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LOEFFELHOLZ v. UNIVERSITY OF WASHINGTON

No. 65364-4-I.

253 P.3d 483 (2011)

Debra LOEFFELHOLZ, Appellant, v. UNIVERSITY OF WASHINGTON and James Lukehart and Jane Doe Lukehart, and the marital community composed thereof, Respondents.

Court of Appeals of Washington, Division 1.

June 27, 2011.

Attorney(s) appearing for the Case

Michael E. Withey , Law Offices of Michael Withey, Seattle, WA, for Appellant.

Howard Mark Goodfriend , Smith Goodfriend PS, Jared Van Kirk , Anne F. Preston , Garvey Schubert Barer , Seattle, WA, for Respondents, James Lukehart and Jane Doe Lukehart.

Howard Mark Goodfriend , Smith Goodfriend PS, Robert Melvin Howie , Skylar Anne Sherwood , Riddell Williams PS, Seattle, WA, for Respondent, University of Washington.

GROSSE, J.

¶ 1 A hostile work environment claim is composed of a series of separate acts that collectively constitute one unlawful employment practice. A plaintiff is entitled to present evidence of harassment before the statutory limitations period to show the cumulative effect of the acts, provided some of the objectionable conduct occurred within the limitations period. Here the record is unclear, but raises an inference, that objectionable conduct occurred...

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