WINFIELD -- A Putnam County woman says she was a victim of sexual harassment and gender discrimination while working for American Electric Power.

In Rebecca Chadwick's complaint, filed June 12 in Putnam Circuit Court, she also says she was subjected to a hostile work environment and that she was terminated from the job for reporting an on-the-job injury to Workers' Comp and in retaliation for reporting "pervasive and severe sexual harassment."

In her suit, Chadwick says she was hired in an EOJ position in the operations division of AEP. She says she was hired directly by Sun Tech, an AEP subsidiary. After some internal reorganization, she was later assigned to Kelly Services and later to Express Services. All of those companies also are listed as defendants in her suit.

While with Sun Tech, Chadwick says she was "subjected to unwelcome sexual remarks from defendant Daniel Smith. These remarks included, but were not limited to, references to a 'bet' regarding who would get to 'f--k' the plaintiff first and comments making reference to plaintiff's breasts as 'the twins.'

"Plaintiff was also subjected to constant attacks for being 'a woman in a man's job' and repeatedly questioned as to whether she was sleeping with superiors to advance her career."

Through the reorganizations, Chadwick says Smith remained her supervisor.

And, his "pervasive sexual remarks and discriminatory statements toward women continued."

Chadwick says she was "deeply offended and embarrassed" by Smith's remarks, so she reported them to Keith Drake, his supervisor, as well as other AEP supervisors. Still, she says Smith's conduct continued until the end of her employment.

Chadwick goes on to allege that the defendants "failed to report a known on-the-job injury suffered by the plaintiff to the West Virginia Workers' Compensation Division."

"Furthermore, it was made very clear to the plaintiff that she was not to report this injury either."

Chadwick says she was forced to rely on personal health insurance to pay for medical expenses incurred from her work-related injury.

In June 2004, she told her supervisor that she needed to have an MRI for the injury. And she said she was fired two days later.

"Plaintiff was not informed whether her termination was a result of her request for medical treatment as a result of her on-the-job injury or whether it was due to her reporting the pervasive and outrageous sexual harassment and discrimination that she was subjected to on a daily basis by defendant Daniel Smith," claims Chadwick, who is represented by attorneys Matthew S. Criswell and Todd A. Twyman.

In addition to the charges of sexual harassment and gender discrimination -- both violations of the West Virginia Human Rights Act -- as well as the hostile work environment and retaliatory discharge, Chadwick also says she was not paid all wages due. She also says she was a victim of severe emotional distress.

She seeks compensatory and punitive damages, as well as permanent injunction against the defendants and another injunction ordering them to establish ongoing training regarding sexual harassment and discrimination. She also seeks to have the Court enjoin Smith from using his position to sexually harassment and discriminate against women by compelling his employer to fire him.

She seeks back pay, including benefits, and compensatory damages for severe emotional and mental distress, humiliation, anxiety, embarrassment, depression, aggravation, annoyance and inconvenience.

Chadwick also seeks compensatory damages for out-of-pocket losses, punitive damages, pre- and post-judgment interest, court costs, attorney fees and other relief.

She requests a jury trial. The case has been assigned to Circuit Judge Ed Eagloski.

Putnam Circuit Court case number: 06-C-197

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