Below are the factual allegations lifted verbatim out of the initial complaint filed by Celeste Bruno in the Monroe County Circuit Court against Monroe County. The case then was removed by Monroe County to the U.S. District Court, because part of the allegations concern violations of federal laws. The Complaint then was amended, dropping all but the first two counts. The factual allegations of misconduct by Sonny McCoy remained the same.
The alleged wrongdoing is set out in detail and minces no words. Because of the candor and detail, it’s hard for me to imagine the allegations are not true or mostly true. I cannot understand why Celeste only sued the County and left Sonny out of it. I also cannot understand why the County did not bring Sonny into the case as a third-party defendant, inasmuch as he is accused of misconduct that had nothing whatsoever to do with his duties and responsibilities as a county commmissioner and Mayor of Monroe County. Instead, the County seems to have protected Sonny at every turn, and in doing so has acted as if it has no exposure in this case. As the case now stands, if Celeste wins, Sonny gets off and Monroe County and its residents and taxpapers get tagged for everything.
I learned two days ago that the trial is set to begin this coming Monday at 1 p.m. in the Key West federal courthouse. I am working on something for the trial judge to consider.
Sloan
General Alleqations
9. The Mayor hired Bruno as his executive assistant February 9,
2005 following an interview during which he never asked about her
qualifications nor sought to see her resume, but commented, “Well, you’re
certainly pretty enough.”
10. The Mayor’s reputation at the time within Monroe County
government for inappropriately interacting with female employees was such
that when Bruno went to the county administrator’s office to complete the
paper work to accept the job, the county administrator’s administrative
assistant, Connie Cyr, stated that she had been approached to take the job,
but that she would not do so - “Not with his reputation” - and Debbie
Fredericks, then a Senior Administrative Assistant and subsequently Deputy
County Administrator, warned Bruno, ‘If he starts, you have to be really
stern.”
11. Although Bruno accepted the job, thinking that The Mayor could
not possibly behave as badly towards women as Cyr and Fredericks had
suggested, she immediately learned otherwise.
12. For example, The Mayor regularly told - and re-told - the
following stories, notwithstanding the fact that Bruno told him the first time
that either she did not need to hear such stories or that it was “more
information that I wanted,” and would tell him during beginning-to-end
encore recitations, “You’ve told me that this already. I don’t need to hear
this again”:
a. The Mayor had an older lover when he had studied in
Paris, France, who along with another woman treated The Mayor to a
menage a trois on the eve of his leaving, the frequency and intensity of the
sex that night being such that he suffered a “runny” penis and visited a
physician when he got back to the United States;
b. The Mayor - when he was in China on an architectural/
cultural trip with former President George H. W. Bush - had the sexual
services of a beautiful Chinese girl “Dah ling,” whose name he could
remember because it sounded just like “darling”;
c. The Mayor broke off an affair with a neighbor’s wife
because he had nightmares about looking up and seeing the man with a sad
look on his face as he watched The Mayor and his wife have sex;
d. When The Mayor made his, 90-mile, one-water-ski trip to
Cuba - a claim-to-fame he has memorialized with a wall of photographs in
his office - there were women on the ski boat whose sole function was to
“keep me up” by periodically appearing at the stern and removing an article
of clothing;
e. The Mayor developed an aversion to overweight women
while working as a cargo pilot when one such women initiated sex with him
after he had passed out drunk;
f. The Mayor officiated at a wedding as Key West mayor, and
then had sex with the bride after the groom got too drunk at the reception;
and
g. The Mayor had sex with Cuban prostitutes when doing
architectural work in Cuba.
13. Following virtually every one of the tellings (or re-tellings) of one
of these stories, The Mayor approached Bruno and said, essentially, “You’ll
tell me if I say something that bothers you, right?,” to which Bruno
inevitably responded, ‘I always have told you that I did not want to hear
your stories and I will keep on telling you,” to which The Mayor would
inevitably reply ‘I joke around more with you than with Kathy [Peters, his
former executive assistant], because you can take it.”
14. The stories and the subsequent exchange occurred virtually daily
throughout Bruno’s employment as The Mayor’s executive assistant.
15. The Mayor after four or five months escalated the unwelcome
sexual advances by asking Bruno on several occasions if she were attracted
to him. When she told him that his inquiry was inappropriate and refused to
answer it, he told her that he was attracted to her and asked again why she
would not answer his question.
16. The Mayor’s other sexually inappropriate remarks included, but
were not limited to, the following:
a, summoning Bruno from her desk to his office merely to tell
her, “You’re cute”;
b. frequently staring at her buttocks and commenting with a
mock Spanish accent, “Que fondillo!” - which translates to “nice bottom”;
c. telling her, as she stood next to where he was sitting
reviewing a document she had typed, ‘I want to slap your behind”;
d. asking her on another occasion what color underwear she
had on;
e. inquiring about her sex life with her husband;
f. telling her - after he returned from a visit to a urologist,
who, he shared, had “put his finger up my buttr’ - that it was amazing how
a man his age could have such a high semen count;
g. talking about how ‘Women shouldn’t have worries - it
ruins their looks.”
17. The Mayor affected inappropriately sexual body language with
Bruno, including learning over her desk, getting close to her and rubbing his
chest through his unbuttoned shirt - after ordering her to arrange the
furniture, including a printer and a scanner, in such a way as to allow him
easier access to the area behind Bruno’s desk than he had enjoyed after his
former assistant, Peters, arranged the furniture to effectively barricade
herself from him.
18. The Mayor also attempted to force upon Bruno inappropriately
large (and unwelcome) gifts. For example, he:
a. ordered her a refrigerator to be put on his bill when hers
broke - which she called and cancelled;
b. offered to have a friend paint her house - which she
declined; and
c. instructed his daughter to order Bruno an MP3 player -
which Bruno rejected by calling The Mayor’s daughter to stop the order.
19. The attempted giving of unwelcome gifts to Bruno was perceived
by Bruno at worst as a thinly disguised and unsuccessful attempt to get her
to prostitute herself or, at best, a “peace offering” indicating his
understanding of how offensive and troubling his sexually explicit conduct
was to her. Additionally, the attempted gift-giving was The Mayor’s modus
operandi, as demonstrated by the way he also treated his immediately
previous assistant, Kathy Peters:
a. whom he got onto a list for affordable housing at a
condominium of which he was the architect;
b. whose $200,000 mortgage he attempted to guarantee;
and
c. for whom he ordered a full set of dishes that Peters left
behind in the office when she transferred to the County Attorney’s office.
20. Following the receipt March 3, 2005 of an anonymous letter
suggesting that Peters had left The Mayor’s employ because she felt sexually
harassed, The Mayor told Bruno daily that “I don’t know what I did to her,”
that ‘I just tried to help her,” and that Peters had been “very emotional” and
would cry in the office.
21. The Mayor repeatedly told Bruno that he could not have sexually
harassed Peters - whom he called “my little Conch girl,” a reference to
natives of the Florida Keys, and whose sexual history he detailed to Bruno
without Bruno’s inquiring or inviting him to do so - because he had never
touched her.
22. Following Bruno’s repeated rejections of The Mayor’s advances,
The Mayor became hostile towards her, e.g.:
a. demeaning her work;
b. asking her repeatedly if she knew what various “big” words
(e.g., “tautologist”) meant and demanding that she tell him;
c. displaying anger when the office received an e-mail from
the Tourist Development Council and Chamber of Commerce congratulating
“whoever wrote” a letter to the governor about windstorm insurance that
Bruno had written but that had gone out over The Mayor’s signature;
d. refusing to listen to anything that she had to say about
windstorm insurance, even though Monroe County’s state representative had
suggested in a phone conference with The Mayor and Bruno that The Mayor
let Bruno brief him on the issue because The Mayor needed to know
something about it;
e. flying into a screaming rage at Bruno because she had
stapled a landscape-format attachment to a portrait-format letter differently
than The Mayor had thought it should be stapled; and
f. laughing at Bruno’s work product in front of County
Attorney Suzanne Hutton and telling her “You’re cute” as Bruno attempted
to present to him and explain a letter she had drafted about windstorm
insurance.
23. Bruno walked out of The Mayor’s office after the incident
described in 7 22(f), refusing to return.
24. She used vacation time and worked in the office of the County
Administrator for a while, seeking other employment with Monroe County.
25. The Mayor’s actions towards Bruno:
a. were based:
i. on Bruno’s gender; or
ii. on Bruno’s having opposed The Mayor’s unwelcome
sexual advances and constant, uninvited discussion of sexual matters by
repeatedly refusing those advances and telling him that she did not want to
hear those kinds of stories;
b. were so serious or pervasive as to permeate Bruno’s
workplace to the point that it altered the terms and conditions of her
employment by requiring her to work in a discriminatorily hostile or abusive
environment;
c, would have offended any reasonable woman;
d. did offend Bruno - to the point that it caused her to seek
professional help for the anxiety and depression The Mayor’s behavior
caused;
e. as to the actions more specifically alleged in 1 22, were the
type of actions that could well dissuade a reasonable worker from opposing
The Mayor’s sexual advances and sexual comments.
f. were, upon information and belief, similar to his actions
towards former assistants, which actions were known to Monroe County
officials to the extent that Tom Wille, the county administrator, told Bruno
when she said that she no longer wished to work for The Mayor that he was
surprised that she had lasted as long as she did in The Mayor’s office and
Debbie Fredericks, the deputy county administrator, asked “Was it hands or
words?,” adding, “We warned you.”
26. Monroe County at all times material failed to exercise reasonable
care to prevent and correct promptly any sexually harassing behavior by The
Mayor in that it:
a. knew of The Mayor’s sexual harassment of other women,
but had done nothing to stop it or to counsel The Mayor about repeating it;
b. had in place a sexual harassment policy that only forbade
harassment or retaliation by employees up through the level of division
director and department head, but did not forbid either harassment or
retaliation by members of the Board of County Commissioners; and
c, provided sexual harassment training to employees, but not
to members of the Board of County Commissioners.
27. Immediately upon leaving The Mayor’s employ, Bruno began
seeking treatment for depression and anxiety.
28. Soon thereafter, Bruno went to work as an assistant to
Commissioner Spehar, whose office was in the same Key West complex as
The Mayor’s.
29. Bruno’s job with Spehar paid 4 per cent less than her position as
executive assistant to the mayor pursuant to General Policy 4.13 of the
Monroe County Personnel Policies and Procedures.
30. Notwithstanding general knowledge of the popularity of The
Mayor - a third-generation “Conch” and former five-term mayor of the City
of Key West prior to being elected to the County Commission - Monroe
County leaked to the press on or about November 10, 2006 word that the
EEOC had notified Monroe County October 17 of Bruno’s sexual-harassment
and retaliation Charge of Discrimination.
31. Following the news leak and the ensuing November 11 coverage,
Milo John Reese, a mentally ill ex-convict, visited Spehar’s office November
13 to leave a handwritten note reading:
Sonny,
Regarding the person who says you harassed, I called my attorney.
She went on her computer. She’s got something on this guy. Cellest
(sic) Higgins, # 305-536-6900.
Thanks,
John Reese
32. Commissioner Spehar, meanwhile, told Bruno several times
subsequent to the news leak that the sentiment she was encountering
whenever she went to an official meeting was that, ‘We’ve got to protect
Sonny.”
33. Reese returned to Bruno’s office November 16, identifying
himself as a friend of The Mayor’s who wanted to help him with Bruno’s
complaint, at which point Bruno telephoned County Attorney Suzanne
Hutton and Bob Shillinger, an assistant county attorney, who spoke with
Reese after Bruno left the room.
34. When Bruno returned, Hutton and Shillinger told Bruno that each
desk had a panic button and told her that were Reese to return, she could
push it and sheriff’s deputies from the nearby courthouse would rush over.
35. Reese the following day left another note, this one on the back
of a blank restaurant check: “Perjury = 3 years in jail. How do you like me
now. Have a nice day. John Reese, FBI.”
36. City of Key West Police Department officers issued trespass
warnings to Reese November 17 for both Commissioner Spehar’s office and
Bruno’s home.
37. Reese nonetheless returned to Commissioner Spehar’s office
November 30, telling Bruno - who told Reese to leave as she pushed the
panic button and dialed 911 - that “I go next door to Sonny’s all the time
and he never told me I couldn’t come here.”
38. While the City of Key West police arrived in response to the 911
call, taking Reese into custody for trespass after warning, no sheriff’s deputy
responded to the panic button.
39. Bruno, fearing that Monroe County could not protect her, left
work that day and went to her psychotherapist, Marilyn E. Berner, a licensed
clinical social worker, who advised her not to return to work - as Spehar’s
assistant or in any capacity - because of the overwhelming fear Bruno had
developed concerning Monroe County’s failure to protect her.
40. Monroe County shortly thereafter terminated Bruno for job
abandonment.