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Ximena Morris says she was demoted after complaining to senior officials of the TO2015 organizing committee.Kevin Van Paassen/The Globe and Mail

A female manager with the Pan and Parapan American Games alleges in a newly commenced lawsuit she was sexually harassed by former Ontario premier and TO2015 chair David Peterson and that when she complained to human resources and senior officials, she was first told to "let it roll off your back" and was then demoted.

An alleged history of flirtatious greetings that escalated into unwanted hugs, sexually tinged remarks and public humiliation at the hands of Mr. Peterson is outlined in a statement of claim Ximena Morris, 34, filed on Thursday with the Ontario Superior Court. In addition to Mr. Peterson, she also names the Pan and Parapan Am Games organizing committee, the Canadian Olympic Committee (a partner of the Games) and three members of the executive team at TO2015: CEO Saad Rafi, head of human resources and general counsel Karen Hacker, and senior vice-president of public affairs Amir Remtulla, who are alleged to have contributed to Ms. Morris's constructive dismissal at the organization.

None of the allegations have been proven in court and the defendants have not yet filed their defence outlining their version of events.

Mr. Peterson called the allegations "wild and untrue."

"I'm surprised and outraged that Ms. Morris would endeavour to embarrass me and the 2015 PanAm Games staff with this lawsuit," he said in an e-mailed statement to The Globe and Mail. "I deny the allegations, categorically, and look forward to confronting them in court."

Neala Barton, TO2015's vice-president of communications, responded on behalf of the organization and the TO2015 executives. She said the organization had not yet been formally served with the lawsuit but had seen a draft of the statement of claim, which she says "grossly misrepresents how management at TO2015 handled Ms. Morris's allegations."

Carl Vallée, the COC's executive director of communications, said in an e-mail that the organization did not believe the matter concerned it in any way and would not be commenting further while it is before the courts.

Ms. Morris says in her claim that after she complained about Mr. Peterson's alleged behaviour, she was told by Mr. Rafi that she should get used to being harassed because it would keep happening during her career.

The claim states she was then stripped of a job in which she managed 1,000 volunteers and eventually transferred to a clerical role.

Ms. Morris said she felt powerless to confront Mr. Peterson given his high regard in political circles and his position as chair of TO2015. "I really didn't feel like I had that freedom or ability given my role and given his role," she said in an interview Thursday at the Toronto office of her lawyer Rocco Achampong.

Mr. Peterson was instrumental in helping Toronto win the bid to host the 2015 Pan and Parapan Am Games. He has served as chair of the board since September, 2013. Ms. Morris alleges in her claim that Mr. Peterson's harassing conduct began just a month after he became chair with "inappropriate commentary" on her physical appearance.

The statement outlines three separate incidents in which Ms. Morris alleges Mr. Peterson behaved inappropriately toward her at Pan Am functions. The first, in October, 2013, took place at a dinner, where she alleges he told her: "You call me 'Handsome,' and I'll call you 'Sexy.' " At another, in April the following year, she alleges Mr. Peterson embraced her, "touching his chest to her breast."

She alleges the final incident happened at an event later in April, 2014, at the organization's headquarters in the Corus Quay building attended by Ontario Premier Kathleen Wynne, sponsors, TO2015 board members and members of the organizing committee's senior leadership team, including Mr. Rafi. Mr. Peterson, in front of attendees, allegedly said to Ms. Morris, "You look like a flamenco dancer, like you could just jump up on a table and start dancing" – an apparent reference, the claim alleges, to Ms. Morris's ethnicity. He allegedly repeated the comment in a boardroom and then in an elevator. In the last instance, Mr. Rafi turned to Ms. Morris and said, "Please don't sue us, please don't sue us. Let it roll off your back," the lawsuit alleges.

The Premier's office declined comment.

Ms. Morris claims she complained about the first incident to Mr. Remtulla the day after it happened. She also complained to him hours after the final incident at the headquarters in April.

Ms. Morris says she was too traumatized to return to work for days after that.

"I had been crying uncontrollably the whole week, hadn't been able to sleep. [I was] constantly throwing up any time I tried to eat," Ms. Morris said in the interview.

When she returned to work, the court document claims, Ms. Morris discussed what happened with Mr. Rafi, who allegedly said "a leopard never changes his spots," in reference to Mr. Peterson, suggesting Ms. Morris simply had to deal with the unwanted attention from him and from others in her career.

Ms. Morris then met with Ms. Hacker about a week later. Ms. Hacker said she'd draft a report about the incidents and give Ms. Morris a copy, but a month later, she still didn't have it, the lawsuit alleges. In May, Ms. Hacker told Ms. Morris there would be no report filed.

Later that month, Ms. Morris was moved from her external partnerships management job to another management position overseeing translations for the Games, despite not being experienced as a translator. In October, she was transferred again, and in June once more. Her most recent posting is a clerical job. The statement of claim says this constitutes constructive dismissal. She is seeking $10-million in damages.

Ms. Morris had worked in government backrooms for nine years previous to being hired by TO2015 in July, 2012.

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