Lawsuit Against Kent Johnson

Case: 3:23-cv-01910-JJH Doc #: 16 Filed: 05/30/24 1 of 121.
PageID #: 208
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
WESTERN DIVISION
REBEKAH HUSKEY
1483 East Lockwood Road
Port Clinton, Ohio 43452
Plaintiff,
v.
CITY OF PORT CLINTON, OHIO Case No. 3:23-cv-01910
c/o Dina Shenker
Director of Law Judge Jeffrey J. Helmick
1868 E. Perry Street
Port Clinton, OH 43452 Magistrate Judge Darrell Clay
and
KENT JOHNSON
423 Adams Street
Port Clinton, Ohio 43452
Defendants.
PLAINTIFF REBEKAH HUSKEY’S SECOND AMENDED AND SUPPLEMENTAL COMPLAINT

WITH JURY DEMAND
The predator wants your silence. It feeds their power, entitlement, and they want it to feed your shame.
–Viola Davis
Predators prey on gentleness, peace, calmness, sweetness, and any positivity that they sniff out as weakness.
Anything that is happy and at peace they mistake for weakness. It’s not your job to change these people, but it’s
your job to show them that your peace and gentleness do not equate to weakness.
–C. Joybell C
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Case: 3:23-cv-01910-JJH Doc #: 16 Filed: 05/30/24 2 of 121. PageID #: 209
NATURE OF THE ACTION
1. At relevant times, Defendant Kent Johnson was Defendant City of Port Clinton’s fire chief.
He became sexually obsessed and infatuated with Plaintiff Rebekah Huskey, a firefighter and EMT
half his age who had known him since she was seven years old and viewed him as a second dad. His
perversion manifested itself in filthy sexual comments, ogling, stalking, groping, intrusions into her
privacy, and sexual assaults.
2. This is an action against Johnson and the City for unconstitutional sex discrimination,
including sexual harassment and assaults, violating the substantive-due-process and equal-protection
clauses of Fourteenth Amendment to the United States Constitution, Title VII of the Civil Rights
Act of 1964, and the Ohio Civil Rights Act, codified in Ohio Rev. Code § 4112.02. Johnson, a final
municipal decisionmaker and policymaker, committed these acts. Because Johnson was the City of
Port Clinton’s fire chief, Defendant City of Port Clinton is liable.
3. Defendants are also liable for Johnson’s violations of 15 U.S.C. § 6851—disclosures
(transfers) of intimate images of Plaintiff Rebekah Huskey without her consent. They are liable
under both under that statute and under 42 U.S.C. § 1983 for federal statutory violations under color
of law.
4. This suit also alleges state-law civil liability for many criminal acts under Ohio Rev. Code
§ 2307.60, including the crimes of
• assault (§ 2903.13(A)),
• kidnapping (§ 2905.01(A)(4)),
• abduction (§ 2905.02),
• unlawful restraint (§ 2905.03),
• gross sexual imposition (§ 2907.05(A)(1)),
• sexual imposition (§ 2907.06),
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• menacing by stalking (§ 2903.211(A)),
• telecommunications harassment (§ 2917.21),
• unauthorized use of property — computer, cable, or telecommunication property
(§ 2913.04),
• interference with civil and statutory rights (§ 2921.45),
• dereliction of duty (§ 2921.44(E)),
• falsification (§ 2921.13),
• tampering with records (§ 2913.42), and
• workers’ compensation fraud (§ 2913.48).
5. And this suit alleges various Ohio state-law torts including common-law assault, battery,
false imprisonment, wrongful invasion of privacy, and intentional infliction of emotional distress,
and destruction of public records.
6. From at least as early as October 2022 through May 2023, in a continuing scheme,
Defendant Johnson serially harassed and assaulted Plaintiff Rebekah Huskey at their workplace, via
telecommunications, and in her home. He obtained illicit access to and stole private intimate images
of her for his own perverted ogling and use.
PARTIES
7. Plaintiff Rebekah Huskey resides in Ottawa County, Ohio. She was a firefighter and
emergency medical technician (EMT) for the City of Port Clinton fire department. Defendant
Johnson later reassigned her, contrary to her desires, to serve as his personal secretary.
8. Defendant Kent Johnson works and resides in Ottawa County, Ohio. He was, until about
January 18, 2024, the fire chief for the City of Port Clinton, Ohio. As fire chief, Johnson was a final
decisionmaker when it came to fire-department personnel decisions, including Huskey’s job
reassignment, discussed below.
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9. Ohio Rev. Code § 737.09 provides, “(t)he chief of the fire department shall have exclusive
control of the stationing and transferring of all firemen and other officers and employees in the
department under such general rules and regulations as the director of public safety prescribes.”
Port Clinton Fire Chief Kent Johnson, age 65
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JURISDICTION AND VENUE
10. This Court has subject-matter jurisdiction under 28 U.S.C. §§ 1331, 1343, and 2201 for
federal claims under 42 U.S.C. §§ 1983 and 1988, 15 U.S.C. § 6851, and the Civil Rights Act of 1964
(42 U.S.C. § 2000e-2(a)(1) and 42 U.S.C. § 1981a and 42 U.S.C. § 2000e). Title 42 U.S.C. § 1988 and
42 U.S.C. § 2000e-5(k) provide for recovery of prevailing civil-rights plaintiffs’ attorney and expert
fees.
11. This Court has supplemental jurisdiction over the state-law claims under 28 U.S.C. § 1367.
12. This Court has personal jurisdiction over Defendants, who reside in and conduct business in
this District.
13. Venue is proper under 28 U.S.C. § 1391, because the events giving rise to the claims took
place within this District.
FACTUAL BACKGROUND
Fire Chief Kent Johnson’s indifference to sexual harassment.
14. Plaintiff Rebekah Huskey is a 32-year-old woman who began working for the City of Port
Clinton fire department in 2006, first as a volunteer at least at age 16. Johnson is a 65-year-old man
who, besides being the longtime fire chief, was a friend of the Huskey family. Ms. Huskey has
known Johnson since she was seven years old. At relevant times, her father, sister, and fiancé all
worked for the fire department, too. Her fiancé still does.
15. Ms. Huskey thought of Johnson as a second dad or uncle, and his family like her aunts and
cousins. Johnson often referred to her as his “sweet, beautiful, special Emma,” referring to his own
granddaughter. And she often called him “dad.”
16. From the beginning of Ms. Huskey’s employment with the Port Clinton’s fire department,
Chief Johnson expressed his indifference towards sexual harassment in the department. Once, he
told Ms. Huskey that she was “going to get sexually harassed,” and that she needed to “pick and
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choose what [she] reported” because he didn’t “want issues with [his] department.” The entire
department adopted this attitude towards sexual harassment.
Chief Johnson grabs Ms. Huskey’s buttocks while she’s pregnant, makes a crude comment
about her breasts.
17. When Ms. Huskey was visibly pregnant in about July 2021, she was pouring herself a cup of
coffee in the office when Johnson came behind her and forcefully grabbed her butt-cheek.
18. He then left.
19. His unwanted groping shocked her.
20. Also, while she was pregnant, Chief Johnson lauded her breasts with, “Your tits look great,”
coupled with references to her soon-to-be born son, whose name he knew: “Matty is going to be a
lucky boy!”
Chief Johnson insists Ms. Huskey return early to work after her pregnancy—when he
harassed her with degrading sexual comments and assaulted her more.
21. While she was pregnant, Johnson forced Ms. Huskey to take leave early, even when she was
able to work. This forced her to exhaust about four weeks of various forms of leave unnecessarily.
22. Under the City of Port Clinton’s policy, Ms. Huskey was not required to return to work until
12 weeks postpartum. In handling her maternity leave, Chief Johnson insisted she rely on him alone,
demanding that she discuss nothing with Port Clinton’s deputy auditor, Rachel Klimentov.
Klimentov generally served in a human-resources, financial, and payroll function. When Ms. Huskey
would reach out to Klimentov, Klimentov would alert Chief Johnson, who would then order Ms.
Huskey not to talk to Klimentov and only to him.
23. During Ms. Huskey’s maternity leave, other fire-department employees had the opportunity
to receive higher EMT-A education. Johnson pressured her to attend, but Ms. Huskey first declined
because the classes were right after she gave birth. To attend those classes, employees must have a
recommendation from the fire department, and the department must pay for the classes.
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24. But when she told Chief Johnson she was ready to attend, he refused to provide the letter of
recommendation or pay for the classes so Ms. Huskey could increase her level of education. Hinting
at the quid pro quo sex he wanted from her, he would say, “I never get anything out of you. What do I
get?”
25. Similarly, Johnson would make comments to her like, “You only like me when it’s benefiting
you and your family.”
26. He did not do these things or make comments like this to men in the fire department.
27. He told her that if she wanted to get pregnant again, she would have to obtain his
permission first.
28. Just five weeks after Ms. Huskey gave birth, Johnson and EMS supervisor Gutman asked her
to assist with one EMS call for the station.
29. She agreed to that one-off request, believing it would be good to get out of the house for a
few hours. When she spoke to Johnson and Gutman, they agreed she would immediately return to
her leave after assisting.
30. But after completing the EMS call, she received multiple messages from Chief Johnson
demanding she return to work full time.
31. She received so many messages, she relented and returned to work.
32. Chief Johnson’s sexual harassment became frequent in September 2021 when Ms. Huskey’s
baby boy was born. He made multiple unwelcome comments to Ms. Huskey about her body,
including:
• Asking if he could watch her pump her breasts.
• Stating “there are men into milking breasts” and that he could “make a fortune off that.”
• Stating her breasts “look amazing.”
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• Stating he has “stopped seeing [her] as a young girl” anymore, and that he viewed her a
“grown, sexy woman.”
33. He also started rubbing her back and shoulders.
34. All of this was unwanted. Ms. Huskey never encouraged it.
Chief Johnson’s sexual comments escalate.
35. From October 2021 onward, Johnson’s sexual harassment escalated. He made several crude
comments to Ms. Huskey about her and her fiancé (who also works for Port Clinton’s fire
department), including:
• Saying “if [Ms. Huskey] and [her] fiancé have sex while on duty at the fire station, [they]
should do it in front of the cameras so [Johnson] could watch.”
• Telling Ms. Huskey that anal sex would be a good birthday present for her fiancé and that it
would be “easier with lube.”
• Telling Ms. Huskey that she looked sexy and making comments about her having sex with a
dog. He would then slyly bring up getting a therapy dog for the firehouse.
• If she posted photos of her with her family on Facebook, like one of her with her family in
swimwear, revealing that he often looked at those photos while touching himself—and had
to “get creative” so that he could mentally block out her fiancé and baby and focus only on
her.
• Repeatedly asking her to send him photos of herself.
• Often calling her to ask what she was wearing.
• Telling Ms. Huskey that he and his wife were not on good terms anymore and asking Ms.
Huskey to come over to his house to join him in his hot tub.
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• If she wore personal attire at the station, commenting on her appearance, often saying she
looked sexy. When she wore open-toe shoes at the fire station, Johnson commented on her
toes and toenail polish. He would say he loves her toes, and he could make money off them
by posting pictures on TikTok. He also said he had many uses for her toes and they “looked
delicious.”
36. Throughout this time, Ms. Huskey repeatedly made clear to Johnson that she wasn’t
interested in a romantic or sexual relationship with him.
37. She did her best to be polite and not anger him, because he was her boss and being a
firefighter and EMT was her dream job.
38. She tried to focus on her work and ignore Johnson’s unwanted and unceasing attention, but
she had to devote substantial time to managing his demands for her attention.
Chief Johnson asks Ms. Huskey whether she’s been “licking” a female friend and
houseguest.
39. Sometime around March 2022, Chief Johnson came unannounced to Ms. Huskey’s home
late in the evening. He was knocking on the door for a while. Ms. Huskey was confused and didn’t
know what he was doing there.
40. When Ms. Huskey finally answered the door, Chief Johnson asked what had taken so long
and asked if Ms. Huskey and her friend and then-houseguest Emily Micheletti were “licking each
other.”
41. This comment was unnecessary and inappropriate.
Chief Johnson sexually assaults Ms. Huskey in his office by running his hand up her leg and
in between her vagina.
42. In about July 2022, Chief Johnson called Ms. Huskey into his office, ostensibly to show her a
new ambulance he claimed to be buying for her.
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43. When she walked into his office, she noticed he had moved his computer to the right edge
of his desk, so it was no longer in front of his chair.
44. Johnson insisted she come around to the back of the desk to look at his computer. He
proceeded to discuss the details of the ambulance, including how many miles it had on it and the lift
system it had. Excited by the new equipment to serve the public, she let her guard down.
45. Then, with Ms. Huskey’s guard down and her still looking at photos of the ambulance,
Johnson pushed his chair back from the desk and ran his hand from her calf, up her leg, in between
her vagina. She smelled alcohol on his breath.
46. She jumped away from Defendant Johnson and shouted, “What the fuck!”
47. He tried to approach her again, saying, “I’m sorry; come here,” but she shoved him back in
his chair.
48. He had a noticeable wet spot on his pants.
49. He demanded she come near him, but she left his office.
50. Upset, she hid in an ambulance to calm down. She heard Johnson enter the bay, searching
for her. But he never found her because she was crouched down in the front.
51. Ms. Huskey told her fiancé about the incident.
52. The next day, Defendant Johnson texted Ms. Huskey that he felt “like a pedophile.” He kept
calling her as well, but she didn’t answer.
53. Disgusted by what Johnson had done and said, given that she had known and thought of
him as a second father or an uncle since she was seven years old, Ms. Huskey deleted that sickening
text message.
54. Johnson also told her after that incident that he was sorry and that he was done “picking on
her.” But he became even more disgusting with his text messages and in what he would say to her.
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Chief Johnson sends Ms. Huskey creepy and even admittedly “crude” messages.
55. Johnson sent Ms. Huskey salacious text messages expressing his infatuation, including the
following:
a. On August 9, 2022, he texted Ms. Huskey an emoji of a female sheep, the letter “R,” and
an emoji of fire, meaning “Ewe [You] are hot.” He added, “Love you” and a heart emoji.
When she asked if he was feeling better because he had been quarantined with COVID-
19, he said, “I’ll be fine…” But then, he begged: “Pictures would sure help...” She didn’t
respond with the requested photos of herself. And she found his use of ellipses creepy.
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b. On August 11, 2022, Johnson texted Ms. Huskey requesting she drop a couple of N95
masks in his mailbox. She agreed. He added, “If you want to carry them in your pants
for a while that would be ok,” followed by a grinning emoji. He added, “Miss you.”:
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c. Ms. Huskey didn’t rise to the bait of his invitation to place near her crotch “for a while”
the N95 masks he was going to put on his face. Knowing what he did was wrong,
Johnson later added, “Sorry for being crude... Thank you for everything.” And then,
moments later, he asked—referring to her baby’s first birthday party—“You dressing up
for the party” with a winking emoji:
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Again, she didn’t respond to his unwanted flirtation.
d. On August 12, 2022, Chief Johnson asked if Ms. Huskey was healthy. She affirmed she
mostly was. Ms. Huskey asked him if he was doing okay, and Chief Johnson suddenly
added, “Yeah, I just worry about my baby.” When she didn’t rise to that bait, because
she was neither “his baby” nor remotely romantically interested in him, he pressed,
“What’s the matter?” And then, “Gonna leave me hanging?” She deflected:
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e. Over the course of months, Defendant Johnson sent Ms. Huskey texts making
unsolicited comments like, “You look spectacular” and “Thank you for being you. You
mean the world to me.”
f. Ms. Huskey tried hard not to engage Chief Johnson with his nonsense every time there
was a clear romantic or sexual connotation, inappropriate for any boss, much less a high-
ranking, public-sector leader.
g. Although Ms. Huskey was in the habit of keeping her text-message threads clear, she
took the above screenshots to share with her friend Emily Micheletti, which she did.
56. Contrary to Chief Johnson’s later claims, discussed below, Ms. Huskey never, ever did
anything to lead him on. His claims to the contrary are lies or self-delusional.
Chief Johnson grinds his groin into Ms. Huskey, gropes her, and forcibly kisses her near the
bay lockers, saying “I would love to try your cream.”
57. On or about August 15, 2022, Johnson texted Ms. Huskey about the bay lockers behind the
ambulance, stating he cleared out a spot near the lockers for the fire-prevention equipment she was
organizing.
58. She was asleep and didn’t respond to his message.
59. During her next shift, Chief Johnson insisted he show her the space he cleared near the
lockers. She feared for her safety because of his escalating sexual behavior toward her, but Chief
Johnson insisted he show her.
60. After Chief Johnson showed her the space, he pushed her face first into the lockers, with her
hands on the doors. He gripped her shoulders and pushed his groin into her. He began grunting and
rubbing her back and buttocks, kissing her shoulder and back.
61. Ms. Huskey froze in fear. She didn’t reciprocate.
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62. While he groped her, Johnson made comments like, “I am crazy about you,” and “I bet
you’re creamy; I would love to try your cream.”
63. He kissed the back of her head and shoulder.
64. She said, “What the fuck!” and pulled away.
65. He apologized, saying he had a lot of stuff going on at home, and said, “I’m done picking on
you.”
Defendant Johnson seizes Ms. Huskey’s phone, forces her to unlock it, and takes it to the
restroom.
66. On about September 1, 2022, Chief Johnson asked to check the IAR (“I Am Responding”) app
on Ms. Huskey’s phone. The app is used to alert the fire station and other employees about who is
responding to a station call. Johnson claimed he wanted to ensure it worked properly.
67. Ms. Huskey told him the app was working fine because she received alerts, and it updated at
night.
68. But Johnson demanded, “Give me the fucking phone!,” grabbed it, and demanded she
unlock it. Afraid to cause a scene, she did, but first swiped and cleared all the background apps that
had been open.
69. Chief Johnson had the phone alone with him in his office for some time.
70. He then took her unlocked phone to the restroom.
71. She protested that “poop particles” would get on it.
72. He said he wouldn’t take it to the restroom but then did so anyway, saying he had to “take
care of business.”
73. He returned 30 minutes later, asking her to unlock the phone again. She unlocked it and
asked what he was doing. He responded, “taking care of business.”
74. Johnson left for the restroom a second time and came back and returned Ms. Huskey’s
phone. She asked him if he saw anything wrong with the app. And he said that he would have to
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look at it again later, and that he was pissed off. He told everyone he was leaving for the day and left
the fire station.
75. Ms. Huskey checked her phone to see what apps were open to try to review what Johnson
had seen. The I Am Responding app was not open. But her Photos app was.
76. Johnson had been looking through her photos and her photo stream was positioned on the
screenshots she had taken of his crude messages to send to her friend Emily Micheletti.
77. Ms. Huskey told a fire-department colleague about the incident. He said it was creepy and
gross but said, “Can you blame him? You’re a pretty girl and he’s a guy.”
78. After accessing her photos, Defendant Johnson often accused Ms. Huskey of blackmailing
him. He was angry about her keeping screenshots of his sexually harassing texts. He demanded she
delete those and said he was mad at her.
Using his own phone, Defendant Johnson secretly takes pictures of deeply personal,
intimate photographs Ms. Huskey had on her own phone of herself.
79. Unbeknownst to Ms. Huskey, and without her authorization, when Chief Johnson took her
personal phone on or about September 1, 2022, he snapped photos on his own phone—for his own
prurient ogling and use—of private, personal, intimate photographs of Ms. Huskey contained on her
phone.
80. These were intimate visual depictions of Ms. Huskey and were strictly for her and her fiancé.
81. Of course, she never showed or gave them to Defendant Johnson, her father figure. She
never authorized their transfer. She never authorized Johnson to make them accessible by putting
them in his Google cloud or by making them accessible to himself from the cloud in the months
following the transfer. Nor did she permit him to publish the photos there so he could see them
from any of his devices, not just his phone.
82. Johnson transferred these images from her phone to his through his cellphone camera, and
again to his Google cloud, never expecting to be caught. By putting the photos in the cloud,
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Johnson published them to himself and made them accessible for his continuous later illicit use.
Johnson still makes these photos accessible to himself today by maintaining them on his Google
cloud.
83. Johnson didn’t disclosure his intrusion, transfers, and publication of Ms. Huskey’s photos to
anyone. They were uncovered by the Ohio Bureau of Criminal Investigation (BCI), which in 2024,
while conducting a criminal investigation of Johnson, obtained access to Johnson’s Google cloud
photo storage.
84. Asked by a law-enforcement agent to explain how he had Ms. Huskey’s intimate images,
Johnson—who didn’t invoke the Fifth Amendment privilege against self-incrimination—voluntarily
admitted he took the photos contained in his Google cloud of the images on Ms. Huskey’s phone.
85. One of the photos he took of an intimate personal image on her phone showed top of his
head reflected in Ms. Huskey’s phone, as he leered at her picture.
86. Another photo he took of her phone showed, along the edges, a recognizable object in his
office.
87. But desperate to explain such conduct (and again, failing to invoke the Fifth Amendment
right against self-incrimination), Johnson also falsely claimed he had been “investigating” Ms.
Huskey for supposedly showing nude photos to firefighter David Koebel. But Koebel had made no
such allegations to him.
88. Johnson could not explain how it is appropriate for a government supervisor supposedly
“investigating” a public employee to seize her personal phone without a warrant and secretly take
intimate personal visual images from it. And to then not tell anyone about it, including Ms. Huskey,
Johnson’s supervisor the safety-service director, or the city’s law director and prosecuting attorney.
89. Johnson later changed his story to law enforcement, claiming he had obtained these images
from Ms. Huskey’s fiancé’s phone.
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90. But Ms. Huskey’s fiancé had never authorized access to, publishing, or transfer of these
photos, either. And Johnson hadn’t had access to Ms. Huskey’s fiancé’s phone on September 1,
2022, the date of the transfer to Google cloud.
91. Johnson, of course, had never told his supervisor, the safety-service director, that he was
“investigating” Ms. Huskey or anyone else over her personal photos. No City of Port Clinton
documentation exists of any such “investigation.” Johnson interviewed no one at the department
and created no memoranda of interviews or reports about an “investigation.”
92. Because there was no investigation.
93. Nor did he say anything about this supposed investigation during the June 6, 2023 meeting
in which he was placed on paid administrative leave, discussed below. That would have been an apt
time to mention it, when he was being told he was being accused of sexual harassment by this
person he was supposedly investigating. As discussed below, Johnson engaged in all sorts of other
innuendo about Ms. Huskey in that meeting, but he mentioned no “investigation.” Even to his boss
the safety-service director or city law director.
94. And this was the same Johnson who, just over two weeks earlier on August 9, 2022, had
begged Ms. Huskey by text message: “Pictures would sure help...” with beckoning ellipses. It was
these types of intimate images of Ms. Huskey, that Johnson, in his lechery, desperately wanted.
95. And she hadn’t obliged then—or ever.
96. Ms. Huskey had only authorized Johnson to use her phone to access the work-related I Am
Responding app. And that was only because he demanded access, even when the app operated just
fine. His taking of her intimate images went well beyond what she had authorized.
97. He kept her intimate images in his Google cloud, never expecting to be caught. And as
detailed below, he later lied to a City investigator about whether he had searched Ms. Huskey’s
phone.
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Chief Johnson steals Ms. Huskey’s underwear and socks from her locker for his own
prurient, fetishistic use—and gets incensed when she wants to lock her locker.
98. Over the course of Chief Johnson’s persistent harassment and assaults, Ms. Huskey would
discover her underwear and socks missing from her locker.
99. When she told Defendant Johnson about the missing garments and said she would put a
lock on her locker, he became enraged and warned her not to do so. He told her that she was going
to “piss off” a lot of people.
100. She bought a lock and told him that she planned to put it on her locker. He became even
more furious and told her she had to give him the combination.
101. Not wanting to do that, she didn’t use the lock and left it in her locker.
102. Obsessed with Ms. Huskey, and as part of his campaign of harassment, Johnson was taking
and keeping her underwear and socks for his own prurient, fetishistic use. This was the same man
who had texted her suggesting she put the N95 masks he would put on his face down her “pants for
a while” before giving them to him. And it was the same man who had told her to put office
documents down her pants before giving them to him, and asked her if she’d done so.
After Ms. Huskey injures her back as a EMT while saving a man at the scene of an accident,
Chief Johnson orders her to withdraw her workers’ compensation claim, which exacerbates
her injury.
103. In 2021, while she was on duty as an EMT, Ms. Huskey severely injured her back trying to
lift an unusually heavy man from the scene of an accident. She tried to nurse the injury herself but
needed continual treatment at the ER to manage her pain. During an ER visit in December 2021,
she applied for workers’ compensation.
104. When Chief Johnson received notice, he became upset with her for submitting the
application. He questioned whether her injury happened while she was on duty, stating she should
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have informed him of the injury the night it happened. He falsely tried to blame the injury on natural
childbirth. For months, he mocked her repeatedly with this claim.
105. Ms. Huskey’s workers’ compensation application was accepted in December 2021 and, soon
after, she attended an appointment with a workers’ compensation doctor.
106. Chief Johnson received notice of the approval and intimidated her into withdrawing her
claim. He manipulated her into believing her application was not actually approved and that she
would be accused of fraud because she did not file the application the night of her injury. His claims
were false.
107. Chief Johnson said he could dismiss the application himself because the fire department
already had three active workers’ compensation claims. She worried that maintaining her claim
would continue to upset Chief Johnson and ruin her career.
108. Chief Johnson was worried about increasing the City’s fire-department-related workers’
compensation premiums.
109. Ms. Huskey’s workers’ compensation doctor discussed maintaining the claim, but Ms.
Huskey feared Chief Johnson’s reaction. Because Johnson demanded it, Ms. Huskey withdrew her
workers’ compensation claim on December 12, 2021.
110. As a result, her care was delayed and she paid many of her further medical expenses out of
pocket, including for her back surgery in October 2022. These expenses would have been covered
by workers’ compensation.
111. Also because of Chief Johnson’s misconduct, she was unable to obtain the early MRI that
would have diagnosed the specifics of her back condition, which would have enabled her to seek
treatment earlier and stop additional damage. Workers’ compensation would have covered that MRI,
but her health insurance did not. Because she did not receive that early, needed MRI, she has been
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diagnosed with nerve damage in her right leg and experienced far more pain than she otherwise
would have. If not for the October 2022 surgery, she would have experienced permanent paralysis.
112. Chief Johnson’s actions deprived Ms. Huskey of her statutory right to workers’
compensation benefits.
113. Because of the way that Chief Johnson so controlled her, and blocked her access to the
central city administration—who would always refuse to respond to her and tell him about her
requests—Ms. Huskey believed that she had no place to go with any of her concerns about the fire
chief.
Chief Johnson makes unsolicited visits to Ms. Huskey’s home and sexually assaults
her when she is almost completely immobile and recovering from back surgery.
114. Over several months, Chief Johnson came to Ms. Huskey’s home uninvited and
unannounced about 15 times.
115. He tried to only stop by when he knew Ms. Huskey was home alone with no other cars in
her driveway.
116. In about October 2022, Ms. Huskey finally had back surgery to repair the injury she
sustained on duty the year before. The surgery rendered her immobile.
117. During her recovery, she spent most of her days on bedrest, except for her required 30
minutes of sitting time each day.
118. Her parents cared for her newborn son full-time during her recovery so that her fiancé could
continue working.
119. Johnson knew Ms. Huskey’s parents were caring for her son during this time and that Ms.
Huskey often would be home alone for a long time.
120. Johnson would walk in the door without knocking, which, when she was immobile and
bedridden, she had to leave unlocked not for him but for other family members who were coming in
to care for her and friends who would drop off food.
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121. He would make it seem as though he was checking in on her as her boss, when his
intentions and conduct were prurient.
122. During these visits, Ms. Huskey was still immobile and on bedrest.
123. Chief Johnson exploited this. He would sit on the side of her bed and rub her legs from top
to bottom, including her toes, knowing she could not move to resist his sexual advances.
124. During the first three visits, Ms. Huskey pleaded repeatedly with Chief Johnson to stop
touching her.
125. But despite her begging, he refused.
126. She told him her family would be home any minute.
127. That made no difference to Chief Johnson.
128. During the visits that followed, because Johnson had ignored her pleas and continued to
grope her, Ms. Huskey felt defeated and stopped asking. She knew that Johnson would not stop
touching her no matter how persistently and forcefully she pleaded with him.
129. Ms. Huskey lived in a state of constant fear.
Chief Johnson again sexually assaults, and this time inflicts severe pain on, Ms. Huskey in
her own home when she is immobile.
130. In October 2022, Chief Johnson, yet again in the guise of checking in on her post-surgery as
her boss, showed up at Ms. Huskey’s home unannounced, knocking on her door and all the
windows.
131. Ms. Huskey was terrified. For her it was like something out of a horror movie.
132. Chief Johnson did not stop knocking until Ms. Huskey, who could barely move, opened the
door.
133. After Ms. Huskey let him inside, Chief Johnson told her he would help her with her required
30-minute sitting for the day. He walked her over to her couch, shaking the entire time.
134. This terrified her because she sensed something bad was about to happen.
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135. And it did.
136. Because of her immobility, she was only wearing a night gown. And she had not bathed for
days.
137. Chief Johnson and Ms. Huskey discussed her surgery and that she was sad she could not
care for her own toddler. She told him she was worried about herself and her family’s stability.
138. She felt deeply insecure because Chief Johnson kept commenting throughout this discussion
that she “looked sexy” in her nightgown.
139. While Ms. Huskey was talking, Chief Johnson stood up, adjusted his pants, adjusted his belt
and loosened it, and adjusted his belly gun strap.
140. Ms. Huskey saw the gun.
141. While Chief Johnson talked, he pushed Ms. Huskey’s walker away from her, adjusting the
brakes to do so, and sat back.
142. Chief Johnson said he would give her fiancé a job to provide for her family if Ms. Huskey
could not do so. He reminded her how much he had done for her and that he plans to continue to
take care of her. He told her he loved her.
143. In that vulnerable moment, Ms. Huskey told Chief Johnson she would go back to work at
Starbucks.
144. Chief Johnson then pushed her walker further out of her reach.
145. Johnson stood up and adjusted his penis, which was erect. There was a wet mark on his
khakis.
146. He loosened his belt when he was adjusting himself, and then adjusted the gun belt that was
around his belly but under his outer shirt, flashing his gun to be partially visible to ensure she knew
he was armed.
147. She saw the gun. It frightened her.
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148. He sat back down next to her.
149. Chief Johnson began rubbing her shoulder and back.
150. Chief Johnson rubbed her fresh incision, saying, “I’ve got magic hands. Trust me.”
151. What he was doing hurt her a great deal.
152. Chief Johnson commented on her red nail polish, saying her toes looked “sexy and
delicious.”
153. He bent down and started rubbing her feet.
154. While groping her, he made comments about how much he “loved” her and how he is
“obsessed” with her. He said they were “destined to be together” and he wished they had met when
he was younger.
155. Chief Johnson added, to Ms. Huskey’s alarm and distress, “If your back wasn’t broken, I’d
break it.” He was referring to sex.
156. Chief Johnson began kissing her shoulder and neck.
157. He was telling her he loved her. He said he wished that he were born later or that she had
been born earlier.
158. Ms. Huskey was paralyzed with fear and wanted to get away from him.
159. But because of her injury she could neither move nor twist her body to evade Chief
Johnson’s unwanted touch.
160. She could not get up from the couch and walk away from him because he had pushed her
walker out of reach. She couldn’t even move away from him on the couch because of her injury.
161. She was his captive.
162. He, then, began forcibly kissing her face and tried to turn her head to make her to kiss him
back.
163. Ms. Huskey refused to do so.
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164. When she did not kiss him back, he stopped touching her and slapped his hands on his legs.
165. He stood up so she could see his erection, flashed his gun again, then raised his voice sternly,
looking her in the eyes, “Did you have fun? It is important to me you had fun!”
166. Ms. Huskey was visibly shaking and crying.
167. Johnson was shaking.
168. Terrified of his shouting and reaction, and home alone with him, she said, quietly, “Yes.”
169. But it would have been obvious to him from the way she was shaking and her eyes were
teared up that the answer was no.
170. Indifferent to her fears, Chief Johnson then vowed he would return later that night to “show
[her] even more fun.”
171. He pushed her walker back to her and reactivated the brakes.
172. He asked her if she wanted him to walk her to bed.
173. She said no.
174. He said he would let himself out and then left her house.
175. Chief Johnson left Ms. Huskey’s house and, knowing Ms. Huskey was watching him through
the window, sat on a concrete pig statue in her front yard and slapped the pig’s rear end several
times, yelling “Yee haw!”
176. Seeing this exacerbated Ms. Huskey’s fear about Johnson’s behavior and her trauma about
what she had just endured.
177. Through that trauma, Ms. Huskey told her mother and her sister about what had happened.
They chose not to tell her firefighter father for fear that he might harm Johnson.
178. Chief Johnson contacted Ms. Huskey later that night asking if he could come back over.
179. Terrified, Ms. Huskey told Johnson that her brother was at her house, which wasn’t accurate.
180. Chief Johnson cursed her brother for “ruining [their] fun.”
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181. She told her mother and sister about the continuing assaults, and they grew concerned about
her safety and well-being.
182. To prevent Johnson from continuing his spree of sexual assaults, Ms. Huskey’s mother and
sister often stayed with Ms. Huskey at her home when her fiancé wasn’t there. If neither her mother
nor her sister could stay with her on any given day, they would leave their cars in her driveway,
making it appear that she was not home alone.
Chief Johnson takes away Ms. Huskey’s firefighter/EMT job, and when she returns to the
fire department in January 2023, he forces her to serve as his “personal secretary.” This
facilitates his continued spree of sexual harassment and assaults.
183. After Ms. Huskey’s October 2022 surgery, Chief Johnson had given her full-time position to
another employee who wasn’t previously employed with the department. Earlier, he had promised to
save her position.
184. Losing this full-time position meant that Ms. Huskey would no longer have health insurance
for herself or her son. Knowing Ms. Huskey’s concerns about her insurance, Johnson manipulated
her into accepting a new position as his “personal secretary,” a department job that never previously
existed.
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185. When Ms. Huskey questioned Johnson about this new position, Johnson told her she
couldn’t return to work as a firefighter/EMT because her back was “still healing”—even though he
knew that Ms. Huskey’s doctor had cleared her to return to work as a firefighter/EMT. Ms. Huskey
provided Chief Johnson a doctor’s letter showing she was eligible to return to work with no
restrictions:
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186. Johnson locked up Ms. Huskey’s fire gear so she could not access it and go out on service
calls as a firefighter.
187. Ms. Huskey was so devoted to her work as a firefighter that she wept about this.
188. The new secretarial position cost Ms. Huskey the ability to earn the type of overtime she did
in her previous position.
189. And because Ms. Huskey was now his personal secretary, she was now required to work
directly with him much more, in the office. He began demanding that she come into work at
unscheduled times and on inconsistent days, making it difficult for her and her fiancé to maintain
consistent childcare for their baby.
190. The reassignment resulted in fewer working hours, including overtime, than what Ms.
Huskey used to earn as a firefighter and EMT. This caused her to receive overall less compensation
than what she previous earned, which affected her and her family.
191. Following Ms. Huskey’s return to work and forward, Chief Johnson continued to harass her,
sometimes even in front of other employees. His sexually harassing conduct included the following:
• Stating “I bet you can handle a dog knot. Do you think you can handle a dog knot?” (This is
a reference to sexual acts between dogs when a male dog locks up inside a female dog.)
• Stating Ms. Huskey had a “fat ass.”
• Telling Ms. Huskey that her “ass looks great” in her duty pants. And when she switched to
oversized baggy pants to avoid his comments, telling her she didn’t look good in them and
insisting should go back to wearing duty pants.
• Calling her “honey,” “baby girl,” and his “girlfriend.” He even told her at one point that he
had her listed in his phone as his girlfriend.
• Requesting that she put documents down her pants before giving them to him or asking her
before she handed documents to him if she had put them down her pants.
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• Blaming her “period and hormones” for her rejecting his sexual advances.
• Telling her he “could last all night long” and that he could “make [her] eyes cross if [she] had
sex with [him].”
• Telling her he’s old but “it” still works, and he could make her eyes roll in the back of her
head.
• Telling her she was “too scared” to have sex with him.
• Telling her he would watch her work out on the cameras, and that she should wear a tank
top when she was working out. (This forced her to work out late at night when he was gone.
But when he kept commenting that he was still watching her work out, presumably on the
camera app on his phone, she stopped working out at work altogether.)
• Telling her he was glad she moved the treadmill, so she was facing the camera when she
worked out.
• Groping her breasts from the side while hugging her, which was constant and unnecessary.
She would not hug back and would stiffen up in his arms. With every hug, he would rub her
breasts from the side.
• Telling her he wanted to “lick [her] nipples.”
192. And in Ms. Huskey’s new position, the sexual harassment she endured from Johnson
included:
• When she would ask what she should be doing, saying he wanted her to “sit on [his] lap.”
• Telling Ms. Huskey multiple times that if he “had it [his] way, [she] would be [his] sex slave.”
• Using Ms. Huskey’s new position as an excuse to touch her and force her to share space
with him.
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• Repeatedly telling her he “did not feel the love from her” and even stating this as the reason
for denying her fiancé the opportunity to attend fire-science school.
• Stating multiple times, after assaulting her, “I’m dealing with a lot,” referring to his
relationship with his wife. He told Ms. Huskey that his relationship with his wife had been
strained for the past year. He would also blame his blood sugar for his misbehavior.
• Saying, whenever he was trying to manipulate her, that he had her best interests at heart and
that no one cares for her the way he does.
• Approaching Ms. Huskey from behind as she sat at her desk, touching her shoulders, ear,
and moving his hands down to grope her breasts.
Chief Johnson sexually assaults Ms. Huskey in a storage room, telling he loves her,
grabbing her shoulder, kissing her face, and rubbing his hands down her back to her
buttocks.
193. In about late February 2023, Chief Johnson directed Ms. Huskey into a storage room at the
fire station ostensibly to show her his ideas for a new organization of the room.
194. They walked through the storage room and exchanged ideas.
195. When Ms. Huskey was looking inside a closet, Chief Johnson came up behind her. He told
her he was proud of her, and he loved her.
196. Chief Johnson grabbed her shoulder and kissed her face. He rubbed his hands down her
back toward her buttocks.
197. He then said, “I’m done picking on you.”
Chief Johnson sexually assaults Ms. Huskey in a storage room, grabbing her hand and
trying to force her to touch his erect penis.
198. In about March 2023, Chief Johnson asked Ms. Huskey to come with him to look at the new
lockers at fire station.
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199. Ms. Huskey first declined, saying that she had seen the new lockers because her fiancé
helped build them and sent her photos of them already.
200. Chief Johnson—her boss—still insisted that she go with him, so Ms. Huskey obeyed. But
she had a bad feeling about what was about to happen.
201. While the two were looking at the lockers, Johnson grabbed his penis through his pants,
stating that his penis was “hard,” because Ms. Huskey “looked very sexy today.”
202. He then asked her to touch his penis and tried to move her hands toward it.
203. Ms. Huskey refused, pulled her hands away, saying, “What the fuck!,” and left.
Chief Johnson sexually assaults Ms. Huskey in the locker area, shoving his groin against
her, grabbing her private parts, and telling her he bets she “squirts.”
204. In April 2023, when Ms. Huskey had just cleaned the entire storage room at the fire station
and was alone in it, Johnson came in and pushed her up against a sink.
205. While he was pushing his groin against her, he asked if she was “playing with the squirt sink”
and whether she “squirts.”
206. She said no.
207. He rubbed his groin against her said again, “Do you squirt? I bet you squirt.”
208. He grabbed her buttocks and made a remark about them.
209. He let her go and said, “I’m done picking on you.”
210. But Johnson continued, “By the way, you’re gorgeous, you should never be insecure, and I
love this fat ass.”
211. From behind her, he grabbed the area between her buttocks and her vagina.
212. She exclaimed, “What the fuck!” and immediately pulled away from his grip and left.
213. Ms. Huskey kept her distance after that.
Chief Johnson again shows up at Ms. Huskey’s home unannounced.
214. Shortly after, Ms. Huskey was off work, and her fiancé called off work as well.
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215. Chief Johnson showed up at her home on their day off unannounced. The couple had just
put their toddler down for a nap and laid down for naps as well. When the chief showed up, the
fiancé went out to deal with him. But it became apparent that Johnson wouldn’t leave until he saw
Ms. Huskey.
216. She went out and Johnson claimed to “just be checking” on them to see if they were okay.
He asked about the baby.
217. They said he was asleep.
218. Johnson left.
Chief Johnson’s stalkerish messages continue.
219. On May 3, 2023, at 3:44 PM, Defendant Johnson sent Ms. Huskey a text message saying,
“Sexy… you look great.”
220. She didn’t respond.
221. There was no business purpose for Johnson sending such a message.
222. Ms. Huskey didn’t need to be called sexy by her then 64-year-old boss and father figure.
223. Nor did she need to be told she looked great by her then 64-year-old boss and father figure.
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224. And contrary to his later insinuations when he was placed on administrative leave and
interviewed during the investigation, she didn’t provoke this harassment.
225. Within the hour that same day, at 4:40 PM, Defendant Johnson left Ms. Huskey a voicemail
saying, “This is your favorite fan. You look very nice today. Give me a call if you get a chance. If
not, I’ll talk to you soon. Love you. Bye.”:
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226. Again, there was no business purpose to Johnson’s voicemail.
227. Once more, Ms. Huskey didn’t need to again be told that day or ever she looked very nice by
her then-64-year-old boss and father figure. And she did not provoke this overture.
228. On May 23, 2023, when Ms. Huskey reported cleaning-and-moving work she had completed
and how she had felt tired afterward, Chief Johnson responded, “Stop.... You need to take care of
yourself..... You aren’t wonder woman….” With two wink-and-kiss emojis.
229. He added, “But you are mine…. Wonder about you all the time.” She replied to the first text
with a Wonder Woman® GIF and “I’m trying to be.” She ignored his second, innuendo-filled text.
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Chief Johnson demands Ms. Huskey ride with him, tries to hold her hand, complains about
his life and that he does “not feel like living anymore,” tells her he fantasizes about “fucking
her all night,” and twice calls it their first date.
230. On or about April 28, 2023, EMS Captain Brian Gutman and Ms. Huskey delivered a
replacement ambulance for a patient transport after the first ambulance broke down. Chief Johnson
arrived on scene in his Chief’s vehicle. The first ambulance needed to be repaired, and was
connected to the Chief’s vehicle to be towed back to the fire station.
231. Ms. Huskey said she wanted to ride with Gutman back to the station, but Chief Johnson
demanded she ride with him. She again said she would like to ride with Gutman, but Chief Johnson
insisted she get in his passenger seat.
232. Frightened of his reaction, she got into his vehicle.
233. To stay away from Johnson, she sat on the right edge of the passenger seat toward the
vehicle door.
234. Johnson forcibly grabbed her hand but she balled up her fist so he could only hold her pinky
finger.
235. Johnson talked about how stressful his home life is. He said he is having problems with his
wife, who he claimed is never home anymore and doesn’t care if he even eats.
236. Johnson said he did “not feel like living anymore.”
237. Referring to himself and Ms. Huskey, he said he never pictured “our first date would be like
this.”
238. Chief Johnson said he instead fantasized about taking her out to a nice dinner and then
“fucking [her] all night.”
239. Johnson said, again, he hates his life and death would be more peaceful. He continued to say
that no one appreciates him.
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240. When they arrived at the fire station, Ms. Huskey quickly got out of the vehicle. Chief
Johnson announced to everyone present, “Yeah, I didn’t think our first date would be like this.”
Chief Johnson contrives an excuse to seize Ms. Huskey’s hand, and when she whips her
hand away again claims he’s “done picking” on her and “will leave her alone.”
241. In May 2023, while preparing for an event at the fire station, Ms. Huskey and her fiancé saw
Chief Johnson intentionally knock over a box of N95 masks.
242. Johnson then left the station and upon his return blamed others for knocking over the
masks. Ms. Huskey said she would pick them up.
243. As she bent down to do so, Johnson, too, bent and placed his hand on top of hers. She
whipped back her hand to get his hand off. Johnson, again, told her he was “done picking on [her].”
244. Chief Johnson said, “Fine, I’ll leave you alone” and left the garage.
Chief Johnson sexually assaults Ms. Huskey even more, tries to kiss her, and angrily tells
her she has left him “with blue balls.” And she finally reaches her breaking point, urinating
on herself in terror.
245. On or about May 23, 2023, Ms. Huskey approached Johnson in his office to inform him that
a young woman whom the department was considering hiring decided not to join the department.
Johnson became upset and went on a tangent about how he didn’t feel appreciated by the
department or the City.
246. Chief Johnson then turned his attention to Ms. Huskey and said he didn’t “feel the love
from you anymore” and that he was “just left with blue balls.” He said he took risks for her and
took her on as project, gambling everything to give her a career. He said he wanted to do things for
her, like purchase a new desk and chair, because he worries about her.
247. Ms. Huskey told Johnson he did not need to worry about her.
248. He became agitated and said, “Fine, I am done worrying about you.” He pivoted, talking
about how much he loved her and made a big show of ogling up-and-down at her body, focusing on
her breasts and groin.
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249. Ms. Huskey tried to leave his office, but Johnson stopped her, falsely claiming there was an
issue with her shoe. He bent down, untied her shoelace, then retied it.
250. When Chief Johnson stood up, he tried to kiss her. Ms. Huskey turned away from him and
tried to leave once again, but Johnson grabbed her shoulders to keep her in place. He grabbed the
sides of her face and her head on her ears, to the point of pain. He was shaking with anger because
she tried to avoid him. He kissed the side of her face up to her ear. He was enraged with Ms.
Huskey’s resistance and began shaking in anger. He eventually let Ms. Huskey go.
251. Ms. Huskey shouted, “What the fuck!” and left his office.
252. Outside his office, she heard Chief Johnson throwing objects. This behavior scared her, so
she left the fire station and fled to the smokehouse outside.
253. She heard five gunshots. Because of Johnson’s serial stalking and assaulting behavior,
including having previously flashed his gun at her, she truly believed he shot the other employees in
the firehouse and possibly shot himself.
254. Johnson had said he wasn’t afraid to kill people or to kill himself, including making
statements like:
• “I have a bullet with his name on it.”
• “This family needs to go.”
• “I have a remedy for that … a (names a gun).”
• “He needs a healthy dose of a 9 mm.”
• “I am not afraid to die.”
• That he didn’t feel like living anymore.
255. All these statements had made an impression.
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256. Ms. Huskey panicked and hid in the fire department’s fire-safety-demonstration
smokehouse, terrified Johnson would look for her and shoot her. She hid for 15 minutes, thinking
she was going to die, and that her baby boy would grow up without her.
257. She wept.
258. And she urinated on herself in her pants, in terror.
259. She was paralyzed in complete panic and didn’t know what to do.
260. Ms. Huskey then saw another employee leave the fire station. She wept in relief and realized
the gunshots were from the shooting range down the road. She called her sister and described what
happened. Her sister advised her to leave work and come home. Ms. Huskey walked back to the fire
station to tell Johnson she was leaving early because she had started her period.
261. Chief Johnson responded, “Well, you’re not bleeding from me.”
Johnson constantly threatens Ms. Huskey’s job, her fiancé’s education and advancement in
the department, and her fiancé’s ability to work in the department.
262. Throughout Ms. Huskey’s ordeal with Chief Johnson, he would threaten her job and
insinuate she could not continue working at the fire department, threaten to block her fiancé’s ability
to obtain required training and certification, and threaten and insinuate that her fiancé could not join
the department even when vacancies occurred.
263. None of this was performance related, and all of it was to pressure her to give into this
sexual overtures and assaults and retaliate against her for resisting.
How Ms. Huskey was particularly vulnerable to Chief Johnson’s manipulations.
264. Throughout Ms. Huskey’s ordeal with Chief Johnson, she was conflicted by the love she felt
for him as a father figure and the web of close relationships of which they were both a part. Her
defining quality is empathy.
265. When she was three years old, her family threw a surprise birthday party for her. She wept
because others had done something for her.
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266. Often, on EMT duty, she would hold the hands of those being treated in the ambulance, and
sometimes cry at their misfortune. Throughout her life, she liked doing things for and caring for
other people. She feels what they feel.
267. These qualities made her a vulnerable victim for Johnson. And having known her since she
was seven years old, he knew that. He preyed on her.
268. She believed what Johnson would tell her about the difficulties he was going through to
excuse his misconduct. She believed him and felt compassion for him when he said he was having
serious problems at home with his wife, health problems, blood-sugar problems, and that he hadn’t
been eating at home.
269. She didn’t know how to deal with it. And she hoped they would both be able to just move
on and she could do the job she loved, protect her career, and protect her income and health
insurance for her family. She wanted to keep her life and relationships in the fire department and
community (including with Johnson’s relatives) intact. What he was doing to her felt like a bad, dirty
family secret. She felt that she couldn’t talk to anyone outside of her immediate family.
270. She did not understand then that Chief Johnson was conditioning, grooming, brainwashing,
gaslighting, and manipulating her. She kept finding reasons to try to forgive him and think his
behavior would stop—when it wouldn’t and was escalating because of his obsession with her and
perversion.
271. His behavior resulted in trauma bonding. Trauma bonding is a defensive mechanism that
occurs when a person develops an unhealthy attachment to their abuser after experiencing physical
or emotional abuse, followed by positive reinforcement.
272. Johnson knew exactly what he was doing.
273. Even after Ms. Huskey finally apprised her fiancé of some of what was happening, she
insisted he not do anything because she thought Johnson would overcome his emotional difficulties.
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As fearful as she was—and she was terrified—rightly or wrongly, she felt compassion and empathy
for him. She prayed for him often. When he would tell her why he was doing what he was doing for
her, he would ask her to pray for him. So she did.
274. And Chief Johnson tried to prevent Ms. Huskey from reporting his conduct by insisting that
the person to whom she would report, Director of Public Safety and Service Tracy Colston,
wouldn’t take her complaints seriously because Colston, according to Johnson, “does not like the
fire department and hates women.”
275. Ms. Huskey had never spoken with or met Director Colston and knew of him only through
the denigrating things Johnson said about him.
276. And, as stated previously, whenever she would try to speak with Rachel Klimentov, Port
Clinton’s auditor, she would be redirected back to Johnson, and he would tell Ms. Huskey not to
talk to Klimentov.
277. Throughout her ordeal, Ms. Huskey had no clear understanding of where she was supposed
to report workplace sexual harassment or abuse.
278. The City had never provided her with policies or procedures—or training for that matter—
about what to do.
279. Indeed, in about 2022, when the Ottawa County sheriff was caught distributing sexual
photos within his office, Johnson sarcastically complained that the City of Port Clinton would have
to do sexual-harassment training.
280. But it never did.
281. Nor did the City do so when the same safety-service director and the former mayor were
also sued for sexual harassment, which resulted in a settlement.
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Ms. Huskey reports the sexual harassment and assaults to EMS supervisor Brian Gutman.
282. Because Johnson had manipulated Ms. Huskey into thinking she could not report the sexual
harassment and assaults to Colston, she reported her complaints to EMS supervisor Brian Gutman
on May 30, 2023.
283. Equally uninformed because of the city’s deficient policies and training, Gutman had no idea
what he was supposed to do.
284. A few days later, Gutman told Ms. Huskey that her report was sent to Port Clinton’s law
director.
Chief Johnson shows up at Ms. Huskey’s home unannounced when she returns briefly from
taking refuge elsewhere, apologizing for “picking on” her, saying he was worried it would
“mess [her] up” and that he’d “gone too far,” promising he “would leave [her] alone this
time,” and admitting what he did was “wrong.”
285. For her safety because of Johnson’s behavior, Ms. Huskey had generally fled her own home,
staying elsewhere, like a refugee. She transported her firearm with her for protection.
286. She returned to her home on the morning of Saturday, June 3, 2023 to do laundry, while her
fiancé worked a 24-hour shift at the fire department.
287. Chief Johnson arrived at her home unannounced at 10 AM, in his fire-department vehicle,
and knocked aggressively on her door.
288. As chief, Johnson knew her fiancé worked a 24-hour shift, so he knew she would be alone.
289. Ms. Huskey opened the door.
290. Chief Johnson said he was calling, texting, and driving by the house to get ahold of her.
291. They discussed her recent emergency surgery and childcare for her son.
292. Chief Johnson said he was sorry for “picking on [her],” and that he was worried it would
“mess [her] up.” He said, words to the effect, “I am worried that you know, I’ve gone too far. But I
want you know; I’m done picking on you. I’m going to leave you alone this time.”
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293. When she thanked him, he responded, “No, you don’t need to thank me—it was wrong. I
was worried that what I was doing would mess you up. That I swear on my life.”
294. He said something about hiring a counselor for fire-station employees and said she should
talk to the counselor.
Johnson: Huskey “takes a birdbath.”
295. After learning of Ms. Huskey’s report, Johnson went into the fire-department women’s
bathroom. Previously, Johnson had commented on Ms. Huskey’s habit of taking a sink bath in the
women’s bathroom before going to bed while on overnight firefighting duty—something he should
not have known. He said she takes a “birdbath.”
296. Ms. Huskey was so creeped out by that, she would then use the toilet at night in the
stationhouse, in the dark, with a flashlight to avoid any motion-detecting camera.
City officials meet with Johnson to place him on paid administrative leave pending
investigation—and Johnson makes various false and defamatory statements, to attempt to
influence and successfully elicit sympathy from those officials.
297. On or about June 6, 2023, the law director and safety-service director called Johnson in for a
meeting to place him on administrative leave, pending investigation.
298. The meeting lasted just over 31 minutes.
299. During the meeting, when Johnson was told that he was being accused of sexual harassment,
he grunted, “Hmmm!” in feigned surprise, as though it was the first time he was hearing this.
300. But it wasn’t. Firefighter/EMT David Koebel had snitched to him after Ms. Huskey had
confided in Koebel. Koebel failed to report what Ms. Huskey told him to Safety Service Director
Tracy Colston or any other city official in a position to do anything about it.
301. Rather than dispute or protest the accusation, one of Johnson’s first impulses was to ask
what Ms. Huskey wanted to resolve the matter.
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302. When the law director told Johnson that the allegations included Johnson grabbing her face
and trying to kiss her, he didn’t deny it. Indeed, later in the meeting he admitted grabbing her face
and kissing her, downplaying it as a “peck.”
303. Unprompted, Johnson blurted: “I’m sure there’s going to be some texts and some other
stuff, so…”
304. And Johnson said, “I’m very disappointed that she’d do that without coming to talk to me.
It’s been over a year.” Trying to blame Ms. Huskey, while effectively admitting something had
happened, he added, “She did some things. And it’s, it’s more of a joking aspect, back and forth and
if it was bother [sic], she shoulda said something.”
305. Trying to portray Ms. Huskey as litigious, Johnson falsely claimed that Ms. Huskey had sued
Firelands Hospital over her back surgery, later claiming that it was about a “drug mishap.” In fact,
she had never filed such a suit.
306. He twice falsely characterized Ms. Huskey as “very unstable,” calling her “just kinda a crazy,
I guess, is the easiest way to put it…” Later, he insinuated further, “I’m not going to go into details
with you guys. But she’s told me shit that just blows my mind.”
307. Johnson’s false statements and maneuvers in the meeting elicited sympathy from the safety-
service director, who groaned, “I’m just sick to my stomach” and, alluding to his own prior
situation(s) with being accused of sexual harassment: “I’ve been there.”
308. Johnson admitted: “Has there been some situations? And—I probably overstepped a
boundary or two.”
309. “But so did she,” he added.
310. The first part was an understatement. That last part was a lie.
311. He tried to minimize his conduct: “There’s joking back-and-forth texts, et cetera. In my
opinion. If she’s— was uncomfortable, I wish she would have come to me.”
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312. The safety-service director asked, “Do you think she has texts of something you shouldn’t
have probably said?”
313. Johnson responded, “Probably.”
314. The safety-service director gasped, “Oh, fuck.”
315. Johnson falsely insinuated that Ms. Huskey was responsible: “I wish I would’ve kept some of
hers.”
316. In truth and in fact, Ms. Huskey had never sent any sexually charged texts to Johnson, the
man she viewed as a dad or uncle. Never. So there was nothing to keep.
317. Johnson tried to blame Ms. Huskey’s sister for having Ms. Huskey come after him.
318. The safety-service director promised, “We want to clear your name, you know? That’s all
Tracy cares about.” He commented on “everything you’ve done to help her out” and said, “No
good deed goes unpunished.”
319. The safety-service director exhorted Johnson about what he might do to Ms. Huskey: “Just
protect yourself” and, “Do what you gotta do.”
320. “I’m sorry, Chief,” he added.
321. Johnson, in another attempt to influence these public servants, suggested retaliation: “If she
wants to play ‘the game,’ she can’t come back as that administrative assistant. That was just a created
position so she could earn money.” This was a false statement because he created the position to
keep her close to him so he could harass and assault her. A doctor had cleared her to return to work
as a firefighter/EMT and he knew that because she had given him the letter.
322. The safety-service director found Johnson’s nonsense so compelling that he responded, “So
you took care of her again and then she fucked you!” And then he sighed loudly.
323. Johnson again admitted, “I’ll tell you, it started off, and it was playful, I guess is the easiest
way to put it. Did I overstep the boundary a little bit, probably.”
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324. Johnson again falsely portrayed Ms. Huskey as a basket case: “She is a very emotional young
lady. I worried about her killin’ herself; overdosin’. She’s told me she had her husband take the gun
away or the boyfriend take her gun away because she’s thought she’d put the gun in her mouth.”
325. These were complete fabrications. And Johnson himself was the reason for Ms. Huskey’s
severe emotional distress.
326. Again, as he attempted to influence these public servants, Johnson was scoring sympathy
and empathy points with them. Their responses to his manipulations included:
• “Scary.”
• “It absolutely sucks.”
• “All of that [Johnson’s negative insinuations about Ms. Huskey] will come into play if it goes
all the way.”
• “People these days.”
• “It gets old.”
• You were “trying to help people.”
• “You get kicked in the nuts.”
• “Kicked in the teeth.”
• “Infuriates me.”
• “I’ve been there.”
• “When is enough enough.”
• “I just care about Kent Johnson’s name.”
• “Please defend yourself if you need to.”
• “I know the type of guy that you are.”
• “But if it means to defend yourself.”
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• “Keep all options open.”
• “It drives me fucking crazy.”
• “You get fucked.”
• “When you’re dealing with potential crazy.”
327. Then there was this exchange:
Safety-service director: I don’t know what’s in her brain when he says she’s
unstable—
Law director: Yeah, well right, she’s crazy, I don’t know what’s in her brain.
Chief Johnson: She’s very, she’s very unstable.
Law director: —I don’t know what’s in her brain either.
328. But reacting to the law director’s “dealing with potential crazy” comment, Johnson
backpedaled: “She’s a goddamn good EMT.”
329. Which was true.
330. Toward the end of the meeting, unprompted, he admitted, “And I’m going to tell you. She’s
probably got enough to hang me out to dry.”
331. Which was also true.
332. But Johnson added, “And I just wish I would’ve saved her shit… You know?”
333. That insinuation, again, that Ms. Huskey had done anything to prompt his misconduct was a
lie.
334. Also unprompted, Johnson volunteered the following, prompting this exchange:
Johnson: [UI] The kiss? You know, where I grabbed her by the face, she was bawling
her eyes out in the office. I felt so damned sorry for her, I grabbed her,
looked at her in the eye, she didn’t pull away, she would’ve been, and what
was it? A peck.
Law director: I don’t know what to say.
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Johnson: I don’t know what to do.
Law director: It’s…
Johnson: All right.
Law director: When you’re a woman, you’ve got all kinds of. Yeah.
335. With his comments, Johnson elicited so much sympathy (and antipathy toward Ms. Huskey)
that the law director warmly embraced him at the end of the meeting: “Give me a hug; I’ll give, I’ll
give you a hug, heh, heh, heh, it’s okay.”
336. Neither official directed Chief Johnson not to contact anyone pending investigation. This
was unlike instructions they gave Ms. Huskey when placing her on administrative leave pending the
investigation. Indeed, they specifically authorized Johnson to speak to his employees.
337. The law director expressed a completely erroneous legal view of the City’s liability for
Johnson’s conduct, declaring that by the City placing Johnson on leave, Ms. Huskey “can’t say she
was wronged by the City. I don’t know.”
338. True, she didn’t know. The U.S. Supreme Court has held that employers are generally liable
under Title VII for supervisor discrimination toward employees. Faragher v. City of Boca Raton, 524
U.S. 775, 786–810 (1998). This includes sexual harassment. Burlington Industries, Inc. v. Ellerth, 524 U.S.
742, 751–76 (1998). Even if an employer takes corrective action after the fact, it still may be liable
under Title VII because it has a duty to prevent harassment in the first place. Williams v. General
Motors Corp., 187 F.3d 533, 561 (6th Cir. 1999).
339. Her misstatement of law reflected the deficiency of City policies and procedures when a
high-ranking executive like Johnson engages in federal and state legal violations.
340. Johnson secretly recorded the conversation. This recording is incorporated and is being
manually filed with the Court. The transcript of that recording is attached.
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Chief Johnson removes or discards Ms. Huskey’s firefighter/EMT continuing-education

training records.
341. Before being placed on leave, knowing from David Koebel that he was trouble, Johnson
discarded boxes of documents and left the office with boxes, which he loaded into his vehicle.
342. Johnson had been responsible for maintaining department personnel’s continuing-education
records for EMS and fire certification. But Johnson had not maintained—or falsified, took,
destroyed, or discarded—Ms. Huskey’s needed continuing-education certifications for EMS or fire
certification.
343. He did so to interfere with her ability to recertify as a firefighter/EMT. To maintain her
certification, she now had to work harder to retake the EMS-education hours she had banked, the
records of which Johnson maintained. She was unable to maintain her fire certification, despite
having completed necessary continuing education.
344. Johnson didn’t do this to men in the department. And he didn’t do it to women he didn’t
want to have sex with.
Because of Defendants’ conduct, Ms. Huskey loses earnings, loses a job and work family
she loved, and is diagnosed with post-traumatic-stress disorder and betrayal trauma.
345. Because of Defendants’ conduct, Ms. Huskey earned far less money overall than she did or
would have with her firefighting and EMT duties. This was hard on her and her family.
346. Chief Johnson treated no male firefighter or EMT the way that he treated Ms. Huskey.
347. Ms. Huskey sought, received, and continues to receive mental-health treatment because of
Johnson’s perverted and unlawful acts. She lived in terror for her baby, fiancé, and her own safety.
She had recurring, brutal nightmares about him. For months she lived in hiding away from Chief
Johnson and her own house, terrified he would enter her home.
348. She has been diagnosed with post-traumatic stress disorder and betrayal trauma.
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Kent Johnson gives false testimony under oath at a hearing in municipal court.
349. On July 26, 2023, a civil-protection order hearing was conducted before a visiting judge in
Ottawa Municipal Court. This was an official proceeding under Ohio law.
350. During that hearing, Johnson tried to recharacterize his sexual comments to Ms. Huskey—
the young woman who viewed him as a dad—as “station banter.”
351. He admitted he made comments about her toes looking “good.”
352. He falsely claimed that when an unnamed “dispatcher” came in to have her I Am Responding
App reset, Ms. Huskey had told him, “If you give her any attention, I’ll scratch her eyes out.” This
was a complete fabrication.
353. Johnson’s counsel asked him, “And during that time, the testimony was that you showed up
at—at least in her affidavit, she testified that ‘Johnson showed up at my home, harassed me, groped
me by rubbing my shoulder, thighs, and forcibly kissing you—my face’; is that true?”
354. In that moment, Johnson dodged directly answering that question. He did not say “no.”
355. Johnson’s counsel asked him point blank, “So, when she testified that, in August 2022, the
bay lockers, you brushed up against her, you kissed her shoulders and back, and told her, ‘I’m crazy
about you.’ Did you do any of those things?”
356. Johnson admitted that “it’s a possibility that she brushed up against [me],” blaming the space
configurations.
357. He falsely denied making multiple sexual comments to her that he made orally, as alleged
above.
358. He falsely denied sexually assaulting her.
359. He admitted he “probably g[a]ve her a neck rub or something like that.”
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360. He admitted, “I did grab her by the ears” and kissed her, but claimed falsely that it was
because she had said she was on her period. (Even if she were on her period, she did not need her
boss kissing her because of that.)
361. He admitted that he had told her, “I’ll stop picking on you.”
362. He admitted sending her the text messages above, including beckoning her to put N95
masks down her pants “for a while” before giving them and then apologizing for being “crude.”
363. Preposterously, he denied that “crude” meant “sexual” in any way.
364. In general, he lied his way through the hearing.
365. And he didn’t disclose to that court, Ms. Huskey, or his well-wishers in attendance that he
had secretly taken and kept photos of Ms. Huskey’s intimate images. He didn’t even claim to have
been “investigating” her.
Chief Johnson submits to two formal interviews by the City’s outside investigator—and lies
persistently, while also making key admissions.
366. Johnson was interviewed twice by the City’s assigned outside investigator. These, too, were
official proceedings and an official investigation under Ohio law. In both interviews, Johnson made
multiple false and misleading statements about Ms. Huskey. Some of those are noted here.
367. The first interview was on September 7, 2023.
368. When the investigator asked if he made any sexual comments to Ms. Huskey, Johnson lied,
“Anything that I would have said to her was in response to her inappropriate comments.” That was
false and defamatory, as the above text-message threads show by example. Ms. Huskey simply did
not initiate, instigate, or provoke her father-figure Johnson’s sexual overtures.
369. In that same interview, Johnson claimed, “After she first hired [sic], she came running into
my office with her cellphone show me a TikTok about relationships with young girls and old men,
‘This could be us.’”
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370. This, too, was a complete fabrication. He repeated this foul falsehood again later in the
interview, in response to a question about whether Ms. Huskey ever suggested she was romantically
pursuing him.
371. In truth and in fact, Ms. Huskey didn’t even download the TikTok app or have a TikTok
account until around the time she reported his harassment in mid-2023. Indeed, until relatively
recently, she owned a flip phone.
372. He completely made this up this defamatory story about adulterous, intergenerational sexual
interest in him by a young woman who viewed him as a dad or uncle. It never happened. Nothing
even like it happened.
373. Johnson also falsely claimed that Ms. Huskey had been nude from the waist up in front of
others while working. This, too, was a lie.
374. Johnson admitted that he grabbed Ms. Huskey’s head by the ears and kissed her on the lips.
375. Johnson said, about the April 23, 2023 incident in which he drove Ms. Huskey back alone in
his truck, that he said in the fire station, “Gee, I never ever thought the first date would be towing
an ambulance.”
376. He falsely accused Ms. Huskey of being “delusional.”
377. As for looking at her cellphone ostensibly to look at the “I Am Responding” app, Johnson lied
to the City’s outside investigator, “I don’t remember looking at other things on it.”
378. As he then-well knew, he had taken photographs on his own phone of intimate personal
images of her stored on her phone, and had stored them in his Google cloud for his lascivious
access. He never disclosed this in the interview.
379. No. Instead, he just lied: “No, I wasn’t searching her phone. Why would I?”
380. Why would he, indeed.
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381. The truth had to come out via a formal criminal investigation by the Ohio Bureau of
Criminal Investigation, which found he had transferred those images to Google cloud on September
1, 2022. And then—caught—he falsely blurted in response to unexpected questioning that he had
been “investigating” Ms. Huskey.
382. There is no official—or even unofficial—record of any such “investigation.”
383. Cockamamie as Johnson’s explanation was when law enforcement confronted him about the
images he had stolen, he should have disclosed that to the City’s investigator—not lie to her that
didn’t search Ms. Huskey’s phone.
384. Seeking to justify his reassignment of Ms. Huskey to secretarial duties, Johnson falsely stated
in that interview that Ms. Huskey had not provided him with return-to-work authorization with no
restrictions. As the embedded physician’s letter above shows, she had.
385. But Johnson admitted that Ms. Huskey wasn’t happy about him reassigning her from her
service as a firefighter/EMT. That much was true.
386. In a second interview on October 31, 2023, the investigator confronted Johnson with
documentary evidence that he had been misreporting Ms. Huskey’s working hours.
387. He repeatedly falsely accused her of “stealing time”—theft from the City—when, in truth
and in fact—and unbeknownst to Ms. Huskey—he had knowingly misreported her hours in close
synchronization with his predatory behavior toward her. This is something she neither wanted, nor
asked for. But it was part of his grooming of her and consciousness of guilt, with each act of hours
non-reporting and false reporting being an admission he had just done something he knew was
wrong. Examples are provided later, below.
388. He also admitted in that interview that he had ordered Ms. Huskey to stop calling Rachel
Klimentov, deputy city auditor.
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389. By that second interview, Johnson’s story about Ms. Huskey had evolved. He falsely
suggested she was a “flirtatious little girl that was going around to all the guys.” He claimed, “She
came onto me. She came and I played back.”
390. These were lies. Defamatory, sick lies.
391. He continued to blame his victim with falsehoods: “[S]he came up to me with a TikTok of
an old man and a young girl. This is us. This could be us.”
392. “This is us” was a new baseless accusation.
393. He falsely portrayed Ms. Huskey as a hussy: “You know, and she come in dressed the way
she was dressed.”
394. He admitted that he “continued to mention her toes.”
395. He admitted that the text messages he sent to Ms. Huskey were inappropriate from a fire
chief to an employee.
The City’s outside-investigating firm issues a report finding that Chief Johnson sexually
harassed Ms. Huskey and engaged in financial theft from the City—but the City fails
entirely to address her most serious allegations of serial sexual assault.
396. In a December 15, 2023 report delivered to the law director, the City’s outside investigator at
the firm of Clemans Nelson issued fact findings that Johnson had “engaged in the sexual harassment
of Ms. Huskey when he sent unwelcome or offensive written communications of sexually suggestive
material to Ms. Huskey.” The report also found that Johnson “had neglected to ensure that Rebekah
Huskey was properly paid for her work hours by both over and under compensating her.” And the
report found that Johnson “had intentionally overpaid Ms. Huskey” from December 2022 through
June 22, 2023.
397. (These were overpayments based on her lower overall compensation as personal secretary
and did not make up for what she lost from being denied reinstatement as a firefighter EMT.)
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398. The City and its outside investigator never addressed Johnson’s serial sexual assaults and
foul, sexual statements to her; his sex and pregnancy discrimination toward her; or his intrusion into
her phone and theft of her intimate personal photos.
Johnson’s submission and maintenance of false payroll records about Ms. Huskey tracked
his guilt about his misconduct.
399. As mentioned above, a review of city pay records reveals that Johnson’s false reporting of
Ms. Huskey’s working hours tracked and related to his acts of sexual harassment and assault as
catalogued above.
400. He would sometimes falsely fail to report days she worked, which were also days on which,
or close to days on which, he sexually assaulted her. And then he would—as he was saying he would
stop picking on her and blaming his unhappy life—falsely report hours she didn’t work.
401. For example, in February 2023, after she returned to work from her back surgery and
Johnson reassigned her to be his personal secretary, Johnson’s sexually harassing comments
occurred often. On February 1, 4, 9, and 10, Ms. Huskey did not work. Yet, as he was pursuing her,
Johnson paid her one, five, three, and three hours, respectively, on those days.
402. On February 20, 2023, Ms. Huskey worked five hours. That was likely the date of the
storage-room incident described above, in which Johnson, came up behind her, told her he was
proud of her and loved her, grabbed her shoulder, kissed her face, rubbed his hands down her back
toward her buttocks, and then said, “I’m done picking on you.”
403. But Johnson did not report that she worked. Ms. Huskey worked six hours the next day,
February 21. But Johnson failed to report she worked that day, too.
404. On February 22, Ms. Huskey did not work. Yet Johnson compensated her for five hours.
And on February 23, she did not work, but he compensated her for seven hours.
405. He was trying to show that she wasn’t there when he groped her. And then give her
gratuities as he was feeling or expressing regret for his behavior. These were admissions.
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406. On about March 7, 2023, Ms. Huskey worked three hours. But Johnson, feeling guilty about
his conduct, compensated her for six. This was likely the date of the incident where, under the guise
of showing her the new lockers, he tried to get her to touch his penis.
407. Throughout that month, Johnson did not accurately report her hours—sometimes not
reporting she worked at all, sometimes underreporting her hours, sometimes overreporting her
hours, and sometimes boosting her sick leave rather than paying her wages for hours she actually
worked.
408. March 27, 2023 was likely the date of the incident in which Johnson insisted she come look
at the new lockers, grabbed his penis through his pants and said it was “hard” because Ms. Huskey
“looked very sexy today,” asked her to touch his it, and tried to move her hands toward it.
409. Ms. Huskey worked 12 hours that day, but Johnson failed to report her working at all.
410. April 14, 2023 was likely the day when Johnson came in to the storage room, pushed Ms.
Huskey up against a sink, rubbed his groin into her, asked her repeatedly if she “squirts” and said “I
bet you squirt,” grabbed her buttocks and commented on them, said, “I’m done picking on you,”
said she’s “gorgeous” and that he “love[s] this fat ass,” and grabbed the area between her buttocks
and her vagina.
411. Again, she worked for 12 hours that day, but again, Kent Johnson didn’t report she worked.
412. April 28, 2023 was likely the day the ambulance broke down, Johnson insisted she be in his
vehicle, tried to hold her hand, and called it a “date.”
413. But the records that she worked that day or from April 24–May 1 seem to have disappeared.
414. May 23, 2023 was the day of the final-straw incident where Johnson ran his hand up her leg
to her vagina, causing her to flee to the smokehouse, experience paralyzing terror, urinate on herself,
and then leave.
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415. She worked for six hours that day. But he submitted 12 hours for her. He paid her for 12
hours the next day when she didn’t work. And he paid for 12 hours on May 26 after she went to the
hospital, losing her pregnancy. He did these things because he knew (and later admitted to her at her
home) that what he did was wrong and he had gone too far, falling over himself (yet again) to
apologize and claim he would stop.
The City fires Johnson, and he tries to stay on the payroll through June 1, 2024 despite the
findings against him of sexual-harassment and theft in office.
416. Following a pre-disciplinary notice and opportunity to respond, the City fired Johnson on or
about January 18, 2024.
417. Johnson, as of this filing, is appealing through the City’s civil-service process. He received
three days of public hearings with a fourth scheduled for June 14, 2024. These are official
proceedings under Ohio law.
418. During the hearing, he continued to falsely deny and otherwise lie about his conduct with
Ms. Huskey and about Ms. Huskey’s conduct. He is expected to lie even more on the anticipated
fourth day of hearing on June 14, 2024.
419. During the third day of hearing on May 17, 2024, it was publicly revealed for the first time
that in non-public discussions, Johnson—despite the findings against him of sexual harassment and
financial impropriety—through his counsel demanded that he be allowed to work and retire on June
1, 2024, to help him reach age 65—the age of Medicare eligibility—and boost his pension. Johnson’s
counsel threatened the City’s safety-service director and law director with personal lawsuits if they
didn’t allow this.
Ms. Huskey returns to work—but is immediately engulfed in a retaliatory and hostile work
environment that City officials fail to stop.
420. Ms. Huskey returned to work on February 17, 2024.
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421. She immediately experienced a hostile and retaliatory work environment and ostracism by
many coworkers—including Assistant Fire Chief Charles Zillman—who behaved as though they
were members of a Kent Johnson cult.
422. The retaliation was for her opposition to the sexual harassment and sex discrimination she
had experienced and her participation in having made a charge, testified, assisted, or participated in
any manner in investigations, proceeding, or hearing under Title VII, the Ohio Civil Rights Act, and
for filing this lawsuit alleging discrimination.
423. People spoke negatively about her within earshot. When she entered a room, people made a
big show of getting up and leaving. And the hostility extended beyond the fire department to other
fellow first responders. When she was on service calls, some Port Clinton police officers—essential
first responders for her to work with—would neither talk to nor look at her. A coworker at the fire
station falsely claimed she was a threat to the fire department and would report anyone who brushes
up against her.
424. Because of the hostile environment, she couldn’t sleep at night when she was on
firefighting/EMT shift at the fire department. (Firefighters sleep while at the station overnight.)
425. In short, she went from being worried about one person—Kent Johnson—to now far more
in the department. She was constantly shaking, looking over her shoulder, and unable to breathe
during her work shifts.
426. What follows are examples of what occurred.
February 6, 2024—Firefighters’ Association Meeting
427. During the February 6, 2024, firefighters’ association meeting, several fire-department
members openly expressed anger over Johnson’s termination and the announcement that Ms.
Huskey would be returning to work.
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428. Some demanded that Ms. Huskey should be fired and wanted to know why she wasn’t in
trouble. When City leaders stated that Ms. Huskey would return to service, several people expressed
anger at this and walked out of the meeting.
429. City leaders failed to discipline these people for their retaliatory hostility toward Ms. Huskey.
February 15, 2024—Re-entry counseling session with Alice Randolph, clinical psychologist,
as mandated by the City of Port Clinton
430. During a city-mandated counseling session on February 15, 2024, city-appointed
psychologist Alice Randolph, Ed.D. advised Ms. Huskey that her return to work would be
“awkward” for her and “awkward for everyone else.” She told Ms. Huskey she needs to respect
“everyone’s space and their personal thoughts,” and told her that other employees should be able to
express their thoughts to help the department move on.
431. Dr. Randolph never acknowledged that such expressions could create a retaliatory and
hostile working environment for Ms. Huskey following her reporting of sexual assault and
discrimination by Johnson. This interaction deeply troubled Ms. Huskey.
432. Johnson admitted in investigative interviews by the City’s outside investigative firm of
Clemans Nelson that he sees this same therapist. Dr. Randolph never acknowledged the conflict of
interest, which she never should have embraced.
433. Given this plain conflict of interest, the City should have never required Ms. Huskey to
speak with the same psychologist.
434. Ms. Huskey told Dr. Randolph that she is more comfortable talking to her own therapist.
February 21, 2024—Coworker spies on Ms. Huskey
435. On February 21, 2024, when Ms. Huskey was on the phone with her mother at the firehouse
in the women’s locker room, she opened the door to the kitchen, and found that coworker Isabella
Knowlton had been listening at the door. Caught, Knowlton bolted, saying nothing.
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February 24, 2024—Shift interaction
436. On February 24, 2024, Ms. Huskey, expecting a child, experienced an episode of morning
sickness. She vomited in the ambulance bay during truck checks. Coworker Isabella Knowlton saw
this and asked Ms. Huskey if she was sick with influenza. Ms. Huskey told Ms. Knowlton that she is
pregnant and in the middle of her first trimester.
437. After concluding truck checks, Ms. Huskey returned to the common space and walked into a
conversation where her name was being used. She overheard Knowlton saying to someone on the
phone, “Yeah, she’s claiming she’s pregnant and I don’t believe that either.”
438. The “either” referred to Ms. Huskey’s reports of sexual assault and harassment.
March 14, 2024—911 call with Port Clinton police department
439. On March 14, 2024, at about 8:40 PM, during a mutual-assistance EMS call where Port
Clinton police officers were on scene before EMS arrived, Ms. Huskey asked on-scene Port Clinton
Officer Amy Pugh about the patient’s condition and events leading to the 911 call. Officer Pugh, a
friend of the Johnson family, refused to respond to Ms. Huskey and intentionally ignored her
important questions related to essential patient care.
440. And it wasn’t just Officer Pugh. Other Port Clinton police officers treated Ms. Huskey the
same way. She doesn’t know their names.
441. This was unprofessional and unacceptable. It was retaliation for Ms. Huskey’s opposition to
Johnson’s conduct and participation in proceedings related to it. Cooperation by other first
responders was essential to Ms. Huskey performing her public-service job.
Before Kent Johnson’s Civil Service Commission appeal hearing
442. Mr. Krupp, the most senior fire-department member, reported to the station with a
firefighter boot full of old decorations and announced loudly to B-shift, fire-department members
Dana Brown, Jodie Brown, Tom Sees, and Kevin Pealquin, “The city needs to reinstate Kent
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Johnson immediately” and that he would be “damned if he was going to be retired by acting chief
Brian Gutman.”
March 19, 2024—Kent Johnson’s Civil Commission appeal
443. On March 19, 2024, several fire-department members showed up to Kent’s civil-service-
appeal hearing and sat on his side of the aisle. This included the Chief of Police David Scott. Active
fire-department members present included Trevor Johnson, Tom Krupp, Keith Conte, Jim Crow,
Dan Meizner, Brock Rider, and Assistant Fire Chief Charles Zillman.
444. All these members engaged in jovial conversation with Johnson and the commissioners
themselves before and throughout breaks in the appeal hearing.
445. During Ms. Huskey’s testimony, several members were making snide remarks, gestures, and
noises expressing their contempt for her.
446. Carl Koebel is one of the civil-service commissioners who—despite his responsibility for
sitting in judgment—chatted with Johnson. He is the father of David Koebel, a fire-department
member who testified for Johnson at Johnson’s civil-protection-order hearing (calling Ms. Huskey’s
allegations “silly,” and who, according to Johnson’s own testimony at the civil-service hearing, went
to warn Johnson before he was placed on leave that Ms. Huskey is “coming after you”). And, as
detailed below, David Koebel actively created the retaliatory atmosphere against Ms. Huskey.
447. Still, the City permitted Carl Koebel to serve as a commissioner during the hearing and do so
in a manner that was contemptuous of Ms. Huskey. When Ms. Huskey was testifying and would
look at the civil-service commissioners, Carl Koebel shook his head to express “no.” Koebel also fell
asleep several times during Ms. Huskey’s testimony, which others in attendance saw. Koebel showed
a level of total indifference to Ms. Huskey’s plight.
448. When the appeal hearing ended, the law director tried to retrieve the evidence, and Mr.
Koebel became defensive and refused to turn over a stack of papers, saying that it was his own
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information and evidence he printed from his personal computer to bring to the hearing. He should
have relied only on testimony and evidence presented in the hearing instead of his own, mysterious
evidence.
449. In any government with a shred of integrity, Carl Koebel’s close family relationship with an
outspoken Johnson supporter, witness, named player in testimony, and participant in retaliation
would be a basis for mandatory recusal.
450. But not in Port Clinton.
451. Even a letter from Ms. Huskey’s counsel detailing Carl Koebel’s misconduct with a
supporting affidavit from Ms. Huskey’s sister and noting that the mayor, under Ohio law, could
remove Koebel for malfeasance did not spur officials to cure the problem. Koebel stayed.
March 20, 2024—Follow-up mandated counseling session with Dr. Alice Randolph
452. During another, March 20, 2024, city-mandated counseling session, Ms. Huskey advised Dr.
Randolph that she wasn’t happy at work and felt stressed. She said she felt she was being treated
differently and was upset knowing that fire-department members were ignoring her and refusing to
serve the community because of her presence.
453. Dr. Randolph suggested Ms. Huskey “was just being overly sensitive.”
454. Ms. Huskey told this therapist that she shouldn’t be this sad and scared while she’s at work
and stated it is very difficult for her to sleep on duty during her 24-hour shift because she always
feels on edge and that she must look over her shoulder. Ms. Huskey reported that people are
passive-aggressive with her. She also reported she went from fearing one person at the station to
now fearing several people.
March 24, 2024—Fire Department refused to show up for third-squad EMS call
455. On March 24, 2024, at about 2:09 AM, the fire department had no available personnel for a
third 911 EMS call because all ambulances were on other calls. Ms. Huskey’s C-shift, through
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dispatch, three times called for help from the fire department. Danbury EMS had to cover the 911
call, because no Port Clinton fire personnel responded while Ms. Huskey was on duty.
456. This sort of thing never happened before Ms. Huskey opposed discrimination and
participated in proceedings related to it.
457. Kent Johnson’s retaliatory cult jeopardized public safety. Ms. Huskey could not bear this.
458. It also put her own safety in jeopardy.
Other incidents.
459. While Ms. Huskey was on administrative leave, her fiancé saw Trevor Johnson (Kent
Johnson’s son and a firefighter) speaking to a group of firefighters on a Tuesday night while
everyone was waiting out in the ambulance bay. He overheard the tail end of Trevor Johnson’s
comments, “That’s what we think—because IVF is so expensive, they need the money.”
460. This was a reference to Ms. Huskey’s ectopic pregnancy, falsely claiming a need for
expensive fertility treatments.
461. Shortly after Ms. Huskey’s return to work, Acting Fire Chief Brian Gutman confirmed to
Ms. Huskey’s fiancé that people had their own suspicions about why Ms. Huskey “tattled” on Kent
Johnson.
462. Fire-department members openly discussed that a majority of active paid and volunteer fire-
department members refuse to show up to emergency calls because of Kent Johnson’s termination
and demanded Ms. Huskey’s firing as a bargaining chip for return to service. Even Acting Chief
Brian Gutman confirmed this to her. Overall fire-department training, emergency response, and
participation markedly decreased following Johnson’s firing and Ms. Huskey’s return to her position.
463. Fire-department member David Koebel advised Acting Chief Brian Gutman and paramedic
Julie Caponi that he refused to respond to calls as long as Ms. Huskey was employed. He claimed he
doesn’t want to be accused of sexual assault and by working with Ms. Huskey he supposedly risks
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that. Koebel also told fire-department members that when he did come in, if he saw Ms. Huskey’s or
her fiancé’s vehicles at the station on the way to a call, he would turn around.
464. Acting Chief Brian Gutman acknowledged that other members were refusing to serve the
community because of their allegiance to Johnson and expressed his disappointment with members’
behavior towards Ms. Huskey.
465. Ms. Huskey expressed to Acting Chief Gutman that she was trying to fly under the radar as
much as possible to minimize the palpable tension at the station.
466. Although he tried to be reassuring, Gutman acknowledged that some members are fervent in
their support for Johnson, even if it means flouting their duty to serve the community.
467. But no City official held fire-department members accountable for their retaliatory
misconduct.
468. Ms. Huskey habitually greeted everyone with a “hello” at the shift change.
469. Fellow firefighter/EMT Jodie Brown vocally expressed “ugh” at Ms. Huskey’s salutation.
470. Assistant Fire Chief Charles Zillman refused to acknowledge or respond to Ms. Huskey and
would not acknowledge her presence. Sometimes, he looked at the floor and shook his head in a
“no” gesture as she walked by.
471. In any normal work environment, a department leader like Zillman would be held
accountable for such blatant retaliation.
472. But Port Clinton hasn’t.
473. Given these circumstances and the intolerable working environment, the City of Port
Clinton constructively discharged Ms. Huskey.
474. Adding to her injury, the City never addressed her allegations of serial sexual assault by
Johnson. The City’s avoidance left her even more exposed to the retaliatory atmosphere she
experienced, which built and built.
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475. Ms. Huskey submitted her involuntary resignation because of constructive discharge on
March 27, 2024, providing two weeks’ notice. Her dream of being a firefighter/EMT—and of
carrying on and passing forward the family heritage—was dead.
476. The way Ms. Huskey was treated devastated the whole family, too. The risk of the retaliation
spreading—and the safety risks presented by angry fellow first responders who might not protect
them in an emergency—were too much to bear. After nearly 20 years of service as a Port Clinton
firefighter, her father resigned on April 24, 2024. And one day later, so did Ms. Huskey’s sister.
City policies, procedures, and practices were deficient.
477. Port Clinton’s personnel manual provides no instructions about bypassing a harassing
manager to report sexual harassment. It also includes no explicit assurances that the safety-service
director’s designee (here the fire chief) can be bypassed when reporting that designee’s sexual
harassment.
478. Chief Johnson and the City never provided Ms. Huskey and her fellow fire-department
members with a personnel manual that would educate them on what to do if were sexually harassed
or faced discrimination. Johnson was even annoyed at the thought of having to provide sexual-
harassment training.
479. Port Clinton’s fire department was far removed from the city’s higher management. Johnson
operated the fire department as his own organization. When employees reached out to city officials,
Johnson was notified, and employees were often sent back to him.
480. Johnson had primary discretion over the department’s personnel decisions, and city-
management officials weren’t a regular fixture of the fire-department employees’ lives. Because the
fire department and Ms. Huskey were effectively isolated from city management, the city provided
no sensible complaint procedure that specifically included how to bypass supervisors like Johnson
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when reporting, and Johnson discouraged her from having any contact with central administration,
Ms. Huskey, as a practical matter, had no one to whom she knew to report Johnson’s harassment.
481. David Koebel failed to report Ms. Huskey’s report of sexual harassment to Safety Service
Director Tracy Colston or any other city official in a position to do anything about it. Instead, his
first impulse was to snitch to the accused, Chief Johnson.
482. Captain Brian Gutman had no idea what to do when Ms. Huskey reported Johnson’s sexual
harassment to him and had to ponder the issue for some time before acting. Indeed, when Ms.
Huskey offered to show him the harassing text messages, he declined to see them.
483. Even the safety-service director and law director’s approach to their June 6, 2023 paid-
administrative-leave meeting with Johnson was hardly a model of probity and neutrality.
Ms. Huskey timely and dually files EEOC/Ohio Civil Rights Commission charges and
receives right-to-sue letters.
484. Ms. Huskey timely dually filed a charge with the Equal Employment Opportunity
Commission and Ohio Civil Rights Commission on July 21, 2023, and received her right-to-sue
letter from the U.S. Department of Justice (responsible for such letters in matters involving
governments) on February 29, 2024.
485. Ms. Huskey dually filed a supplemental retaliation charge with the Equal Employment
Opportunity Commission and Ohio Civil Rights Commission on or about March 27, 2024 and
received her right-to-sue letter from the U.S. Department of Justice on April 8, 2024.
486. The original , the first amended and supplemental complaint, and this second amended and
supplemental suit were all timely filed.
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CLAIMS
CLAIM 1
DENIAL OF EQUAL PROTECTION UNDER THE FOURTEENTH AMENDMENT (SEX
DISCRIMINATION IN THE FORM OF SEXUAL ASSAULT, HARASSMENT, JOB REASSIGNMENT, AND
PAY REDUCTION) AGAINST THE CITY OF PORT CLINTON AND DEFENDANT KENT JOHNSON
AND FOR FAILURE TO TRAIN AND SUPERVISE, UNDER 42 U.S.C. § 1983,
AGAINST DEFENDANT CITY OF PORT CLINTON
487. Plaintiff incorporates all previous allegations.
488. Ms. Huskey has a right, protected by the Fourteenth Amendment’s equal-protection clause,
to be free from invidious discrimination based on sex in public employment.
489. As detailed above, Ms. Huskey suffered purposeful or intentional discrimination including,
but not limited to, sexual assault, sexual harassment, unwanted job reassignment, and reduced
overall compensation from what she used to and had the potential to receive as a firefighter and
EMT.
490. As detailed above, Defendants, acting under color of law, violated Ms. Huskey’s
constitutional right to be free from sex discrimination.
491. Ms. Huskey’s right to be free from sex discrimination in employment was clearly established
and any reasonable public employee or official would have known of that.
492. Defendant Johnson’s sexual assaults and sexual harassment of Ms. Huskey, along with his
illicit taking photographs of her personal intimate images, was discrimination against her because of
her sex, as was Johnson’s unwanted job reassignment of her and failure to reinstitute her to her
firefighter and EMT duties, and the other acts detailed above.
493. As fire chief, Defendant Johnson was Ms. Huskey’s supervisor and controlled the terms and
conditions of her public employment.
494. As fire chief, Defendant Johnson was a final decisionmaker and policymaker for Defendant
City of Port Clinton’s fire department, acting under color of law. City of Port Clinton effectively
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delegated complete authority to him over his department, including the handling of personnel and
sexual-harassment issues.
495. Defendants’ conduct was objectively unreasonable given Ms. Huskey’s clearly established
constitutional right to be free of sex discrimination, sexual harassment, sexual assault, and invasions
of personal privacy.
496. Defendant City of Port Clinton was engaged in a custom, policy, pattern, and practice of
constitutional violations.
497. As a direct and proximate result of Defendants’ unlawful conduct, Ms. Huskey’s has suffered
and will continue to suffer damages for which Defendants are liable.
498. Defendants’ acts were willful, egregious, malicious, and worthy of substantial sanction to
punish and deter them and others from engaging in this type of unlawful conduct.
CLAIM 2
VIOLATION OF SUBSTANTIVE DUE PROCESS UNDER THE FOURTEENTH AMENDMENT FOR
SEXUAL ASSAULT AND FOR SUPERVISORY LIABILITY UNDER 42 U.S.C. § 1983
AGAINST DEFENDANTS CITY OF PORT CLINTON AND KENT JOHNSON
499. Plaintiff Huskey incorporates all previous allegations.
500. Ms. Huskey has a substantive right to bodily integrity and privacy, protected by the
Fourteenth Amendment’s due-process clause, to be free from sexual assault by a local-government
official, her supervisor.
501. As detailed above, Ms. Huskey suffered purposeful or intentional discrimination based on
sex by Defendant Johnson’s sexual assaults. This violated her constitutional right to substantive due
process.
502. Ms. Huskey’s right to be free from sexual assault was clearly established and any reasonable
public employee or official would have known about that.
503. As fire chief, Defendant Johnson was Ms. Huskey’s supervisor and controlled the terms and
conditions of her public employment.
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504. As fire chief, Defendant Johnson was a final decisionmaker and policymaker for Defendant
City of Port Clinton’s fire department, acting under color of law.
505. Defendants’ conduct was objectively unreasonable given Ms. Huskey’s clearly established
constitutional rights.
506. Defendant City of Port Clinton was engaged in a custom, policy, pattern, and practice of
constitutional violations.
507. As a direct and proximate result of these actions, Ms. Huskey has suffered and will continue
to suffer economic and non-economic damages for which Defendants are liable, including, but not
limited to, pain and suffering; emotional distress; and the loss of salary, wages, and benefits, and
other terms, privileges, and conditions of employment.
508. Defendants’ acts were malicious, in bad faith, performed in a wanton and reckless manner,
willful, egregious, and worthy of substantial sanction to punish and deter them and others from
engaging in this type of unlawful conduct.
CLAIM 3
SEX DISCRIMINATION AND SEXUAL HARASSMENT (HOSTILE WORK ENVIRONMENT) UNDER
TITLE VII OF THE CIVIL RIGHTS ACT OF 1964, 42 U.S.C. § 2000E-2(A)(1)
510. Under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1), it is an unlawful
employment practice for an employer to discriminate against its employees based on an individual’s
sex.
511. Under 42 U.S.C. § 2000e, et seq., whoever violates the above-described legal obligation is
subject to a civil action for damages, injunctive relief, or any other appropriate relief.
512. Ms. Huskey’s right to be free of disparate treatment while employed by Defendant is
protected under Title VII.
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513. Defendant City of Port Clinton intentionally and maliciously discriminated against Ms.
Huskey by permitting Chief Johnson to sexually harass and assault her severely and pervasively, and
by maintaining an environment indifferent to sexual harassment, as described in the factual narrative
above.
514. Johnson also changed her job duties and curtailed her service to the public as a
firefighter/EMT, against her desires. In general, he treated her differently than men, as detailed
above.
515. Defendant failed to take appropriate steps to prevent or remedy Chief Johnson’s behavior,
as described in the factual narrative above.
516. As a direct and proximate result of these actions, Ms. Huskey has suffered and will continue
to suffer economic and non-economic damages for which Defendant is liable, including, but not
limited to, pain and suffering; emotional distress; and the loss of salary, wages, and benefits, and
other terms, privileges, and conditions of employment.
517. Defendant’s acts were malicious, in bad faith, performed in a wanton and reckless manner,
willful, egregious, and worthy of substantial sanction to punish and deter it and others from
engaging in this type of unlawful conduct.
CLAIM 4
SEX DISCRIMINATION AND SEXUAL HARASSMENT (HOSTILE WORK ENVIRONMENT) AND
UNDER OHIO REV. CODE § 4112.02(A)
519. Ohio Rev. Code § 4112.02(A) makes it an unlawful discriminatory practice for any employer,
because of the sex of any person, to discharge without just cause, to refuse to hire, or otherwise to
discriminate against that person with respect to hire, tenure, terms, conditions, or privileges of
employment, or any matter directly or indirectly related to employment.
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520. Chief Johnson’s sexually charged comments, sexual advances, sexual assaults, and other
sexual harassment of Ms. Huskey were unwelcome and created an intimidating, hostile, and
offensive work environment.
521. Chief Johnson’s sexual harassment of Ms. Huskey was based on her sex.
522. Chief Johnson’s sexual harassment was severe and pervasive enough to affect the terms,
conditions, and privileges of employment. As described above, Ms. Huskey experienced severe
anxiety and emotional distress because of the sexual harassment and assaults she experienced. She
experienced severe trauma and betrayal syndrome and needs counseling because of Johnson’s
harassment and assaults.
523. Chief Johnson even changed her job duties and curtailed her service to the public as a
firefighter/EMT, against her desires. In general, he treated her differently than men, as detailed
above.
524. As a direct and proximate result of Defendant’s unlawful conduct, Ms. Huskey has suffered
and will continue to suffer economic and non-economic damages for which Defendant is liable,
including, but not limited to, pain and suffering, the loss of salary, wages, and benefits, and other
terms, privileges, and conditions of employment.
CLAIM 5
CIVIL ACTION RELATING TO DISCLOSURE OF INTIMATE IMAGES FOR DAMAGES AND
INJUNCTIVE RELIEF, UNDER 15 U.S.C. § 6851 AND 42 U.S.C. § 1983,
AGAINST DEFENDANTS KENT JOHNSON AND CITY OF PORT CLINTON
525. Plaintiff Huskey incorporates all previous allegations.
526. Title 15 U.S.C. § 6851(b)(1)(A) establishes a federal civil cause of action by
an individual whose intimate visual depiction is disclosed, in or affecting interstate or foreign

commerce or using any means or facility of interstate or foreign commerce, without
the consent of the individual, where such disclosure was made by a person who knows that,
or recklessly disregards whether, the individual has not consented to such disclosure, may
bring a civil action against that person in an appropriate district court of the United States
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for actual damages or liquidated damages of $150,000 and injunctive relief, along with the costs of
the action including reasonable attorney fees and litigation costs.
527. Title 15 U.S.C. 6851(a) defines key terms in the statute that apply here:
(2) Consent
The term “consent” means an affirmative, conscious, and voluntary authorization made by
the individual free from force, fraud, misrepresentation, or coercion.
(3) Depicted individual
The term “depicted individual” means an individual whose body appears in whole or in part
in an intimate visual depiction and who is identifiable by virtue of the person’s face, likeness,
or other distinguishing characteristic, such as a unique birthmark or other recognizable
feature, or from information displayed in connection with the visual depiction.
(4) Disclose
The term “disclose” means to transfer, publish, distribute, or make accessible.
(5) Intimate visual depiction
The term “intimate visual depiction”—
(A) means a visual depiction, as that term is defined in section 2256(5) of title 18,
that depicts—
(i) the uncovered genitals, pubic area, anus, or post-pubescent female nipple of
an identifiable individual; …
***
528. Title 15 U.S.C. § 6851(b)(2) clarifies that “the fact that the individual consented to the
creation of the depiction shall not establish that the person consented to its distribution” (15 U.S.C.
§ 6851(b)(2)(A)) and “the fact that the individual disclosed the intimate visual depiction to someone
else shall not establish that the person consented to the further disclosure of the intimate visual
depiction by the person alleged to have violated paragraph (1).” (15 U.S.C. § 6851(b)(2)(B).)
529. Ms. Huskey had intimate visual depictions of herself on her phone.
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530. Chief Johnson, under color of law as Ms. Huskey’s government supervisor ordering her to
unlock and give him access to her iPhone, violated 15 U.S.C. § 6851(b)(1)(A)’s prohibition against
disclosing these intimate visual depictions of a depicted individual by disclosing—that is transferring,
using his cellphone camera from Ms. Huskey’s phone to Google cloud, publishing the photos to his
Google cloud, and making the photos accessible to himself repeatedly in the months after
transferring the photos—in or affecting interstate or foreign commerce and using any means or
facility of interstate or foreign commerce, without Ms. Huskey’s consent, and knowing that, and
recklessly disregarding whether, Ms. Huskey had not consented to his disclosure.
531. Defendant Johnson is liable to Ms. Huskey for actual damages or liquidated damages of
$150,000 and equitable relief.
532. Defendant Johnson was a final policymaker for the City of Port Clinton acting under color
of law. The City failed to train and supervise him. The City delegated total authority over his
department to Defendant Johnson. Thus, the City is also liable for Defendant Johnson’s federal
statutory violation under 15 U.S.C. § 6851 under 42 U.S.C. § 1983.
punish and deter Defendants and others from engaging in this type of unlawful conduct. His acts
also merit injunctive relief.
CLAIM 6
RETALIATION UNDER CIVIL RIGHTS ACT, TITLE VII, 42 U.S.C. § 2000E-3(A)
535. Under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-3(a), it is an unlawful
employment practice for an employer to discriminate (retaliate) against its employees because
she opposed an unlawful discriminatory practice or because she made a charge or participated in
any way in an EEOC proceeding.
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536. Under 42 U.S.C. § 1981a and 42 U.S.C. § 2000e, et seq., whoever violates the above-
described legal obligation is subject to a civil action for damages, injunctive relief, or any other
appropriate relief.
537. Ms. Huskey had a reasonable, good-faith belief that she has experienced sexual
harassment and assault and complained about this unlawful practice.
538. Ms. Huskey engaged in protected activity under Title VII by opposing this harassment,
by complaining internally, by filing a charge of discrimination with the EEOC and OCRC, and
by filing this lawsuit.
539. She also engaged in protected activity under Title VII by opposing discrimination
(retaliation for opposing sex discrimination) internally and by filing a charge of discrimination
with the EEOC about the retaliation she faced for opposing discrimination.
540. The City intentionally and maliciously discriminated against Ms. Huskey after she
opposed an unlawful discriminatory practice, and tolerated such concerted retaliation by its
employees.
541. The retaliation changed the terms and conditions of Ms. Huskey’s employment and
subjected her to adverse employment actions.
542. The retaliation Ms. Huskey suffered would dissuade a reasonable worker from opposing
discrimination.
543. The City is vicariously liable for its agents’ acts toward Ms. Huskey. Kent Johnson was the
city’s agent as fire chief. The fire department and police department employees who retaliated
against her were also City agents.
544. As a direct and proximate result of this unlawful conduct, Ms. Huskey has suffered and will
continue to suffer economic and non-economic damages for which the City is liable, including, but
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not limited to, emotional distress; pain and suffering; reputational loss; the loss of salary, wages, and
benefits; and loss of other terms, privileges, and conditions of employment.
545. Defendant City of Port Clinton’s acts were willful, egregious, malicious, and worthy of
substantial sanction to punish and deter Defendant and others from engaging in this type of
unlawful conduct.
CLAIM 7
RETALIATION UNDER OHIO REV. CODE § 4112.02(I)
547. Under Ohio law including Ohio Rev. Code § 4112.02(I), it is an unlawful employment
practice for any person to discriminate in any way (retaliate) against any other person because
that person has opposed an unlawful discriminatory practice.
548. Ohio Rev. Code § 4112.01(A) defines “person” to include “individuals,” “legal
representatives,” “agent[s],” “the state and all political subdivisions,” “authorities,” “agencies,”
“boards.”
549. As detailed in the preceding claim, Ms. Huskey engaged in protected activity and
suffered retaliation as a result.
550. The City is vicariously liable for its agents’ acts. Kent Johnson was the city’s agent as fire
chief. So were other fire-department and police-department employees, including Assistant Fire
Chief Charles Zillman.
551. As detailed above, they retaliated against her for her opposition to sex discrimination,
sexual harassment, sexual assaults, and her participation in EEOC and OCRC proceedings, and
this lawsuit. Defendant Johnson’s retaliation for her opposition included, but was not limited to,
depriving Ms. Huskey of her job as a firefighter/EMT and associated wages and overtime.
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552. As a direct and proximate result of this unlawful conduct, Ms. Huskey has suffered and
will continue to suffer economic and non-economic damages for which Defendants are liable,
including, but not limited to, emotional distress, pain and suffering, the loss of salary, wages, and
benefits, and other terms, privileges, and conditions of employment.
CLAIM 8
AIDING AND ABETTING DISCRIMINATION BY REBEKAH HUSKEY UNDER OHIO REV. CODE
§§ 4112.02(J)
AGAINST DEFENDANT KENT JOHNSON
555. Under Ohio law, including Ohio Rev. Code § 4112.02(J), it is an unlawful employment
practice for any person to aid, abet, incite, compel, or coerce the doing of any act declared an
unlawful discriminatory practice under Ohio Rev. Code § 4112.02.
556. Under Ohio law, including Ohio Rev. Code § 4112.99, whoever violates the above-
described legal obligation is subject to civil action for damages, injunctive relief, or any other
appropriate relief.
557. Under Ohio law including Ohio Rev. Code § 4112.02(I), it is an unlawful employment
practice to discriminate in any way (retaliate) against any person because she opposed an
unlawful discriminatory practice.
558. To aid or abet in discrimination, a person need only knowingly do something he ought
not to do or omit to do something he ought to do that “assists or tends in some way to affect
the doing of the thing which the law forbids.”1
1
State v. Stepp, 117 Ohio App.3d, 569, 690 N.E.2d 1342 (4th Dist.1997) (quoting Smith v. State, 41
Ohio App. 64, 67-68, 179 N.E. 696 (9th Dist. Dec. 9, 1931)), cited in Luke v. City of Cleveland, No.
1:02CV1225, 2005 U.S. Dist. LEXIS 49630 (N.D. Ohio Aug. 22, 2005); see also Woodworth v. Time
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559. Johnson aided, abetted, incited, compelled, and coerced in an unlawful discriminatory
practice: sexual harassment, sex discrimination (including job reassignment, pay reduction, and
retaliation against Ms. Huskey), as described in the factual narrative and claims above.
560. Johnson similarly aided, abetted, incited, compelled, and coerced others in retaliating
against Ms. Huskey.
will continue to suffer economic and non-economic damages for which Defendant Johnson is
liable, including, but not limited to, emotional distress; pain and suffering; reputational loss; the
loss of salary, wages, and benefits; and loss of other terms, privileges, and conditions of
employment.
562. Johnson’s acts were willful, egregious, malicious, and worthy of substantial sanction to
Warner Cable, Inc., N.D. Ohio No. 1:15-CV-1685, 2015 U.S. Dist. LEXIS 148832 (N.D. Ohio Nov.
2, 2015) (citations omitted).
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CLAIM 9
CIVIL LIABILITY FOR CRIMINAL ACTS UNDER OHIO REV. CODE § 2307.60 (A)(1),
INCLUDING, BUT NOT LIMITED TO:
OHIO REV. CODE § 2903.13(A) (ASSAULT),
§ 2905.01(A)(4) (KIDNAPPING),
§ 2905.02 (ABDUCTION),
§ 2905.03 (UNLAWFUL RESTRAINT),
§ 2907.05(A)(1) (GROSS SEXUAL IMPOSITION),
§ 2907.06 (SEXUAL IMPOSITION),
§ 2903.211(A) (MENACING BY STALKING),
§ 2917.21 (TELECOMMUNICATIONS HARASSMENT),
§ 2913.04 (UNAUTHORIZED USE OF PROPERTY — COMPUTER, CABLE, OR

TELECOMMUNICATION PROPERTY),
§ 2921.45 (INTERFERENCE WITH CIVIL AND STATUTORY RIGHTS),
§ 2921.44(E) (DERELICTION OF DUTY),
§ 2921.13 (FALSIFICATION) (AND OHIO REV. CODE § 2921.13(G)—CIVIL CAUSE OF ACTION

FOR FALSIFICATION),
§ 2913.42 (TAMPERING WITH RECORDS),
§ 2913.48 (WORKERS’ COMPENSATION FRAUD),
§ 2923.02 (ATTEMPT), AND
§ 2923.03 (COMPLICITY)
564. Ohio Rev. Code § 2307.60 provides: “Anyone injured in person or property by a criminal act
has, and may recover full damages in, a civil action.” Ohio Rev. Code § 2307.60(A)(1). Section
2307.60 “independently authorize[s] a civil action for damages caused by criminal acts.” Jacobson v.
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Kaforey, 149 Ohio St. 3d 398, 399 (2016). And no proof of an underlying criminal conviction is
required when bringing a civil action under § 2307.60. Buddenberg v. Weisdack, 161 Ohio St. 3d 160,
2020-Ohio-3832, 161 N.E.3d 603, ¶ 11.
565. For the Court’s convenience, criminal acts Defendant Johnson committed are consolidated
under this single claim, although any single one of them would establish separate civil liability under
§ 2307.60.
566. Ohio Rev. Code § 2923.02(A) (Attempt) provides that “No person, purposely or knowingly,
and when purpose or knowledge is sufficient culpability for the commission of an offense, shall
engage in conduct that, if successful, would constitute or result in the offense.”
567. Ohio Rev. Code § 2923.03(A) (Complicity) provides that no person, acting with the kind of
culpability required for the commission of an offense, shall
(1) solicit or procure another to commit the offense;
(2) aid or abet another in committing the offense;
(3) conspire with another to commit the offense in violation of section 2923.01 of the
Revised Code; or
(4) cause an innocent or irresponsible person to commit the offense.
568. Those who commit complicity may be criminally prosecuted and punished as if they were
the principal offender.
569. Ohio Rev. Code § 2903.13(A) (Assault) provides that “no person shall knowingly cause or
attempt to cause physical harm to another...”
570. Ohio Rev. Code § 2905.01(A)(4) (Kidnapping) provides that “no person, by force, threat, or
deception…shall…restrain the liberty of the other person…to engage in sexual activity, as defined in
section 2907.01 of the Revised Code, with the victim against the victim’s will…”
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571. Ohio Rev. Code § 2905.02(A)(2) (Abduction) provides that “no person, without privilege to
do so, shall knowingly…by force or threat, restrain the liberty of another person under circumstances
that create a risk of physical harm to the victim or place the other person in fear…” Ohio Rev. Code
§ 2905.02(B) provides that “no person, with a sexual motivation, shall violate division (A) of this
section.
572. Ohio Rev. Code § 2905.03(A) (Unlawful Restraint) provides that no person “without
privilege to do so, shall knowingly restrain another of the other person’s liberty.” Ohio Rev. Code
§ 2905.03(B) (unlawful restraint) provides that no person “without privilege to do so and with a sexual
motivation, shall knowingly restrain another of the other person’s liberty.”
573. Ohio Rev. Code § 2907.05(A)(1) (Gross Sexual Imposition) provides that “no person shall
have sexual contact with another…[when] the offender purposely compels the other person...to
submit by force or threat of force.”
574. Ohio Rev. Code § 2971.01(J) defines “sexual motivation” as “a purpose to gratify the sexual
needs or desires of the offender.”
575. Ohio Rev. Code § 2907.06 (Sexual Imposition) provides, in relevant part:
(A) No person shall have sexual contact with another, not the spouse of the offender; cause
another, not the spouse of the offender, to have sexual contact with the offender; or
cause two or more other persons to have sexual contact when any of the following
applies:
(1) The offender knows that the sexual contact is offensive to the other person, or one
of the other persons, or is reckless in that regard.
(2) The offender knows that the other person’s, or one of the other person’s, ability to
appraise the nature of or control the offender’s or touching person’s conduct is
substantially impaired.
576. Ohio Rev. Code § 2903.211(A)(1) (Menacing by Stalking) provides that
No person by engaging in a pattern of conduct shall knowingly cause another person to believe
that the offender will cause physical harm to the other person or a family or household
member of the other person or cause mental distress to the other person or a family or
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household member of the other person. In addition to any other basis for the other person’s
belief that the offender will cause physical harm to the other person or the other person’s
family or household member or mental distress to the other person or the other person’s
family or household member, the other person’s belief or mental distress may be based on
words or conduct of the offender that are directed at or identify a corporation, association, or
other organization that employs the other person or to which the other person belongs.
Ohio Rev. Code § 2903.211(A)(2) bars the use of telecommunications for these criminal purposes.
And Ohio Rev. Code § 2903.211(A)(3) provides that, “No person, with a sexual motivation, shall
violate division (A)(1) or (2) of this section.”
577. Ohio Rev. Code § 2917.21(A)(6) (Telecommunications Harassment) provides that no
person shall knowingly make or cause to be made a telecommunication, or knowingly permit a
telecommunication to be made from a telecommunications device under the person’s control, to
another, if the person “[k]nowingly makes any comment, request, suggestion, or proposal to the
recipient of the telecommunication that is threatening, intimidating, menacing, coercive, or obscene
with the intent to abuse, threaten, or harass the recipient.”
578. Ohio Rev. Code § 2917.21(A)(9) provides that no person shall knowingly make or cause to
be made a telecommunication, or knowingly permit a telecommunication to be made from a
telecommunications device under the person’s control, to another, if the person
[k]nowingly makes any false statement concerning the reputation, indecent conduct, or criminal
conduct of the recipient of the telecommunication or family or household member of the recipient
with purpose to abuse, threaten, intimidate, or harass the recipient.”
579. Ohio Rev. Code § 2917.21(A)(10) provides that no person shall knowingly make or cause to
be made a telecommunication, or knowingly permit a telecommunication to be made from a
telecommunications device under the person’s control, to another, if the person “[k]nowingly incites
another person through a telecommunication or other means to harass or participate in the
harassment of a person.”
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580. Ohio Rev. Code § 2917.21(B) provides that no person shall make or cause to be made a
telecommunication, or permit a telecommunication to be made from a telecommunications device
under the person’s control, with purpose to abuse, threaten, or harass another person; and that no
person shall knowingly post a text or audio statement or an image on an internet website or webpage
for the purpose of abusing, threatening, or harassing another person. Ohio Rev. Code
§ 2917.21(B)(1) and (2). Telecommunications harassment is, at a minimum, a first-degree
misdemeanor and can be a felony. Ohio Rev. Code § 2917.21(C)(2).
581. Ohio Rev. Code § 2913.04(B) (Unauthorized Use of Property) provides:
No person, in any manner and by any means, including, but not limited to, computer
hacking, shall knowingly gain access to, attempt to gain access to, or cause access to be
gained to any… telecommunications device, telecommunications service, or information
service without the consent of, or beyond the scope of the express or implied consent of,
the owner of the… telecommunications device, telecommunications service, or information
service or other person authorized to give consent.
582. Ohio Rev. Code § 2913.04(G)(1) then establishes that “Whoever violates division (B) of this
section is guilty of unauthorized use of computer, cable, or telecommunication property, and shall
be punished as provided in division (G)(2), (3), or (4) of this section.” And (G)(2) provides that
“unauthorized use of computer, cable, or telecommunication property is a felony of the fifth
degree.”
583. Under the relevant part of Ohio Rev. Code § 2921.13(A) (Falsification):
No person shall knowingly make a false statement, or knowingly swear or affirm the truth of
a false statement previously made, when any of the following applies:
(1) The statement is made in any official proceeding.

(2) The statement is made with purpose to incriminate another.
(3) The statement is made with purpose to mislead a public official in performing the
public official’s official function.
(Cleaned up.)
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584. Under Ohio Rev. Code § 2901.22(B):
A person acts knowingly, regardless of purpose, when the person is aware that the person’s
conduct will probably cause a certain result or will probably be of a certain nature. A person
has knowledge of circumstances when the person is aware that such circumstances probably
exist. When knowledge of the existence of a particular fact is an element of an offense, such
knowledge is established if a person subjectively believes that there is a high probability of its
existence and fails to make inquiry or acts with a conscious purpose to avoid learning the
fact.
585. Under Ohio Rev. Code § 2921.01(A):
“Public official” means any elected or appointed officer, or employee, or agent of the state
or any political subdivision, whether in a temporary or permanent capacity, and includes, but
is not limited to, legislators, judges, and law enforcement officers. “Public official” does not
include an employee, officer, or governor-appointed member of the board of directors of
the nonprofit corporation formed under section 187.01 of the Revised Code.
586. Under Ohio Rev. Code § 2921.01(D):
“Official proceeding” means any proceeding before a legislative, judicial, administrative, or

other governmental agency or official authorized to take evidence under oath, and includes
any proceeding before a referee, hearing examiner, commissioner, notary, or other person
taking testimony or a deposition in connection with an official proceeding.
587. Ohio Rev. Code § 2921.13(G) also provides for a separate civil cause of action for damages,
including attorney fees, costs, and expenses, for violations of Ohio Rev. Code § 2921.13(A)
(Falsification).
588. Ohio Rev. Code § 2921.45(A) (Interference with Civil and Statutory Rights) provides
that “No public servant, under color of the public servant’s office, employment, or authority, shall
knowingly deprive, or conspire or attempt to deprive any person of a constitutional or statutory
right.” Various federal and Ohio constitutional and statutory rights here are detailed above and
below.
589. Ohio Rev. Code § 2921.44(E) (Dereliction of Duty) provides that “No public servant shall
recklessly fail to perform a duty expressly imposed by law with respect to the public servant’s office,
or recklessly do any act expressly forbidden by law with respect to the public servant’s office.”
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590. Ohio Rev. Code § 2913.42(A)(1) (Tampering with Records) provides that, “No person,
knowing the person has no privilege to do so, and with purpose to defraud or knowing that the
person is facilitating a fraud, shall do any of the following: (1) Falsify, destroy, remove, conceal, alter,
deface, or mutilate any writing, computer software, data, or record….” The statute makes it a felony
when the records are those of a local government.
591. Ohio Rev. Code § 2913.48 (Worker’s Compensation Fraud) provides, in relevant part:
(A) No person, with purpose to defraud or knowing that the person is facilitating a fraud,
shall do any of the following:… (3) Alter, falsify, destroy, conceal, or remove any record or
document that is necessary to fully establish the validity of any claim filed with, or necessary
to establish the nature and validity of all goods and services for which reimbursement or
payment was received or is requested from, the bureau of workers’ compensation….
592. Ohio Rev. Code 2921.03(A)(4) (Complicity) provides that, it is a crime to “cause an innocent
or irresponsible person to commit the offense.”
593. Defendant Johnson’s conduct detailed in the facts section above and more constituted
criminal acts under the above and other criminal laws.
594. Defendant City of Port Clinton is vicariously liable for Defendant Johnson’s acts, which
were undertaken in the scope and course of employment. The Political Subdivision Tort Liability
Act, Ohio Rev. Code § 2744.02(A)(1) does not apply to “[c]ivil actions by an employee… against his
political subdivision relative to any matter that arises out of the employment relationship between
the employee and the political subdivision.” Ohio Rev. Code § 2744.09(B). (Emphasis added.)
including, but not limited to, emotional distress; pain and suffering; loss of reputation; the loss
of salary, wages, and benefits; and loss of other terms, privileges, and conditions of employment.
punish and deter Defendants and others from engaging in this type of unlawful conduct.
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CLAIM 10
ASSAULT
598. Defendant Johnson’s serial intentional actions caused Plaintiff repeated reasonable
apprehension of an immediate harmful or offensive contact.
including, but not limited to, emotional distress; pain and suffering; the loss of salary, wages, and
benefits; and loss of other terms, privileges, and conditions of employment.
were undertaken in the scope and course of employment. Kent Johnson was the city’s agent as
fire chief. The Political Subdivision Tort Liability Act, Ohio Rev. Code § 2744.02(A)(1) does not
apply to “[c]ivil actions by an employee… against his political subdivision relative to any matter
that arises out of the employment relationship between the employee and the political
subdivision.” Ohio Rev. Code § 2744.09(B). (Emphasis added.)
CLAIM 11
BATTERY
603. Defendant Johnson intentionally and repeatedly caused harm or offensive contact to
Plaintiff without her consent.
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including, but not limited to, pain and suffering; the loss of salary, wages, and benefits; and loss
of other terms, privileges, and conditions of employment.
were undertaken in the scope and course of employment. Johnson was the city’s agent as fire
chief. The Political Subdivision Tort Liability Act, Ohio Rev. Code § 2744.02(A)(1) does not
subdivision.” Ohio Rev. Code § 2744.09(B). (Emphasis added).
CLAIM 12
FALSE IMPRISONMENT
608. Defendant Johnson intentionally confined Plaintiff without her consent, violating her right to
be free from restraint of movement.
including, but not limited to, pain and suffering, the loss of salary, wages, and benefits, and other
terms, privileges, and conditions of employment.
were undertaken in the scope and course of employment. Johnson was the city’s agent as fire
chief. The Political Subdivision Tort Liability Act, Ohio Rev. Code § 2744.02(A)(1) does not
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subdivision.” Ohio Rev. Code § 2744.09(B). (Emphasis added).
CLAIM 13
FOURTH AMENDMENT VIOLATION, UNDER 42 U.S.C. § 1983,
613. The Fourth Amendment to the U.S. Constitution prohibits unreasonable searches and
seizures, including warrantless seizures by government actors.
614. Under color of law, Defendant Johnson, the City of Port Clinton’s fire chief and a final
policymaker for the fire department, unreasonably, without probable cause, and without a warrant,
searched Plaintiff Rebekah Huskey’s phone and seized her intimate personal images. His search and
seizure exceeded any authority she had given him, even if through coercion.
including, but not limited to, emotional distress; pain and suffering; reputational harm, the loss
of salary, wages, and benefits; and loss of other terms, privileges, and conditions of employment.
CLAIM 14
WRONGFUL-INTRUSION INVASION OF PRIVACY
618. Wrongful intrusion type of invasion of privacy is defined as the wrongful intrusion into one’s
private activities in such a manner as to outrage or cause mental suffering, shame or humiliation to a
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person of ordinary sensibilities. The interest protected is primarily a mental one rather than economic
or pecuniary. Actual damage is not necessary.
619. With his constant visits to her home, touching of her person, comments about her relationship
with her fiancé, unauthorized intrusion into, and appropriation of intimate images from her phone,
among other acts, Defendant Johnson wrongfully intruded upon and invaded Ms. Huskey’s privacy.
including, but not limited to, emotional distress; pain and suffering; reputational harm; the loss
of salary, wages, and benefits; and the loss of other terms, privileges, and conditions of
employment.
621. Defendant City of Port Clinton is vicariously liable for Defendant Johnson’s acts, which were
undertaken in the scope and course of employment. Kent Johnson was the city’s agent as fire chief.
The Political Subdivision Tort Liability Act, Ohio Rev. Code § 2744.02(A)(1) does not apply to “[c]ivil
actions by an employee… against his political subdivision relative to any matter that arises out of the
employment relationship between the employee and the political subdivision.” Ohio Rev. Code
§ 2744.09(B). (Emphasis added).
CLAIM 15
DEFAMATION
624. As a direct and proximate result of Defendant Johnson’s unlawful activity, Plaintiff has
suffered and continues to suffer economic and non-economic damages for which Defendants are
liable.
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625. Defendant Johnson published, distributed, and caused the above-described and other false
and misleading statements (and denials) about Ms. Huskey at a minimum negligently, but also knowing
they were false, and with reckless disregard as to whether the statements were true. (This claim does
not encompass Johnson’s statements made under oath in court proceedings.)
626. Defendant’s statements reflected upon Plaintiff’s character by bringing her into ridicule,
hatred, or contempt, or affected her injuriously in her trade or profession.
627. Some of the false statements Defendant Johnson made were defamation per se while others
were per quod. That is, they are susceptible to one meaning that is inherently abusive, disparaging, and
malicious, and defamatory. Damages are presumed.
§ 2744.09(B). (Emphasis added.)
including, but not limited to, emotional distress; pain and suffering; reputational harm; the loss
of salary, wages, and benefits; and the loss of other terms, privileges, and conditions of
employment.
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CLAIM 16
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
632. In conducting himself as he did, Defendant Johnson either intended to cause emotional
distress or knew or should have known that the actions taken would result in serious emotional distress
to Plaintiff.
633. Defendant Johnson’s conduct toward Plaintiff, including, but not limited to, sexually
assaulting, battering, and unlawfully restraining Plaintiff went beyond all possible bounds of decency
and was such that it could be considered intolerable in civilized society.
including, but not limited to, emotional distress, pain and suffering, reputational harm, the loss
of salary, wages, and benefits, and other terms, privileges, and conditions of employment.
§ 2744.09(B). (Emphasis added).
CLAIM 17
DESTRUCTION OF PUBLIC RECORDS UNDER R.C. 149.351
(AGAINST DEFENDANTS CITY OF PORT CLINTON AND KENT JOHNSON)
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2. Public records may not be removed, destroyed, mutilated, transferred, or otherwise damaged
or disposed of except under a records-retention schedule approved by the county records
commission, the state auditor, and the Ohio History Connection (formerly the Ohio Historical
Society).
3. The City had no records-retention schedule that would permit the destruction of Ms.
Huskey’s continuing-education records, time sheets, and payroll records.
4. Under Ohio law, public records may be deleted only in accordance with an approved
records-retention schedule.
5. Because the City had no records-retention schedule authorizing the destruction of videos
captured at the jail, it was obligated by law to keep those records indefinitely.
6. There is no reasonable explanation for why Ms. Huskey’s continuing education records, and
possibly her timesheets and certain payroll records and other records, disappeared.
7. Defendant Johnson destroyed these records.
8. As explained above, Ms. Huskey is aggrieved by the destruction of her continuing-education
records.
9. Ms. Huskey commences this civil action for injunctive relief to compel compliance with R.C.
149.351(A), for her reasonable attorneys’ fees, and for the civil forfeiture of $1,000 per record for
the destruction of records documenting her continuing education and time worked.
PRAYER FOR RELIEF
For the reasons stated above, Plaintiff respectfully requests the following relief from the Court:
A. Declare that Defendants’ acts and conduct constitute violations of federal and Ohio
law;
B. Enter judgment in Ms. Huskey’s favor as to all claims for relief;
C. Award Ms. Huskey full compensatory damages, economic and non-economic,

including, but not limited to, damages for pain and suffering, mental anguish,
Page 91 of 92
emotional distress, humiliation, and inconvenience that Ms. Huskey has suffered and
is reasonably certain to suffer again.
D. Award Ms. Huskey punitive damages for Defendants’ intentional and malicious
violations of federal and Ohio law;
E. Award prejudgment and post-judgment interest at the highest lawful rate;
F. Award Ms. Huskey her reasonable attorney fees (including expert fees) and all other
costs of this suit;
G. Enjoin Defendants from further misconduct.
H. Award all other relief in law or equity to which Ms. Huskey is entitled and that the
Court considers equitable, just, or proper.
JURY DEMAND
Plaintiff demands a trial by jury on all issues within this Complaint.
Dated: May 30, 2024 Respectfully submitted,
THE CHANDRA LAW FIRM LLC
/s/Subodh Chandra
Subodh Chandra (0069233)
Donald P. Screen (0044070)
1265 West 6th Street, Suite 400
Cleveland, Ohio 44113-1326
216.578.1700 Phone
216.578.1800 Fax
[email protected]
[email protected]
Attorneys for Plaintiff Rebekah Huskey
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2023-06-06 Kent Johnson meeting with Tracy

Colston and Dina Shenker
00:03
TRACY COLSTON: We have a complaint made against you. Trying to get all the details. Ms. Shenker
has had conversations with an attorney. They are accusing you of sexual
harassment.
KENT JOHNSON: Hmmm!
COLSTON: She believes that there’s a lot of evidence, and I’ll let her speak to that. I have not
talked to the attorney. So we need to have a discussion today about this. It looks
like you’re probably headed to paid administrative leave. She can tell you,
substantiate that a little more for the conversations that her and I have had today.
So, go ahead and—
00:40
DINA SHENKER: We’ve— so there’s an attorney out of Cleveland, that we’ve been contacted by,
like, literally this morning, contacted by this attorney in Cleveland. And they have,
I don’t know, I don’t know how to do this. They have Rebekah Huskey—
JOHNSON: —Mm hmm—
SHENKER: —as apparently a new client. And she has made some allegations to them that
they want to get more information on. So they called us to advise, well, called me
to advise me that they’re going to, they’re gonna get all this information from her.
They’re like trying to build a timeline with her, but she’s having some trauma. So
it’s, it’s hard for her to put stuff down.
So they asked us for a little bit of time, but they wanted to tell us what was going
on. And it just, like, shocked me that, you know, I was getting a call from this
attorney’s office. But she’s made allegations and they’re sexual in nature. And
she, she’s really kind of messed up from it right now. Like to where, like, she’s
just probably not in in the best mindset right now.
So I don’t know, who led her to an attorney. I don’t know, like, why she didn’t tell
anybody else first. Or, like, why she didn’t like, you know, I don’t know what, I
don’t know what the process was in her head or how she got there. But it’s just
that that’s how we were made aware of what she you know, what she… she’s
scared to come back to work. And we need to put the initial, you know,
Page - 1 - of 29
protections for you, you know, and for her on. So we can do everything by the
book. I mean, that’s we just had to make sure that we do everything by the book
to protect you, to protect her, to just just kind of do the administrative— the paid
administrative leave. That’s what they requested us to do. So, you know, we
want to make sure that we just follow protocol, and they didn’t…the allegations
aren’t super developed yet, I guess from what they were— they didn’t give me a
lot of information yet. They said it was to come. They did give me a couple of
instances. I don’t know if you want me to go further or not.
JOHNSON: Yeah, go ahead. I don’t, I don’t care.
SHENKER: Or just leave. So they said that there was an incident right before, the week
before Memorial Day where you were in your office and you attempted to kiss her
and like grabbed her face and attempted to kiss her and she pulled back. That
was one instance they gave.
They said you went to her house Saturday.
JOHNSON: Mmm hmm.
SHENKER: And that like freaked her out. I don’t know if she was home or not or if you talked
to her—
03:52
JOHNSON: She was home. I’ve been to her house three times I’m trying to get paperwork on
her illnesses.
03:57
SHENKER: Okay. Yeah, I don’t know; that they just said you went to her house
JOHNSON: I did.
SHENKER: They didn’t really elaborate why or how or… and then they said that you had her
be your like administrative assistant? Or like have her help you with—
JOHNSON: She’s helped—
SHENKER: —whatever.
JOHNSON: She’s helped at, with Brian and I on different things, safety town [UI]—
04:18
SHENKER: Yeah, and she felt super uncomfortable just being in like small spaces like if you,
you know, you know how you go in, you reach over someone, you, like, look at
Page - 2 - of 29
something, so, those are just a few instances they gave. There’s gonna be more.
From what the attorney said he said there’s at least eight instances, but they did
not share…yeah—
04:39
JOHNSON: Oh, I’m sure there’s gonna be some texts and some other stuff, so…
04:43
SHENKER: Okay. Yeah, I don’t know. I mean, like I said, I don’t…
04:46
JOHNSON: What do they want for resolution?
04:47
SHENKER: I don’t know. I don’t know know. That’s…I was trying very hard to be very
diplomatic and kind of, you know, feel around; I don’t know. I honestly don’t
know. I think… I don’t know. I mean, I— I don’t know I don’t know what to tell you
because I don’t…
JOHNSON: —That’s alright. because I just I’m very—
05:08
SHENKER: —’Cause I just don’t know—
JOHNSON: I, I’m very disappointed that she’d do that without coming n’ talkin’ to me. It’s, it’s,
it’s been over a year. She did some things. And it’s, it’s more of a joking aspect,
back and forth and if it was bother, she shoulda said something.
05:22
SHENKER: Right, and like I said, I don’t know what got her to the point of going to an
attorney…
05:26
JOHNSON: Well, it could have been…
SHENKER: —you know?
JOHNSON: It, it could be a number of things and like I said, I’ve tried to do everything I can.
She’s very unstable.
SHENKER: Yeah.
JOHNSON: And I tried—
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COLSTON: —Sounds like it.
JOHNSON: —very hard to help her.
SHENKER: Yeah, well, she’s…
JOHNSON: I gave her a bunch of vacation time, or not vacation time but… sick time so she
get through with her back surgery, I’ve made arrangements for her to come back
into work so she is not losing any money.
05:49
SHENKER: And she obviously had this last…?
05:54
JOHNSON: She had surgery last Friday.
05:56
SHENKER: Yeah, for that incident. That’s gotta, that’s gotta mess with—
JOHNSON: [UI]
SHENKER: —with your head. I can’t imagine that wouldn’t mess with your head. You know,
the, you know the, from I understand, from the where you’re pregnant your
Fallopian tubes.
JOHNSON: Mm hmm.
SHENKER: Yeah, I mean that’s gotta mess with anyone, I don’t, and so that’s, that’s all we
have. So, the paid administrative leave would continue until the investigation is
complete. We’re going to farm out the investigation to, I don’t even know who
but—
COLSTON: —probably—
SHENKER: We’re just gonna—
06:28
COLSTON: It’ll probably just run through Clemans Nelson—
SHENKER: —Yeah—
COLSTON: —on the internal stuff. And that’s—
SHENKER: Let them take care of it.
Page - 4 - of 29
06:33
COLSTON: —that has nothing to do, I have no idea if they’re gonna go criminal, take it to the
sheriff, I have no idea. I, I have not talked to anybody but her—
DINA SHANKER: Yeah—
COLSTON: —on the subject.
06:42
SHENKER: And I wish I—
COLSTON: —Fuck.
SHENKER: —I wish I could get a better handle on what that attorney, you know, is looking
for.
06:53
COLSTON: I say we, we wait and see what happens when he sends you a letter stating—
SHENKER: —Yeah—
COLSTON: —all the facts and claims. Then we have him turn over, you can answer that to
the people and do it that way. Uh, do the Garrity rights so that doesn’t come into
criminal if it, if it goes that far. I don’t have any idea if it’s gonna go that far. I don’t
know her I don’t know her at all.
SHENKER: I don’t, either.
COLSTON: I didn’t even know who she was until I, when we were
JOHNSON: She’s—
COLSTON: down there—
07:13
JOHNSON: She’s just kinda crazy, I guess, the easiest way to put it, under a tremendous
amount of stress, n’.
07:18
COLSTON: Well this, I, I’m just sick to my stomach. I—
JOHNSON: Ehhh.
Page - 5 - of 29
COLSTON: I mean for you— I am! I…
JOHNSON: I’m tired of this shit.
COLSTON: I know it.
SHENKER: It’s a, it’s just—
COLSTON: It’s just one other thing that we’ve, we’ve, you and I’ve had these discussions, it’s
just another fucking layer. My question to you: who do, I have to go down and
make somebody in charge. Who, who is it? Is it Brian? Is it, what do, what do you
want me to do?
JOHNSON: Yeah, give it to Brian.
COLSTON: Give it to Bri?
JOHNSON: Yeah.
COLSTON: Okay. Unfortunately, you’ll probably have to leave your truck at this fire station.
07:46
JOHNSON: That’s fine. Give me an hour to get it empty.
07:49
COLSTON: You do, you don’t even, you whatever, I don’t care, but just. Then you can’t come
back on the premises, I guess, [to Shenker] Is that what you said?
SHENKER: I, right.
COLSTON: I would see, or have any contact with her, whatever you do—
SHENKER: Please. Please.
COLSTON: —do not go over there. Please stay away from her.
SHENKER: Please do not.
COLSTON: ‘Cause I don’t, I have not talked to her at all. She would not—
SHENKER: No, she would not—
COLSTON: [UI]
Page - 6 - of 29
SHENKER: Yeah.—
COLSTON: —’Cause you tried or something—
SHENKER: There was, there was nothing that, it was, her attorney contacted us and
basically told us that any conversations take place have to go through the
attorney. There was no,
COLSTON: And what, who, who was it?
SHENKER: The attorney?
COLSTON: What was the company?
08:22
SHENKER: Um, it, the attorney’s name is, his last name is Chandra [sic]. He said “This is
attorney Chandra,” I can’t, his first name I think is— It’s an Indian name, it’s Sub,
Sub, Subeed, or Sub— I’m not sure; I need to look it up.
08:37
JOHNSON: It’s probably the same one that’s handling her lawsuit against Firelands.
SHENKER: Who?
JOHNSON: Rebekah’s suin’ Firelands for her surgery, her back-surgery issues.
08:47
COLSTON: Really? See, there’s so many layers to this—
SHENKER: There’s so many layers and I didn’t know anything—
COLSTON: This is—
SHENKER: —about that.
COLSTON: —this is—this is re—
SHENKER: That would actually make sense, because, that would make sense, because—
What’s his name, Chandra?
09:00
COLSTON: And so from my stand, only thing I, I’ll tell the supervisors, I suppose I’ll have to
call the board [UI] to tell them ‘cause they, see, deal with you, or I shouldn’t? Tell
me, tell me where to go.
Page - 7 - of 29
JOHNSON: You, you tell whoever you want. I don’t care.
09:10
SHENKER: No, we, we
COLSTON: No, no, that’s why I’m gonna
SHENKER: Yeah, no. We wanna try to—
09:15
COLSTON: I wanna know who, who should be in charge. I’m saying it’s administrative leave.
Nobody’s gonna hear one other effing word out of Tracy so—
SHENKER: Right.
COLSTON: —I can tell you that now.
09:21
SHENKER: We want to try to not, we’re not going to be blasting this anywhere. This is, we’re
trying to definitely, like, right now, it’s just paid administrative leave, you, you
know?
COLSTON: I’m looking out for you man, I, I—
SHENKER: It’s nothing more.
09:35
COLSTON: It just absolutely sucks.
SHENKER: So, it’s Sub— Sub—
COLSTON: Absolutely sucks.
SHENKER: It’s S-U-B-O-D-H. Chandra. I don’t know.
JOHNSON: Don’t know. Don’t care.
SHENKER: I have no idea, it’s a law firm out of Cleveland.
09:47
JOHNSON: I’m very disappointed that she did it and didn’t come talk to me. And, has there
been some situations? And— I probably overstepped a boundary or two. So has
she.
Page - 8 - of 29
SHENKER: Yeah, I don’t—
JOHNSON: There’s, there’s been no relationships. No, nothing along those lines. There has
been no relationships; no nothing along those lines. There’s joking back-and-
forth texts, et cetera. In my opinion. If she’s— was uncomfortable, I wish she
would have come to me.
SHENKER: Yeah—
10:10
COLSTON: Do you think—
SHENKER: —and then—
COLSTON: —she has texts of something you shouldn’t have probably said?
JOHNSON: Probably.
COLSTON: Oh, fuck! [SIGHS].
10:19
SHENKER: Yeah, I, and yeah, I mean, I, I, like I said—
10:23
JOHNSON: I wish I would have kept some of hers.
SHENKER: Right—
JOHNSON: But I just delete them, ‘cause I laugh at ‘em and delete them.
COLSTON: Sure.
10:31
SHENKER: So, yeah, I mean, obviously, we don’t know how big of a bomb they’re gonna
drop. We just—
JOHNSON: —I don’t care—
SHENKER: —we don’t. But it’s, you know, it’s, and she, she did make the statement that she
is very concerned about the firehouse and very concerned about tearing it apart.
And we are too. We, you know?
10:53
Page - 9 - of 29
COLSTON: Ah this, this stuff I, by doing that tears it apart.
10:57
SHENKER: Well, but we haven’t, you know, and that’s why—
COLSTON: He’s gotta look out for his name, that’s all.
SHENKER: Right, right. And you have to look, right, absolutely—
COLSTON: That’s all, that’s all I care—
SHENKER: You have to look out for yourself and—
COLSTON: I just care about Kent Johnson’s name.
SHENKER: —you know, yourself and— that’s, you know, your kids, and your family, and, you
know, I mean it’s all, I don’t know, like I said, if we can keep this, you know, if we
can keep this, like, internal, you know, no, no police involvement, that would be
the best situation for everyone, you know. But the thing is, is she may just say,
like, “Oh, if he’s still there, then I want criminal charges,” or something. So, I don’t
know. I just don’t know what, I’ve never, I don’t think I’ve ever had more than a,
“Hi!” you know, kinda conversation with her, so I don’t, I don’t know—
11:42
JOHNSON: I don’t know, somebody. There’s somebody. She is Rose’s sister— Rose
Huskey—yeah, Rose Huskey—
COLSTON: Yes.
JOHNSON: —she’s probably pushing it.
SHENKER: Who’s Rose? Is Rose, like, her age, or younger, or older?
COLSTON: Older, she’s older.
11:55
JOHNSON: And her and I’ve had a couple, Rose and I have had problems with regards to—
11:59
COLSTON: So if she went to Rose, you’re thinking Rose says “Yeah, fuck yeah. Go get him.”
12:02
JOHNSON: Yeah. Cause I smucked [sic] her at the hospital a few weeks ago. She made a
comment at the hospital and I told— What’s-His-Name?
Page - 10 - of 29
SHENKER: Yeah, but just please, please just stay away from her. As far—
JOHNSON: Well I ain’t gonna go anywhere near her.
SHENKER: As far away as possible.
12:21
JOHNSON: Her husband is working today or boyfriend is working today.
SHENKER: Just—just—as—
COLSTON: I’ll confirm it.
12:28
SHENKER: —as nonchalant as possible, as, you know. I mean, because nobody knows, like
I said, right now the only people who are aware of this is Tracy, myself, obviously
Rebekah, the attorney, and then Tracy called Clemans Nelson. That’s it. So, you
know, we don’t, we’re not out to make this, like, a big thing. We just want to, just
see if we can just get through this and see, have the best possible outcome
because—
JOHNSON: Alright.
SHENKER: No, don’t say that.
COLSTON: I want to clear your name, you know?
SHENKER: You know, we want to make sure things are good—
COLSTON: That’s all Tracy cares about at this point.
13:07
JOHNSON: I think everybody on the outside knows my name is good. And they know its
hers—
COLSTON: And that’s what I said too.
JOHNSON: —and they know who she is.
SHENKER: Yeah.
JOHNSON: I’m very disappointed it went that way, especially everything I’ve done to help—
Page - 11 - of 29
COLSTON: Done to help her out.
SHENKER: Yeah.
JOHNSON: So—
13:20
COLSTON: Then you get slapped upside the head. That’s bullshit. I didn’t hear all that..
SHENKER: What’s, what’s that, “No good deed goes unpunished?” Like, seriously?
JOHNSON: That’s what my wife said.
COLSTON: It’s true!
SHENKER: Seriously?
13:28
COLSTON: It is. And it’s, it’s just, and, and, you know, even back to the Leone thing. She
made the same, Jen did the same shit back to him, and she sat on his lap, if you
remember at one of our parties, and all that kinda shit, it’s all fun and games, but
that. She’s getting no benefit out of anything. She’s not been fired because of
this. So I mean, I just don’t understand.
13:50
JOHNSON: Well, I won’t drag her name through the mud. She’s got enough problems.
COLSTON: Just protect yourself. That’s all I’m saying to you. You do what you got to do but
just protect yourself.
14:00
SHENKER: Yeah, I don’t, like I said, I don’t know her but— I just, I just don’t under— like, I
personally, in my mindset don’t understand why she went to the attorney first—
COLSTON: Right.
SHENKER: That’s what, that’s what, you know, is, like—
JOHNSON: Somebody’s pushing her.
SHENKER: Or, she might have the medical claim. Like, if she, if she has a medical claim
against Firelands, she may have not needed to go very far because there might
be the same place, I don’t know—
Page - 12 - of 29
COLSTON: That’s a good point.
SHENKER: But that makes, that makes a lot more sense—
14:24
COLSTON: But she brought that up when she was doing the medical, “…and this” or
something,
14:27
SHENKER: —than just randomly going to an attorney.
COLSTON: Yeah, it’s doesn’t make sense to go to some attorney in Cleveland out of the
blue? Come on, unless if it was—
SHENKER: And they’re one of those, they’re one of those, you know, you don’t, you don’t
pay upfront, you know, “we usually get—”
COLSTON: Oh, really??
SHENKER: “We get the settlement from you after,” so that’s usually, that screams medical,
you know, that screams like, you know, like, like medical malpractice.
14:50
COLSTON: About you, you know. “You’re gonna get 50,000, I’m getting 52, why don’t you
sign?”
SHENKER: Well, yeah, because they get a cut.
14:54
Well, yeah, because they get a cut. They get a cut of it. So, I don’t, like I said,
that’s—
COLSTON: Well, I’m sorry, Chief, but that’s—
SHENKER: Me, too.
COLSTON: —what we’re gonna have to do and—
15:01
JOHNSON: It is what it is. Who’s financially responsible, me or the city?
15:06
COLSTON: Well, if on work, if it’s on work time, I think that the city gets involved with that. If
it’s on your personal time, or going to the house after work, then you probably
Page - 13 - of 29
want an attorney too. I mean, I’m just saying for my case, I had one from the city,
but I also had my own personal attorney. And I would always tell, I can’t tell you
what to do, but that’s what, that’s what I did, let me just say that. I had my own
personal, I grabbed Terry Dunn to be my own personal, he was in every single
meeting that I had, or deposition I had to do. I had Terry Dunn at my side and a
city attorney. That’s how it worked. So, that’ll be the thing. We don’t know what
the allegations, is it going to be after-work stuff? Is it going to be during-work
stuff? I don’t know.
15:44
SHENKER: Right. We don’t know. I mean, so far—
COLSTON: If you told me there’s texts, were those during working hours? Was it after your
working hour— I mean, who knows? So I can’t totally answer, but you know, I’m
saying, yes, if it’s the city related and from that position, then yeah, I would, we’d
have to help out for sure. But I’d get my own, too. I, I, I just didn’t believe. I
thought that those lawyers are just, you know, negatin’ what happens to this
situation, not taking care of Tracy from a personal standpoint.
SHENKER: —Right—
COLSTON: So that’s why I did my own. That’s—
SHENKER: Right.
COLSTON: —that’s just how I— I’m not telling you what to do, that’s just what I did. And
that’s how I handled it.
16:16
SHENKER: Right. And, like I said, I mean, she, she brought up one incident that was at
home, and then one incident that was at work. So, I don’t know, I mean, I don’t
know what, what, what the other incidents are going to be. It, it frustrates me that
we’re at, now, at the mercy of this attorney, you know, to get all this information,
because I told, I said, “Listen, we need to get, we need to get this information,
you know? You can’t just be making, like, you know, two allegations and then say
“There’s more to come.” But I think just to protect you, just administrative leave,
protect the city, that way the city can say “Listen, we, you know, we just did the
administrative leave to keep things kosher.” Keep things, you know, without, you
know, any type of escalation, especially at the fire, you know, the fire station, you
know?
17:07
COLSTON: When did she come back?
Page - 14 - of 29
JOHNSON: I don’t know. That’s why I was at the house Saturday. I needed her medical
paperwork.
17:14
SHENKER: I don’t know either. I don’t know. I’m not sure. I don’t know how serious the
surgery was.
JOHNSON: She had incisions and all sorts of stuff, according to her and Matt.
COLSTON: Her back?
SHENKER: Matt.
JOHNSON: No, Matt. Her husband, her boyfriend, baby-daddy.
17:29
COLSTON: Gotcha.
SHENKER: So, yeah, I don’t know. Like, if, if you can come back right away, or if you have to
have downtime to—
17:37
JOHNSON: That’s why I went Saturday, was, I tried calling ‘em; they don’t answer her phone.
She doesn’t answer his phone. So I tried calling. They didn’t answer so I, I gotta
have that paperwork, see what’s she’s doing—
SHENKER: Right. Right.
JOHNSON: —’cause in theory, she shouldn’t be allowed to work without the doctor’s release.
I don’t have it.
17:56
SHENKER: Right, right. You want to make sure she’s okay, ‘cause she’s—
JOHNSON: I didn’t, I got, I had to push for a doctor’s release on her back and I was not
comfortable the way that came about, and I didn’t want to run squad.
COLSTON: So, when you talk to that lawyer again, we, I have to have a medical release for
her to come back to work.
18:11
SHENKER: Oh, absolutely. I’m gonna tell him, I’ll be like, “Listen, I understand, whatever. But
we need—”
Page - 15 - of 29
COLSTON: That’ll be the next thing, we work, come back, she gets hurt and then I get sued.
SHENKER: Yeah, yeah, yeah.
18:19
JOHNSON: I guess the next thing to do is if she wants to play “the game,” she can’t come
back as that administrative assistant. That was just a created position so she
could earn money.
SHENKER: Gotcha.
18:32
COLSTON: So you took care of her again?
JOHNSON: Mm hmm.
COLSTON: Then she fucked you.
JOHNSON: Mm hmm.
SHENKER: Gotcha. Yeah, I mean, I think we’re, like I said they, they asked for like a week or
so, 10 days to get some to get the timeline together. But you know, I told him I
said, you know, “We got to keep moving forward. We can’t, can’t,” I didn’t want to
say “play the game,” but we can’t, you know, “We gotta we gotta get this
information,” so everybody, you know,
18:59
JOHNSON: Like I said, I’m not going to drag her name through the mud, but I’ll tell you, it
started off, and it was playful, I guess is the easiest way to put it. And did I
overstep the boundary a little bit? Probably, but I never did anything to hurt her.
SHENKER: Yeah.
JOHNSON: Just tried to help her. She is a very emotional young lady. I worried about her
killin’ herself; overdosin’. She’s told me she had her husband take the gun away
or the boyfriend take her gun away because she’s thought she’d put the gun in
her mouth.
SHENKER: Wow.
JOHNSON: So—
SHENKER: Scary.
Page - 16 - of 29
19:32
COLSTON: All that will come into play if it goes all the way.
JOHNSON: We’ll see.
COLSTON: Yep, so that’s what we got, so— do what you need to do. I’ll get a hold of Brian
later this afternoon. Tell him he’s in charge. I’ll let, I guess I’ll let PD Dave Scott
can just go to say your administrative leave, I’ll contact Brian Gutman give him
his phone number and do it that way—
19:54
SHENKER: That’s all we’re saying.
COLSTON: That’s all I’m doing.
SHENKER: It’s paid administrative leave. No—
COLSTON: Nothing else.
SHENKER: You don’t deserve any—
COLSTON: Nobody needs an explanation.
SHENKER: —further explanation. Yeah, nobody gets an explanation.
COLSTON: They don’t, they get nothing. Not from Tracy, anyway. I’ll tell Rachel for
your timesheet is off. [UI], that, and that’s it. We go from there.
20:12
SHENKER: Yeah, just, you know, let him, I guess let him speculate—
COLSTON: I will be—
SHENKER: Hahaha, I don’t know.
COLSTON: But I’ll get the charges and all that stuff, we certainly will call you back and have
discussion again.
SHENKER: Yeah. So, the timeline, hopefully, is we’re just going to wait to get this information
in. And then we’re going to, we’re going to turn it over to Clemans Nelson so they
could ask, you know, questions of her, of you, of—
COLSTON: Whoever.
Page - 17 - of 29
SHENKER: Whoever, if, you know—
COLSTON: Any of that stuff, was there witnesses? Can I ask?
Pause
COLSTON: No?
JOHNSON: No.
COLSTON: ‘Kay.
SHENKER: So it’s just those—
20:47
JOHNSON: Her dad was there Saturday.
COLSTON: Okay.
SHENKER: At the house?
JOHNSON: Mm hmm.
COLSTON: Okay.
SHENKER: Did you talk to him?
JOHNSON: Her dad?
SHENKER: Yeah.
JOHNSON: Yeah.
SHENKER: Did he, like—
JOHNSON: Yeah.
COLSTON: Like, nothin’, no—
20:57
JOHNSON: And I’ll tell you a funny story. There is always, she, you know, and this is where it
just blows my mind. She said, every time when I see any of my employees, you
can ask Kurt Clawson. I give him a hug every morning. Sometimes I give him a
Page - 18 - of 29
cuss [sic] and tell him I love ya.
COLSTON: Mm hmm.
JOHNSON: And she told me Saturday morning, walkin’ out the door, “I love ya.” So was it
sexual in nature? No. It was more like a father-trying-to-take-care-of-the-kid in
nature.
SHENKER: Yeah. I don’t even know.
JOHNSON: I don’t, I don’t care. I just don’t give a shit, so—
21:34
SHENKER: —All right—
JOHNSON: —All right—
SHENKER: —if we hear anything, we’ll let you know.
COLSTON: I’ll be in touch with you.
SHENKER: And I think once, once all this stuff comes in, you know, you said what do they
want out of this? What resolution they want? We probably will know more. You
know, I think, I think, yeah, I mean—
COLSTON: I have no idea.
SHENKER: I don’t know, but I think, like, we’ll definitely know, and we’ll definitely let you
know, so, you know, and I would probably get an attorney just to have your back.
And, you know, especially for the pre-disciplinary hearing, you know, you should
have an attorney come with you. But other than that, I don’t know, unfortunately,
we’re kind of in the dark—
JOHNSON: That’s fine.
SHENKER: Till they give us, whatever they have, so…
COLSTON: So he just gave you a little teaser basically,
SHENKER: Basically, which is annoying.
22:19
JOHNSON: Well, he, I’m sure he wouldn’t have taken the case if he didn’t think he had
something, so—
Page - 19 - of 29
SHENKER: Unless, unless they have the medical case. I don’t, and I don’t know—
JOHNSON: I don’t know who’s got the medical case, but there was a drug mishap in the
medical case.
22:31
SHENKER: Oh, Jesus. Yeah, I don’t know, so… I don’t know.
22:37
COLSTON: I just, people these days that just, that’s, we’ve talked, him and I have had these
discussions about, it’s getting old with all the bullshit, we gotta fuckin’—
22:44
SHENKER: —Well, yeah, there’s more bullshit than anything else—
COLSTON: —It gets, it gets, it gets old. And you’re trying to do the right thing and trying to
help people but I—
22:49
JOHNSON: That’s what pisses me off. I’m getting tired helpin’ people and getting’ the shit
kicked out—
SHENKER: Right! I mean, it’s—
COLSTON: You get kicked in the nuts—
JOHNSON: You know what?
COLSTON: For trying to help somebody.
SHENKER: It’s a thankless job.
22:58
JOHNSON: It just might, it just might be just easier to stop helping.
SHENKER: Yeah.
COLSTON: —[UI] miss that—
23:06
SHENKER: But no, I hear you. I mean, you get kicked in the teeth, you get, you know,
whatever. And people were just like, pfshtt [UI]—
Page - 20 - of 29
JOHNSON: Well, if I meant to do her any harm, I’d have done it. But I didn’t. And if she had
an issue, she should have said something to someone.
COLSTON: I know you well enough and you’re the way you, that you only try to help people.
You’d never try to fuck somebody over—
SHENKER: —Right.
COLSTON: And, it just, it just infuriates me that I have to sit here and—
JOHNSON: Well, that’s alright.
COLSTON: —and I’m almost in tears myself. Because I’ve been there. No, I, believe me, I
get it more than anybody else here, I get it. You know, when, when you help,
help Jennifer ever in my whole life, taking her kid to school, “Hey, go talk to this
teacher,” call on teachers to help her kid, and then get fucking shit on, I mean,
you know? It just, it just gets old.
SHENKER: Yeah.
COLSTON: It truly gets old. When is enough, enough?
SHENKER: Truly.
COLSTON: Obviously, you’re getting to the point where enough’s enough. I’m—
SHENKER: I hear you.
COLSTON: I’m frustrated with the workers, you know, guys quitting and leaving. I mean,
that’s on my mind. And it just keeps on one thing after the next.
SHENKER: Tracy’s ready to retire—
COLSTON: No, I—
SHENKER: Hahahaha—
COLSTON: He and I had this talk a couple weeks ago.
JOHNSON: I’m sitting right now if that makes things better. I’ll retire today, you know. I have
no problem with that.
Page - 21 - of 29
SHENKER: That’s, that’s obviously up to you, I, obviously, I mean, I just— I think it might take
a lot of the anger out of the, you know, the attorney, that, you know what I mean?
Like, if like, like, okay, “That’s done, done.”
JOHNSON: Well, if he’s—
SHENKER: We can’t tell you to you what to do—
JOHNSON: If he’s after financial gain, then he’s done.
24:34
SHENKER: So, but if—
COLSTON: If he comes, if he comes just as a complaint to the city, one thing. If he goes to,
to the, that, then we can’t control that. If it goes to the courts, they’ll decide if
they’re going to move forward or not.
SHENKER: Right, but—
COLSTON: Those are two separate issues.
SHENKER: But, but you, you could only, you know, she goes against the city you can only,
you know, she’s usually go against the deeper pockets, you don’t go against, you
know, usually…
COLSTON: But she just effing told us, basically today.
SHENKER: Well, right and we immediately took action—
COLSTON: That’s my point.
SHENKER: —immediately took action. So the fact that, you know, she can’t say she was
wronged by the city. So if, if, you know, you can’t say you’re wrong then you’re
not wronged, then maybe it’ll just—
COLSTON: Go away?
SHENKER: —just be done. I don’t know. I’ve never, I don’t know.
COLSTON: I don’t know what’s in her brain when he says she’s unstable—
SHENKER: Yeah, well right, she’s crazy, I don’t know what’s in her brain.
JOHNSON: She’s very, she’s very unstable. But—
Page - 22 - of 29
SHENKER: —I don’t know what’s in her brain either.
COLSTON: But [UI] well, you think she’s out looking for money? I don’t know—
SHENKER: —I have no idea.
COLSTON: —I don’t know her from a hill-a-beans. If she walked in here and I’d have to say,
“Who is that?” Probably.
25:34
JOHNSON: I, did, is she lookin for money? I don’t know.
SHENKER: I don’t know either.
JOHNSON: But I do know that when she had her back surgery, she, she was pregnant. Used
all of her sick time in pregnancy. Blew her back out, and she wasn’t… it’s two or
three months, maybe four months, blew her back, had to go in for surgery. And
she was out of sick time, out of everything. So Rachel and I made arrangements
to give her 250 hours of sick leave. So she could pay her insurance for that baby.
That’s all I wanted.
SHENKER: Hmm.
COLSTON: And this now makes no sense—
JOHNSON: And then—
SHENKER: Yeah, none of this makes sense.
COLSTON: It makes no sense; it makes no sense.
JOHNSON: And…and it’s…
COLSTON: I mean, and like I said, I don’t even know her to even comment on her, ‘cause I
don’t know…
SHENKER: I don’t either—
COLSTON: —but, like you said, Dina, no good deed goes unpunished.
26:21
SHENKER: And you’re dealing with potential crazy that’s not gonna—
Page - 23 - of 29
26:24
JOHNSON: Well, like I said, I don’t want to call her crazy. She’s a goddamn good EMT. She’s
a good person on—
COLSTON: Seriously?
JOHNSON: On the inside, on the outside, but…
COLSTON: She’s a wreck.
JOHNSON: There’s something that’s going on now, you know, it’s, she’s, she’s, I don’t know,
ain’t gonna go into details with you guys, but she’s told me shit that just blows my
mind.
26:42
COLSTON: Well, that’s, all I’ms [sic] asking you, and I know you get to that point: please
defend yourself if you need to. That’s all I’m saying.
SHENKER: Right.
COLSTON: Please, please…
SHENKER: If you choose—
COLSTON: —just—
SHENKER: —retirement, I mean that’s—
COLSTON: You do what you want on that—
SHENKER: That’s on…that’s like, that’s…
COLSTON: That’s totally…
JOHNSON: Man, I can’t, I’m not gonna retire and leave my ass out to dry. Right now, I have
some city protection.
SHENKER: Absolutely.
COLSTON: That’s right.
27:00
SHENKER: Absolutely. No, I agree with you. Totally. That’s why, you know, you need the city
to…
Page - 24 - of 29
COLSTON: Well you gotta see what the charges…
SHENKER: You gotta see what the charges, yeah,
COLSTON: —see what, see what they’re doing. If they’re just coming internally, then you can
make decisions like that…
SHENKER: Yeah, absolutely.
COLSTON: …if they’re going externally, then, then, you know…
SHENKER: It might—
COLSTON: —you have to have some protection.
SHENKER: Yeah. So, yeah—
COLSTON: You have to—
COLSTON: Just, let’s let it run its— basically, it runs its course, you know? Innocent till
proven guilty. What you say and how, you, only you and her know the whole true,
substance of that, nobody else does. I know the type of guy you are—
27:38
JOHNSON: I am, I am too nice, I am too good a guy to drag her through the mud. But I can’t.
No, but I won’t.
COLSTON: But, if it means to defend yourself, not my thing to say.
27:48
SHENKER: Just keep, keep all options open, you know?
COLSTON: Yes.
SHENKER: Just keep all options open. Because if it’s coming like, you know, hard and fast
and, you know, she’s just spewing all kinds of stuff that you know, you’re like, this
isn’t true. I mean, you gotta be, you gotta be true to yourself.
28:03
JOHNSON: I’m gonna say, in her mind, it is, she probably feels it is true. but none of it,
anything that I’ve ever done to anyone, is not malicious.
SHENKER: Yeah.
Page - 25 - of 29
COLSTON: Oh, you, you’ve helped people that you absolutely hate.
JOHNSON: Mm hmm.
COLSTON: And, and so have I.
SHENKER: [UI].
COLSTON: No, I mean…
SHENKER: No, I know!
28:20
COLSTON: I deal with [UI] still, both of us, we absolutely can’t stand him. I mean, he’ll say it,
I’ll say it to his face. We can’t stand him. He acts like we’re his buddy. And we do
what we have to do to survive that situation, is what I, the way I look at it. I do
what I have to do and if it’s right to help out, then I help out. If it’s not, then no.
And that’s the same as him. But he doesn’t have to go on EMT calls when the
fuckin, two women are out there and the guy’s 400 pounds.
JOHNSON: Yep.
COLSTON: Kent goes out and busts his back, and can barely walk, but he goes and helps
somebody do that.
SHENKER: Right.
COLSTON: And he doesn’t have to do that, you know. The guy could joke and say, “Hell, we
shoulda just let him die,” you know or the guy Narcan’s himself 87 fuckin times…
SHENKER: [Chuckles] Right.
COLSTON: The other day, you told me you were at, I forget how many cannisters you used,
it was an exorbitant number you told me…
JOHNSON: Mm hmm, yeah, he should’ve died. Nineteen, we shoulda stopped at ten.
COLSTON: Nineteen Narcans they used on one guy…
SHENKER: Oh, my God.
COLSTON: —to bring him back. He coulda stopped at five and “Hey, we tried our best, this
guy’s dead,” but no! He goes above and beyond…
Page - 26 - of 29
SHENKER: I know, and you just—
COLSTON: —and that’s what, and you get fucked.
SHENKER: You get fucked.
COLSTON: I just, aint no sense in talking no more but I, ‘cause it just drives me fucking
crazy.
JOHNSON: Alright.
SHENKER: You get fucked—
COLSTON: So—
SHENKER: I’m sorry—
COLSTON: When you, when you go, when you go home whatever you do…
JOHNSON: Nah, but I gotta get—
COLSTON: I’ll call Brian—
JOHNSON: I’ll get shit out my truck; I’ll tell Brian. I ain’t got a problem with that
COLSTON: Alright, tell Brian he’s in charge.
JOHNSON: Yep.
COLSTON: Okay, and if he has any issues to call me.
JOHNSON: Yep.
COLSTON: Please. He doesn’t need to deal with others.
SHENKER: Yeah.
COLSTON: We’ll go that way. I’ll tell other supervisors…
SHENKER: Don’t, don’t tell ‘em…anything…
JOHNSON: I ain’t gonna, I ain’t gonna tell ‘em shit.
Page - 27 - of 29
SHENKER: —other than—
COLSTON: Paid administrative leave, that’s it.
SHENKER: Paid administrative leave. He’s out. Gotta go.
29:42
COLSTON: And I, I think I, I would have you talk to Lucas ‘cause I don’t think that, I think it
should come from you…
JOHNSON: I’ll call—
COLSTON: If you want me to go do it—
JOHNSON: I’ll talk to the boys.
COLSTON: Okay. Take care. And I will—
JOHNSON: ‘Cause I will employ the middle boy.
COLSTON: Okay. I will…
Unknown: Alright.
COLSTON: —call the mayor and tell them we had a conversation—
SHENKER: Hang in there.
JOHNSON: I just really don’t give a shit.
SHENKER: I know, but just hang in there.
JOHNSON: And I’m going to tell you. She’s probably got enough to hang me out to dry. And I
just wish I would’ve saved her shit… You know?
SHENKER: Well, let’s see what comes in.
JOHNSON: I know, [UI]. The kiss? You know, where I grabbed her by the face, she was
bawling her eyes out in the office. I felt so damned sorry for her, I grabbed her,
looked at her in the eye. She didn’t pull away, she would’ve been, and what was
it? A peck.
SHENKER: I don’t know what to say.
Page - 28 - of 29
JOHNSON: I don’t know what to do.
SHENKER: It’s…
JOHNSON: Alright.
SHENKER: When you’re a woman, you’ve got all kinds of… yeah.
JOHNSON: Don’t worry. I’m not going to kiss you.
COLSTON: Onward.
SHENKER: Give me a hug; I’ll give, I’ll give you a hug, heh, heh, heh, it’s okay. Hey, we did
the, we did the pats. The three pats. Alright, Tracy, why don’t, give me a ride?
COLSTON: [UI] take you home.
[Background chatter and noise not transcribed.]
Page - 29 - of 29

Lawsuit Against Kent Johnson

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Lawsuit Against Kent Johnson

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Case: 3:23-cv-01910-JJH Doc #: 16 Filed: 05/30/24 1 of 121.

IN THE UNITED STATES DISTRICT COURT

PLAINTIFF REBEKAH HUSKEY’S SECOND AMENDED AND SUPPLEMENTAL COMPLAINT

NATURE OF THE ACTION

privacy, and sexual assaults.

Port Clinton’s fire chief, Defendant City of Port Clinton is liable.

3. Defendants are also liable for Johnson’s violations of 15 U.S.C. § 6851—disclosures

§ 2307.60, including the crimes of

• unlawful restraint (§ 2905.03),

• gross sexual imposition (§ 2907.05(A)(1)),

• sexual imposition (§ 2907.06),

• menacing by stalking (§ 2903.211(A)),

• telecommunications harassment (§ 2917.21),

• unauthorized use of property — computer, cable, or telecommunication property

• interference with civil and statutory rights (§ 2921.45),

• dereliction of duty (§ 2921.44(E)),

• tampering with records (§ 2913.42), and

• workers’ compensation fraud (§ 2913.48).

and destruction of public records.

of her for his own perverted ogling and use.

decisionmaker when it came to fire-department personnel decisions, including Huskey’s job

reassignment, discussed below.

Port Clinton Fire Chief Kent Johnson, age 65

JURISDICTION AND VENUE

place within this District.

Fire Chief Kent Johnson’s indifference to sexual harassment.

granddaughter. And she often called him “dad.”

department adopted this attitude towards sexual harassment.

18. He then left.

19. His unwanted groping shocked her.

Huskey not to talk to Klimentov and only to him.

you and your family.”

to assist with one EMS call for the station.

her leave after assisting.

demanding she return to work full time.

• Asking if he could watch her pump her breasts.

• Stating her breasts “look amazing.”

“grown, sexy woman.”

33. He also started rubbing her back and shoulders.

Chief Johnson’s sexual comments escalate.

should do it in front of the cameras so [Johnson] could watch.”

would be “easier with lube.”

• Repeatedly asking her to send him photos of herself.

• Often calling her to ask what she was wearing.

interested in a romantic or sexual relationship with him.

firefighter and EMT was her dream job.

know what he was doing there.

41. This comment was unnecessary and inappropriate.

new ambulance he claimed to be buying for her.

of his desk, so it was no longer in front of his chair.

her vagina. She smelled alcohol on his breath.

48. He had a noticeable wet spot on his pants.

51. Ms. Huskey told her fiancé about the incident.

calling her as well, but she didn’t answer.

moments later, he asked—referring to her baby’s first birthday party—“You dressing up

for the party” with a winking emoji:

Again, she didn’t respond to his unwanted flirtation.

mean the world to me.”

ranking, public-sector leader.