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http://nycourts.law.com/CourtDocumentViewer.asp?view=Document&docID=46729 Judge Baer PLAINTIFF SUED the Jewish Theological Seminary of America, alleging sexual harassment by a female rabbi, pursuant to Title VII of the Civil Rights Act of 1964, among other things. The court granted defendant’s motion for summary judgment, finding that plaintiff’s claims that two instances of touching made him feel uncomfortable are not enough. The court noted that without some evidence of something like a causal connection between the alleged sexual harassment and plaintiff’s firing, the quid pro quo sexual harassment claim must be dismissed. The court added that plaintiff only alleged three independent incidents and not a pervasive pattern of harassment. The court found that merely hugging a subordinate in an effort to console, touching a subordinate’s thigh during a meeting when such conduct could be construed as non-sexual in nature, and stating one’s love for a subordinate in a telephone message, do not collectively establish a hostile work environment.

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