NKLER eae BROWN = March 7,2012 PRIVILEGED/CONFIDES ‘Mr. Dorsey E. Hopson Il, General Counsel > Memphis City Schools £2597 Avery Avenue, Room 115 ‘Memphis, Tennessee 38112 Re: Tiffany Crutchfield Investigation Our File No. 21451,51968 Dear Mr. Hopson: On February 23, 2012, Glankler Brow, PLLC was engaged to assist in an investigation lnderiaken im response to 2 complaint of sexual harassment made by Tiffany Cratehfcld Gsereinafor refered a9 “Ms, Cruichfcld") ou Felauwry 21, 2012, 10 Dr Krinet cash Ihe Superintendent for Memphis City Schools (*MCS", ith copies of the complaint also sent to you and Cerita Butler the Interim Executive Director of Human Resouces for MCS." In the ‘omespandence, Ms. Crutchfield alleged that Dr. ving Hamer, the Deputy Superintendent of ‘Academic Operations, Technology & Innovation for MCS, sexually harassed her by making “several ingppropriate, vulgar and degrading comments to” her in the preseace of MCS employees.” "We were asked to investigate the veracity of Ms, Crutehfeld’s complaint and to determine what, if wny, actions should be taken in response to Ms. Crutchfield's complaint. In investigating this mater, we interviewed Ms. Crutchfield, Dr. Cash, and a numberof other MCS employees, and reviewed certin documents submitted by these individuels. "We also attempted to interview Dr, lrving Hamer, bt were unable to do so prior tothe completion ofthis epor., 1. INTERVIEWS A. Tiffany Crutchfield, On February 23, 2012, the undersigned met with Ms, Crutchfield at the offices of Glankler Brown. Ms. Crutchfield was hired by MCS in August 2006 as an Executive Secretary in MCS" Communications Department. Approximately one and one-half years afer she was hired by MCS, she was promoted to the position of Program and Project Specialist in the "Sen Ms. Crue's Feroary 21, 212, comespenencs to Dr. Cish tached hereto 88 EAB “A." Although the complain is ted Fehr 21,2012, Dr. Cash did vot sey reseive Ms. Cruhfes compat ane February 23,2012, Seo iie“A”‘March 7, 2012 Page 2 Privileged/Confidenti Communications Department. In June 2008, Ms. Crutchfield was promoted to the position of Executive Assistant to the Superintendent In her role as Executive Assistant 10. the Superintendent, Ms. Crutchfield reports diteetly to Dr. Kriner Cash and is responsible for ‘managing Dr. Cash's calendar, school visits, speaking engagements, travel, presentations, and sending tothe day-to-day needs of Dr, Cash took place at Dr. According to Ms, Crutchfield, she was invited to attend a gathering Cash’ residence on Febny 18,2012 De. Cah invited is Exe satbering as wel as his administrative stall Ms. Crutceld char gathering. “Near the end of the evert, Dr. Hamer began making renwsti ty al attendance regarding the work feng’ MCS employes asthe elby County Schools moves close to fition. Ms, Crutchfield was stadng be ‘MCS employees when Dr, Hamer looked in her direction and remarked to Willie ie Spates Regional Superintendent —“are you having a side bar with Ms. feng, din‘t you how she's mated, T Hoow he gt sone gs, bt ses mari Ma Chl sted hat secon i attendance seemed shocked by Dr, Hamer’s commeat“Cafetiae Bail the Northeast Regional Superintendent attempted to get Dr. Hamer ith his speech but Dr. Hamer vace satin made a coment sbost Mi Crile tym is dearer ioe Sa aes ther fois eamments “Ss ‘Ms, Crutchfield wes evenly directed byl eutside of Dr. Hamers line of vision ssl De Hamer completed his eases Accorng to Ms: Crueheld De Hanes eees ‘er eva uniting erasing Je emt ctu shrly a De as ‘made his comments. Sa» % ty ge (On Sunday ot Sz. Ma. Exucheldrescvd a elphone cll om De. Cs, checking on her cos “as lvised Ms, Crutchfield that Dr. Hamer owed an epology to Ms, Crutches enyone cle in atendace, for his remarks sbout Ms Catch, ©n Monday Febnity,20)2012, Ma. Creed recived un email tat wat teat fats De 112, Rime S S wes snp n stein een iG esnas in Sy Dy an snes fas ml veel cae Se Han Crutcield* De stated tat he only explanation for his) bebavor wes [is] ‘sa tesupize Wire we ner, wha we wee dpe ho was in enous red teal familar Sith (Ms) Crutchfield) and our colleagues” Ms. Crichfild avsed that she wes offended by this tomment bectse any “falar” with Ms, Cuthfeld Is tinied to Work dle for snd at MCS. “Ms. Crutefeld also stated tht she believes this eommoat may Tend oers to think that Dr. Hamer had a reason to make the aforementioned remarks about Ms. Crutchfield, » Seer. Hamers Feirary 21,2012, esnall to Ms. Crh ached ert ws Ah “B, “See Buea * See Benita”‘March 7, 2012 Page 3 Privileged/Confidential Ms. Crutchlield advised thot while she is at work, she has litle contact with Dr, Hamer. 2; Hamers office is down allay trom Dr. Cass ofie, and Ms, Crtchfeld typically ony communioetes with Dr. Hamer's assistant. Ms, Crutchfield estimatcs that she ceoemnicac, With De, Hamer ae svetly work-related. Ms. Cratheld sated tht she and Dr Hea tone never had a personal or romenti relationship. Ms. Crtehield cone tin he ps she “~ Ms. Cruchfld sivisd that De. Haters comments at Dr. Gs residence and Dr arse’ subsequent plogy have cused Ma. Crashed ga etaansesvand it, (On Monday, February 20, 2012, Ms. Cred ws peed Up De igh ke tine oto Gare wth this uation. Ms, Crutchiel bles that De imer sould eczve seine toon ot Ginn for ls acon, Ms Cruel ao request sve eae soiaceee ‘with Dt. Hamer going foseed, ee oy, ‘On February 24, 2012, the under ae telephonic interview of Dr. Kriner Gash, Dr. Cash isthe Superintendent of MCS! has betn employed in that postion cone 2008. Tiny Chute hs beet one OE DELCasy exosve taste of ony brwiming of Ds. Cash's tenure with MCS. When Dr Cx wasted by MCS os Supeisenden he hired Dr Iving Hamer ws a his Deplly Supcnindent. "Dr Cash bad enhecay ‘worked with Dr: Hamer whe oth vite eiloyed by the Mant-Dade Sahoo! Sys! % De; Cash advised ut heed hi ecutive Cabinet es well as his administrative staff Sa cece om Surety 18, 201, allah work dey Hea Oa MCS employers wei liviied'tg itéad the event. Dr. Hamer prepared the main dich for te, Set and theteneeversilgued to bing ecole beverages fo he cv The ev should las in 720.po, 19 9:0 pan. De Cash chamtrzed the event ara ayes {ype aster ns itwabone Ofte fist socal events he had atended wih he Eeenttie oer IIe assed ay alate 2011 B. Dr: Kriner Cash, : sifu De. Hamer was making his ost, Dr. Cash recalled Dr. Hamer reftrenciag Ms, De enti’ breasts on atleast two (2) occasions. Dz. Cash commented that he atemped oor Dr. Hamer to stay on point with his toast. After Dr. Hamer made the comuvente toswe Toe