to feel afraid in my own apartment, such that I had my locks changed in order to maintain some semblance of safety and security. Mr. Allen coerced me to maintain my office on the 7th floor after my move to the Civil Division; because of this, I have been physically ostracized from my co-workers and have been deprived of the benefits of working closely with more experience attorneys. I am the only litigation attorney in the Civil Division on the 7th floor.

In 2004, after I terminated the relationship with Mr. Allen, he mouthed the words 'I love you' to me as he passed me in the 7th floor back hallway, causing me extreme anxiety, discomfort and distress. Subsequently, on another occasion, Mr. Allen kissed me without my consent or invitation on the west stairwell landing between the 7th and 8th floors, and I immediately chastised him. In April 2004, during the time period in which Mr. Allen was coercing me to accept a lesser position, he repeatedly urged me to come up to his office to 'talk,' reminding me that he had gotten me 'out of juvenile (prosecutor's division).'

When I came to Mr. Allen's office as he directed, he began to fondle me and attempted to become intimate with me, urging me to expose my breasts to him, at which point he masturbated in front of me. Mr. Allen's conduct has deprived me of an equitable salary, bonuses, and promotional opportunities on account of my sex and in retaliation for my rejection of his sexual advances and unwillingness to continue in the affair with him. Mr. Allen's policies and practices as described above have deprived me of equal employment opportunities, and I am now being deprived of income in the form of wages and of prospective retirement benefits, and other fringe benefits due me, solely because of my sex and rejection of his sexual advances.

It is noted that Mr. Allen has the reputation of being an extremely intimidating person with vindictive tendencies, and neither the Hamilton County Prosecuting Attorney's office or and other county official has offered any real protection for me or other relief from harassment while I have been employed there.

Since I have terminated my relationship with Mr., Allen, I have been forced to divert my career path from an appointment to the Municipal Division of the office, and take a lesser position in the Civil Division. Also, my compensation and promotional opportunities have been negatively affected since I have terminated the relationship with Mr. Allen, leading to the inescapable conclusion that sexual favors were clearly a term and condition of my employment. In addition, I also have suffered retaliation because of Mr. Allen's deceptive attempts to mischaracterize and/or conceal his relationship with me from his wife, Lisa Allen, a judge in the Hamilton County Municipal Court.