These excerpts are taken from a June 25, 1998, deposition of Michael Bloomberg in the sexual harassment lawsuit filed by Mary Ann Olszewski, a former sales representative who claimed she was raped by Bloomberg executive Bryan Lewis in his Chicago hotel room.

Did you ever form a belief as to the truth of her allegations or Lewis’s denials? My personal belief is that we have an allegation without proof. The person making it was unwilling to explain.

What would constitute satisfactory proof to you that the allegation was genuine? I guess an unimpeachable third-party witness.

Do you think that’s possible in most instances of date rape? I don’t know whether this was date rape.

Describe for me your conception of how there could be a third-party witness to confirm or deny the truthfulness of her allegations.There are times when three people are together.

Other than those circumstances when a woman claiming rape was in the presence of more than one man, what other? Why does it have to be a man?

Have you ever read any psychosocial literature about the subject of rape? There was a cover story in one of the weekly news magazines last month. I’m sure I glanced through it.

Which one? Time, U.S. News, or Newsweek. For all I know, it was all three. They all do the same things.

Do you disbelieve Ms. Olszewski’s allegation? I don’t have enough information to know. I know she said it to Mr. Eccleston [Bloomberg’s No.2 executive].

What kind of participation [in a company investigation] would you expect of a woman who alleged she was raped by a coworker? She would have to sit down with our Human Resources department and repeat the allegation and provide any corroborating evidence.

Would you require corroborating evidence? If two people say different things and there is no way to ascertain which is telling the truth, my policy would be to tell them both that it was not something we would tolerate, but all we can do is provide separate working environments for the two.

Are you aware that even criminal law does not require a rape victim to produce corroborating evidence? I don’t know what the law is. My own morals would require it.

Do you believe that false claims of rape are common? I don’t have an opinion.

Was there any information conveyed to you that led you to be skeptical of her claim? The time between when she made the allegation [1995] and when she alleges it took place [1993].

What is the significance of the time lag? Common sense, as I would define it, would say that if one has a problem, one faces that problem relatively close to the time it took place.

Are you aware that studies by experts in which the U.S. Government participated establish that the majority of rape victims do not report that they have been raped? Have you ever heard that? No, I have not.

Did you or the company at any time consult with any expert on this subject matter in connection with what the company should do to investigate the allegation or the subject? It would be normal procedure for us to inform counsel, and I’m sure we did.

Do you know whether any psychiatrist, psychologist, or social worker was ever contacted by anyone at Bloomberg in connection with how Bloomberg should deal with an allegation of rape? Not that I know of.

Did the company ever consider removing Lewis either to a different floor or a different branch? Not that I know of, and there would be no reason to do so. She was making the allegations, not him. He seemed content with where he was.

Did you receive any advice from any source regarding the psychological consequences of rape? No.

Here’s a collection of other, unconnected Bloomberg comments, taken from various parts of the same deposition:

Have you ever made a comment to the effect that you would like to “do that piece of meat,” or I’d “do her in a second?” I don’t recall ever using the term “meat” at all.

How many complaints of any kind about sexual discrimination or sexual harassment has the company had? In the 17-year history of the company, perhaps a dozen, no more. I do not remember virtually any of them.

Has Bloomberg ever negotiated a severance package with any employee who alleged sexual harassment? Not to my knowledge whatsoever.

If such a thing were to take place, would it be brought to your attention? It would be, and I would instantly kill it. I have always been against the kind of extortion that the press says most companies jump to when somebody falsely alleges inappropriate behavior.

To the extent that Ms. Olszewski alleges she was raped by Lewis and that the company did not respond as it should have, do you regard that as extortion? The company did take the appropriate behavior when she made her allegation, and any insinuation to the contrary is an attempt of extortion.

To the extent that she alleges a hostile working environment by coworkers who create a sexually degrading environment for women, do you consider that extortion? Yes I do.

When did Bloomberg first establish a policy against sexual discrimination and sexual harassment? We have had that policy since day one, October 1, 1981.

What document reflects that? We had a written code of conduct.

Can you point out anywhere in this document where the word sexual harassment appears? It does not, but it is part of discrimination based on sexual orientation. It’s plain English.

Which words are the plain English that Bloomberg does not tolerate sexual harassment? “We do not discriminate against.”

So you believe sexual orientation means sexual harassment? It certainly does.

Doesn’t the sentence that contains the phrase “sexual orientation” mean simply that Bloomberg will not tolerate discrimination against homosexuals? We don’t discriminate against homosexuals, but that is not what this language says or means to me.

Was there any document that described the procedure for an employee to lodge a complaint for sexual harassment at Bloomberg in 1993? I don’t know. I don’t remember any.

Are you familiar with Equal Employment Opportunity Commission guidelines concerning sexual discrimination and harassment? I don’t remember reading specifically a federal document, no.

Are you aware it is available to you on the Internet? I wasn’t aware, but it doesn’t surprise me.

Do you have a computer on your desk? I do.

As the head of your company, do you believe it’s important that you are familiar with EEOC guidelines? Yes, I do.





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