In addition to the racist rants and harassment about wearing a head scarf that Plaintiff was subjected to, Defendant KATHLEEN MULLENWEG also created a hostile, and sexually charged environment by repeatedly discussing Defendant MATTHEW MULLENWEG's sex life in graphic detail. KATHLEEN MULLENWEG would discuss Defendant MATTHEW MULLENWEG's attraction to Asian women, and how Asian women were all "whores" and "sluts" and "prostitutes." She also discussed that Defendant MATTHEW MULLENWEG would engage in threesomes with his girlfriends, that Defendant MULLENWEG was easily seduced by the Asian women, that the Asian women would poke holes in condoms in an attempt to set him up for marriage. Defendant KATHLEEN MULLENWEG would discuss how her son would sleep with multiple women at the same time, and other graphic details about Defendant Matthew MULLENWEG's sex life, Defendant KATHLEEN MULLENWEG engaged in a pattern of continuous, pervasive, and severe daily harassment intentionally occurring in the immediate presence of Plaintiff, in a direct and intentional attempt to offend, embarrass, and provoke Plaintiff, who repeatedly requested that this behavior stop.

In addition to the racism, Kathleen Mullenweg engaged in a pattern of continuous, pervasive, and severe daily sexual banter which occurred directly in Plaintiff's presence in her immediate work environment. In addition to the racism, the workplace was permeated with sexually-charged harassment which embarrassed, humiliated, and offended Plaintiff. For example, Kathleen Mullenweg would discuss in graphic detail the sex between defendant MULLENWEG and his Asian girlfriends even though Plaintiff begged her not to discuss such private matters. Kathleen Mullenweg at one point asked Plaintiff to spy on her son having sex with his girlfriends. She also asked Plaintiff to check the trash cans to search for condoms. Plaintiff made numerous complaints directly to Defendant MATTHEW MULLENWEG, AUDREY and to MULLENWEG's mother regarding the severity of Kathleen Mullenweg's racism and sexually charged non-stop rants, and the discomfort it was causing her, however Defendants did absolutely nothing to prevent it from occurring. In fact, to the contrary, Defendant MULLENWEG would share Plaintiffs complaints with his mother who would then retaliate against Plaintiff and threaten her with termination if she ever complained about her harassment to her son again.