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HE 1.

  1. The wrong section in the Faculty Handbook is cited for Charge 4 quoted above in the Notification of Charges. The section cited, Section 2.9.2(b) of the KSU Faculty Handbook governing “Faculty Responsibilities,” states, “[Faculty members] shall respect the rights of all campus members to free and orderly expression.” HE 2, p. 2 - 38. The correct section for Charge 4 is Section 2.9.2(c) of the KSU Faculty Handbook, which states, “[Faculty members] shall act with propriety in all dealings with members of the University community.” HE 2, p. 2 - 38. The language of the correct section is actually what is quoted in the Notification of Charges.
  2. When Mr. Haskins returned to his office after his encounter with Dr. Stokes at her classroom on October 19, 2015, Dr. Stokes called him on the phone and told him he “didn’t have her back,” and if he returned to her class with the students, that she would “call the police and have you removed.” HE 6; and 1 HR 1:51 and 2:10.
  3. In her testimony, Dr. Stokes claimed she did not know Assistant Director Haskins by sight, implying she did not realize she was speaking to a KSU administration individual. 2 HR 1:40:30. First, he is the same individual with whom Dr. Stokes had exchanged emails on October 12, 2015, about the “classroom safety incident” involving MS. See HE 7. And regardless of whether or not she immediately recognized him when he looked into her classroom, she admitted on cross examination that she went into the hall with him whereupon he identified himself. 2 HR 2:16. Thus, she obviously knew he was a KSU administration official when she called him on the phone.

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