Then, on April 29, 2016, the Petitioner's counsel wrote a letter to KSU's General Counsel stating, "Dr. Stokes denies each and every allegation contained in paragraphs 1, 2, 3, and 4 of the April 25, 2016 [charging] letter." The Petitioner's April 29, 2016, letter asks for documentation supporting the charges, but it does not affirmatively state that the Petitioner claims back pay to the date KSU stopped paying the Petitioner.

On September 16, 2016, KSU suspended Dr. Stokes without pay and removed her from the roster of faculty who taught classes at KSU.3 2 HR 1:59:30.

During some of the time period covered by the charges, the Division of Literature, Language, and Philosophy did not have a chairperson. During this interim, Dr. Stokes reported to Dr. Lorna Shaw, KSU Dean and Associate Provost for Academic Affairs.

On October 12, 2016, the Petitioner filed a Complaint with the Franklin Circuit Court, case number 16-CI-01086, against Kentucky State University; Dr. Aaron Thompson, Interim President of KSU, in his individual and official capacity; the Board of Regents of KSU; and all of the Board members in their individual and official capacities. The Complaint states that the Petitioner has not been afforded a hearing. The Petitioner also states she has not been paid since the time she was suspended without pay, and that she is due compensatory damages, although the amount and basis for this claim are not stated in the Complaint.

On March 8, 2017, before the Franklin Circuit Court issued any ruling in the case, the Petitioner's counsel filed with the court a Motion to Hold Case in Abeyance Pending Hearing. In an appearance before the court on March 8, 2017, counsel for KSU stated that KSU agreed the suit should be stayed pending a resolution by the Board. The Franklin Circuit Court