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Whatever relevance such evidence may have to prove other elements of plaintiff's case, it does not have anything to do with the issues presented by the president's and Ferguson's motions for summary judgment. I.e., whether plaintiff herself was the victim of alleged quid pro quo or a hostile work environment, sexual harassment, whether the president and Ferguson conspired to deprive her of her civil rights, or whether she suffered emotional distress so severe in nature that no reasonable person could be expected to endure it.

Charles Ruff
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