Declaration of LaShondra Peebles in ‘Beverly, et al. v. Watson, et al.’

FYI The Fire published two things regarding the LaShondra Peebles' lawsuit see links below. Especially illuminating is the full text of Ms Peebles' declaration. This is a real insider's perspective on the workings of a political machine masquerading as a university.

http://www.thefire.org/ex-chicago-state-admin-i-was-pressured-to-file-false-harassment-claim-against-faculty-critic/

Peebles' declaration betrays the Watson administration's oft-spoken statement that "no one reads the blog..."

http://www.thefire.org/declaration-of-lashondra-peebles-in-beverly-et-al-v-watson-et-al/


Declaration of LaShondra Peebles in 'Beverly, et al. v. Watson, et al.'
By Fire March 19, 2015

Case: 1:14-cv-04970 Document #: 68 Filed: 03/19/15 Page 1 of 8 PageID #:547

DECLARATION OF LASHONDRA PEEBLES
I, LaShondra Peebles, declare as follows:

1. I was hired by Chicago State University (“CSU”) in March 2012 as a Process Improvement Specialist.

2. In July 2012, I became the Director of Compliance for Enrollment Management.

3. On July 1, 2013, I was promoted to Interim Vice President of Enrollment and Student Affairs. My duties were to manage and supervise eleven departments and a staff of approximately 130 employees in the areas of enrollment related services and student affairs. In this role I oversaw a budget of approximately $7,000,000. I was employed by CSU in this position until my termination on June 2, 2014.

4. On February 18, 2015, I filed a civil lawsuit in the Circuit Court of Cook County, Illinois, alleging that Chicago State University, the university’s President Wayne Watson, and the Board of Trustees of Chicago State University violated the Illinois State Officials and Employees Act, 5 ILCS 430/15-5 insofar as the termination of my employment constituted retaliatory action of my protected speech in violation of the Act. See Exhibit A.

5. My lawsuit alleges that while I was employed at CSU:
     a. I was asked to approve payments without signed contracts, and my statements to Watson that I would report any such conduct to the Illinois Auditor General constituted protected speech as defined by 5 ILCS 430-15-10(1);
     b. Watson prevented me from reporting CSU’s provisional status with the U.S. Department of Education regarding Title IV Federal Financial Aid for students to the Board of Trustees in violation of my protected speech as defined by 5 ILCS
     c. Watson and other CSU officials demanded that I make false claims of sexual harassment against Phillip Beverly as part of an effort to shut down the CSU Faculty Voice blog, and my refusal to do so constituted protected speech as defined by 5 ILCS 430/15-10(1).
     d. My protected speech was a motivating factor in my discharge.

CSU Faculty Voice

6. As a CSU employee, I was familiar with Professor Beverly because he and other CSU faculty members publish a blog titled CSU Faculty Voice. The blog discusses management by the CSU administration, and provides links to public documents regarding CSU. It contains information and opinions critical of CSU management and President Watson.

7. Watson referred to the “fight” that he was in against the CSU Faculty Voice, Beverly, and the blog’s contributors. Watson routinely had his assistants, Joy Hearn and Binta Chauncey, print copies of blog articles that angered him and distribute the copies to CSU officials. I heard many conversations among management critical of the blog.

8. Watson described Professor Beverly in my presence as a trouble-starter.

9. When I began my position as Interim Vice President of Enrollment and Student Affairs, Watson advised me that he wanted to be immediately informed if Professor Beverly spoke with me and that I was to report the substance of any conversations with Beverly to Watson.

10. From at least September 2013 through April 1, 2014, I was present during several conversations about Professor Beverly and the CSU Faculty Voice among CSU officials who discussed what actions they could take to remove Beverly from campus and shut down the blog. During that time, I was present during numerous meetings in which Watson, Patrick Cage, General Counsel and Vice President for Labor and Legal Affairs; Angela Henderson, Interim Provost and Senior Vice President for Academic Affairs; Hon. Bernetta Bush (Ret.), Ethics and Diversity Officer and Special Counsel to the President; Farah Muscadin, Director of Intergovernmental Affairs; Renee Mitchell, Director of Human Resources, and other CSU officials discussed ways to remove Beverly from the CSU faculty and shut down the blog.

Cease and Desist Letter

11. In November 2013, I attended a meeting in Henderson’s office along with Watson, Cage, Bush, and Mitchell to discuss sending Professor Beverly a letter to cease and desist from publishing the Faculty Voice blog. Henderson typed the letter and all attendees at the meeting were asked to assist in drafting the letter. The letter was conceived to shut down the CSU Faculty Voice blog and silence Beverly and other blog contributors who criticized Watson’s administration. I believe the letter was sent within one or two days of the meeting.

12. Attendees at the meeting offered various suggestions for what grounds could be asserted for shutting down the blog. Cage suggested that the letter assert that the name of the blog violated a registered CSU trademark. Watson said that even if the intellectual property claim did not “stick” he wanted the letter sent to Professor Beverly. Watson suggested that the letter reference CSU’s civility standard, as set forth in the Computer Usage Policy.

Cyber Bullying Policy

13. In November or December 2013, Henderson spoke with me and asked me to research examples of cyber-bullying policies at other universities. A meeting of CSU officials was convened to discuss adopting a cyber-bullying policy. I brought the sample policies that I researched from other schools to the meeting.

14. At the meeting, Watson, Cage, Henderson, Bush, and Muscadin discussed whether a cyber-bullying policy could be used at CSU to discipline Professor Beverly and shut down the Faculty Voice blog. The cyber-bullying policy was promoted by the CSU officials who attended as a response to the Faculty Voice blog and a means to close down the blog.

15. A draft CSU cyber-bullying policy was presented to the CSU Board of Trustees.

16. At the March 2014 CSU Board of Trustees meeting, the Board heard a “first reading” of the final proposed cyber-bullying policy, which was presented to the Board by Watson and Cage.

Sexual Harassment Allegation
17. In September 2013, Professor Beverly visited my office and asked to schedule an appointment with me to discuss CSU enrollment issues. I told him that no appointment would be necessary and offered to speak with him immediately in my office. We sat at my conference table and discussed CSU enrollment strategy and my professional qualifications to address CSU’s enrollment issues. Our conversation lasted ten to fifteen minutes. At the conclusion of our conversation, Beverly referenced his military experience and said that he had found it essential in life – as in the military – to have a “wing man” or someone to “watch your back.”

18. Per Watson’s request that I inform him if I had any contact with Professor Beverly, I immediately went to Watson’s office and reported my conversation with Beverly. Watson responded by characterizing Beverly’s parting words a “threat.” I responded that I did not feel threatened.

19. In a later conversation the same day in his office, Watson advised me that he needed to “protect” me and asked me if I felt threatened by Professor Beverly. I told him I did not feel threatened by Professor Beverly. Watson advised me that I should not talk further with Beverly and that Watson would “teach me” how to respond to Beverly in the future. The incident did not come up again until several months later.

20. In December 2013 I hired Monica Moss as Dean of Students. I passed along Watson’s instruction and told Moss to report to me if Professor Beverly spoke with her because Watson had said Beverly was out to “get him.”

21. In late January, Moss called to inform me that Professor Beverly had met with her and asked her questions about her professional experience and qualifications for her role as Dean of Students.

22. Complying with Watson’s standing instructions, I called Watson and informed him that Professor Beverly has spoken with Moss without discussing the content of the conversation. Watson responded by stating “that’s three,” claiming that Beverly had threatened and sexually harassed Angela Henderson, Moss, and myself. Watson stated that he needed the three of us to charge Beverly with sexual harassment. Watson said that he and the CSU administration were in a fight against Beverly and that he wanted to get rid of Beverly. Watson told me that he needed my help in the fight and advised me to file a lawsuit for sexual harassment against Beverly based on Beverly’s visit to my office. I told Watson that I did not feel threatened or harassed by Beverly’s conversation. Nevertheless, Watson asserted that I had been harassed and that I “did not realize it.”

23. I later spoke with Moss who informed me that she had been contacted by Watson and that Watson asked her to file sexual harassment charges against Professor Beverly. She resigned her employment February 28, 2014.

24. In early 2014, I was interviewed by Patrick Cage about my meeting with Professor Beverly. I was not advised about the subject of the meeting in advance. I described my conversation with Beverly and in response to his questions told Cage that I did not feel harassed or threatened by Beverly.

25. I was subsequently pressured by numerous CSU officials to file false sexual harassment charges against Professor Beverly. I was pressured in approximately ten different meetings with various CSU officials including Watson, Cage, Henderson, Bush, Muscadin, and Mitchell. The meetings would be initiated by a request via phone, in person, or via my assistant, Arlina Worrill, to participate in an ad hoc conference in an office or conference room without prior notice.

26. On another occasion, in early 2014, I was summoned to a meeting in Muscadin’s office, along with Watson, Cage, and Henderson, as well as Robin Hawkins, Assistant General Counsel and Tom Wogan, Director of Public Relations. I was again questioned about whether I was sexually harassed by Professor Beverly. When I denied any harassment, Watson to me that I was “too strong” and that he needed me to file the harassment lawsuit against Beverly so Watson could protect me. I reiterated that I did not feel threatened by Beverly and did not intend to sue Beverly. I stated that if I testified that Beverly harassed me, my testimony would be false.

27. In late February 2014, I received a text from Henderson to come to Watson’s home for a dinner meeting. At the meeting were CSU officials and others, including Watson; Bush; Muscadin; Hawkins, Cage; Angela Henderson and her husband Victor Henderson, Esq.

28. A discussion was held over several hours on how to get rid of Professor Beverly and shut down the CSU Faculty Voice. Attendees voiced their anger that blog contributors continued to post articles criticizing the administration without punishment.

29. Victor Henderson criticized Cage for not enforcing the cyber-bullying policy to get rid of Professor Beverly and blog contributors in light of recent blog reports suggesting that Angela Henderson had plagiarized her dissertation. Watson asserted that the administration had developed the policy to be used to shut down the blog and complained that no action had been taken against Beverly or any blog contributors via the policy yet.

30. There was also a discussion of filing a CSU lawsuit that would be used to obtain an injunction preventing publication of the blog.

31. The conversation then turned to whether or not CSU should file suit against Professor Beverly for sexual harassing me.

32. Angela Henderson said that she had agreed to file a sexual harassment complaint against Beverly.

33. Bush told me I was threatened by Professor Beverly and just did not realize it. I again stated that I did not feel harassed or threatened by Beverly’s conversation related to CSU administrative matters. I stated that would not falsely testify in support of such a complaint.

34. Bush offered to file a sexual harassment complaint if Moss and I refused.

35. The discussion became heated, with individuals telling me to file a claim against Professor Beverly. I was accused of not being a “team player.” I became distressed by the discussion and left the meeting.

36. In March 2014, I was interviewed once again regarding my conversation with Professor Beverly in a teleconference with Cage and lawyers who introduced themselves as attorneys retained by CSU to investigate the conduct of Beverly’s interaction with me and other CSU employees. I answered questions from the attorneys regarding my conversation in September 2013 with Beverly and stated again that Beverly had not sexually harassed me. The attorneys then questioned me regarding Moss's resignation and asked whether she had resigned because Beverly had harassed her. I told the attorneys that I did not believe Moss would state that she resigned because she felt harassed by Beverly.

37. I make the above statement based on my knowledge and recollection of events and if called as a witness would testify to the above facts.
                                                             
                                                                   LaShondra Peebles

VERIFICATION 

I, LaShondra Peebles, under penalties as provided by law pursuant to 735 L.L.C.S. 511-109 certify that the statements set forth in the foregoing Declaration are true and correct to the best of my knowledge and belief.
 
                                                                   LaShondra Peebles