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Case 1:12-cv-02521-ELH
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Filed 08/23/12
RIMINATrON
CHARGE OF
is afreeted. by Ih!\
Document 1-2
Page 1 of 2
CHARGE NUMBER
_GENCY
Act 0/1974; See Privacy Act Statement bt'l/Ofe oompleting . (his form,
DFEPA
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EEOC
Maryland Commission on Human RelaUons
Slate
NAME(fndlcllitl Mr..
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and
u«, Mrs.}
HOME rELEPHONE
(Includo Area Code)
(410) 827-7271
Krlsty Lynn Murphy
DATEOF BIRTH
CITY, STATE AND ZIP CODE
STREET ADDRESS
Queenstown, MD 21658
2512 Bennett Point Road
03/19/1977
NAMED IS THE EMPLOYER. LABOR ORGANIZATION, EMPLOYMENT AGENCY, APPRENTICESHIP
AGENCY WHO DISCRIMINATeD AGAINST ME (If more than one lls! below.)
NAME
COMMITTeE, STATE OR LOCAL GOVERNMENT
TELEPHONE (Include
Area Code)
NUMBER OF EMPLOYEES. MEMBERS
Queen Anne's County; John P.
Borders, Jr., County Administrator.
eeoc
local Agency. if ally
(410) 758-4098
Over 500
Queen Anne's Co. Office of the
Sheriff
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STREET ADDRESS
101 N. Uberty
CITY, STATE AND. ZIP CODE
st.
Centreville, MD 21617
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code)
STREET ADDRESS
CITY, STATE AND ZIP CODE
queen Anne's
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DRACE
RETALlATfO
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COLOR
NATIONAL
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SEX
e'SABILlT
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RELIGION'
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COUNTY
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DATE DISCRIMINATION TOOK
PLACEEARLIEST
CAUSEOF DISCRIMINATION BASED ON (Check appropriate box(es))
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COUNTY
TELEPHONE NUMBER (,Jnq{utje Area
NAME
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AGE
OTHER (Specify)
June 2005 & Continuing.
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THE PARTICULARS ARE (If additions' paper Is neoded, allach ex(ra shoal($)):
I. I am a 32-year-old female. On July 23. 1999. I began working for the Queen Anne's County Ottlca of the Sheriff in the
Patrol Division. In December 19991 graduated from the police academy. In December 2000 I was awarded Deputy of the
Year.
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advise Ihe agencies if I change my address or telephone number and I will cooperate fully
with tnem In the p/oce8sfng of my charge In accordance with their procedures.
I declare under penalty of perjury that Ihe foregoIng ISlrue and correct.
I swear Of affirm I at I have read the above charge and that it
Is true to tho best of my knowledge, Informatton and bellet.
SIGNATURE OF COMPLAINANT
SUBSCRIBED AND SWORN TO BEfORE ME THIS DATE
(Day, mOilln. ;11\11Y~'I)
ChargIng Party (S~naluro\/ItM..Ivr.n.('/ /
Case 1:12-cv-02521-ELH
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Document 1-2 Filed 08/23/12
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Krlsty Murphy
2. In June 2005 1was permanently assigned to the Cr/mlnallnvestigations DivisIon (CID). Captain Curtis Benton attended the
servIce of my f1r~tsearch warrant and saId "This 15the first search warrant a female has ever written and will probably be
the last. 'I During this time our office was trying to obtain a raise and allowance (or new patrol cars (rom the County
CommissIoners. Capt. Benton told me that "I should weer« bikini and attend the Commissioner's meeting so we could get
the raise and allowance.
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3. First Complaint of Sex Harassment: Following Capt. Benton's comment, in September 20051 went to HUman
Resources artd complained to HR Tina Miles regarding Capt. Benton. She said she would speak with the County Administrator
but later told me that since the Captain's position was an appointed position. there was nothIng that could be done.
.
'4. In November 2006 Sergeant Gary Hofmann was elected as the Sheriff In Queen Anne's County. His brother, J.D. "Dennis"
Hofmann was assigned to the CID as a Corporal. Cpl. Dennis Hofmann started coming Into my office when Iwas preparing (0
leave for the day. As I would stand to leave, he would block me and try to touch my breasts, I would push hlm'sway and
turn away with my back to him. When he would fInally let me leave, he would walk and than stop so I would run Into the
back of him, ThIs progressed and he started shuttIng my office door as he entered. He would try to touch my breasts
under my clothing and say, IILet me see them." Iwould tell hIm Its top. No, open the door!"
6. On March 19,2007, which Is my birthday. Cpl Hofmann gave me a sexually suggestive birthday card that says IIWorklng on
your birthday? Sometimes It must be done", which doesn't mean you stili can't find a way to have some funl" As you
open the card, InsIde It says IIPSSSout pnotocopie« of your behind. Moon the boss. Add vodka to the water cooler."
6. On June 24 to 28. 2007. Cpt. Hofmann and I went to Sex Offenders Training In San Diego, CA. On the night of tho 26th, In
the glass -enctosea hotel elevator, he sexually assaulted by groping me and tried to kIss me and touch me. When we
reached my floor, he followed me off tho elevator and pushed hla way Into my room. He thr6w me down on the bed, got
on top of me and sexually assaulted me, kissIng me and touching my breasts and privates. I used my entire body,
IncludIng my legs, to push him off. I screamed at him, tellfng him to leave.
7. Second ComplaInt of Sex Harassment: In July 2007 I went to Sheriff Hofmann and complained to him about his
brother and my supervisor (Dennis Hofmann) sexually assaulting me. He asked me who I had told and I said "my mother and
my boyfriend, Donnie." He said "lf you tel/anyone else, J will have to do somothlng about It. In October 2007, Opl Dennis
Hofmann was promoted to Sergeant.
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8. On August 25, 2009, Sgt. Hofmann and I had court In Cecil County. En route back from court. while driving hIs department
vehlct», he reached over wIth hIs right hand and tried to put It down the front of my pants. He kept trying to put hIs right
hand Ins/de my blouse and touch my right bres:tt: I kept telling him to stop and pushing hIs hand away. After several
attempts he touched my rIght breast and then said he wanted to (eel the other one. He then tried to touch my left breast.
I told him to stapf I finally told him that I was not feeling well and hIs hands were cold. He stopped trying to touch me.
9. On November 1 to 8, 2009. Detective Amelia Lopez and I attended training at a fingerprint lab In Raleigh. NC. On November 2
In the morning, Det. Lopez was on her cell phone and I could hear a male voice. I heard her say JlFuck you!" and she closed
nor cell phone endIng the conversation. She looked at me and said, "that was Stouffor.[Detectlv6 Stephen Stouffer] He
just asked me" we licked each Qther's pussies last nIght. JI
10. DUring training. Det. Lopez and I were given 1\•••0 sealed boxes contaInIng ffee fingerprint items (rom the Instructor. When we
returned from our Iralnlng, I brought the boxes lnto the CID office. As I took the items out of the box, Lt. Dale Patrick said "I .
guess I need to call up to class and find out whloh one of my deputies was the biggest tramp to get all this stu","
11. Third Complaint of Sex Harassment: On November 18, 2009 Captain James Williams came to me and asked me
about rumors of sexual harassment. / told him about the comment that Lt. Patrick had made, how he had grabbed my thIgh
and stated, "Thet'« firm" and a/so about th9 comments Det, Stouffer msde to Det. Lopez. Cap!. WiUlams asked me what I
wanted done with Lt. Patrick. He said "Thls /s the tlrstttm» this has ever happened. JI The next day I met with the HR Director
Beverly Churchill and capt. Williams. I told Ms. Churchill about the sexual comment made by Lt. Patrick and how he would hug
me and mek« grunting sounds as well as grabbing my thIgh. I told both of them that someone else had sexually harassed
me as well. but I did not feel comfortable dIscussing It and that I was scared. At the end of the meeting. Capt. Williams ordered
me to put the harassment on paper.
12. On November 20, 2009 I placed my written sexual harassment complaint in Capt. Williams' mailbox. I also sent him an emall
nqu(rlng about the Investigation of the comments made by oet. Stouffer and U. Patrick. I never heard anything further regarding
his (nvesl/galion. I later received an email that Oat. Stouffer and Sgt. Hofmann had been promoted.
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