Cricket Tasmania will fight claims it ignored sexual harassment complaints from the woman at the centre of the Tim Paine sexting scandal, alleging she often initiated sexually charged correspondence with one employee and had a drug problem, according to documents filed in the Federal Court.
Renee Ferguson is seeking almost $1 million in damages from Cricket Tasmania, claiming she made complaints to different senior staff members, against three male colleagues, alleging sexual harassment in the workplace dating back to 2015.
Cricket Tasmania has rejected the allegations in documents filed with the Federal Court on Tuesday.
"The Respondent has searched the Applicant's email history and there is no record of her ever emailing any of the Respondent's management or staff with allegations of sexual harassment," the defence documents said.
Cricket Tasmania has written that her sexual harassment allegations against Jon Adams, who was museum and membership services manager between 2015 and 2017, had been denied by him.
According to the documents, several staff Ms Ferguson said she had complained to about Mr Adams disagreed they were made aware of her concerns.
Cricket Tasmania said Ms Ferguson had told her manager Rodney Purves in mid-2017 she had received "an inappropriate picture" via text message from another, unnamed staff member, but said Ms Ferguson did not take up his offer to escalate the matter.
The court documents said Mr Purves told his manager of the allegations regardless but it was decided it could not be taken further given she did not wish to make a complaint.
A former colleague of Ms Ferguson's, Kat Caroll, was said to have had a "vague recollection" she had mentioned receiving a message of a sexual nature, but alleged Ms Ferguson had spoken "not with any concern, but rather in the form of workplace gossip".
The staff member was later revealed as Tim Paine's brother-in-law, Shannon Tubb, when a law firm acting for Ms Ferguson wrote to Cricket Australia in June 2018.
The organisation initiated an investigation into the allegations, which were denied by Mr Tubb.
"Mr Tubb admitted that he and (Ms Ferguson) had shared messages but says the messages were mutually exchanged and were consensual in nature," the court documents said.
To back his denial, Mr Tubb provided a message from May 2016 in which Ms Ferguson said, "Do your hair and lippy and swing on by", and said she had consented to being added on messaging app Snapchat because she provided her username on request.
"With respect to the message saying, 'Get on Snap you mole', Mr Tubb provided email evidence that this type of language was commonplace in their communications with each other," the court documents said.
He also provided three photos of a sexual nature sent to him by Ms Ferguson, in which, according to Cricket Tasmania, she did "not look sad or humiliated", and described others in which she allegedly sent photos of her breasts, lips, open mouth, the penis of a man she was sleeping with, and her "bruised and sore … nude top half after alcohol and drug-fuelled sex sessions".
Mr Tubb further alleged she exhibited sexual behaviours at work, such as exposing her bra and the top of her breast when he was present, and claimed she had a "serious drug problem" and had discussed with him "the issues she had had in trying to stop her drug use".
"Mr Tubb advised … (Ms Ferguson) never asked him to stop sending messages of a sexual nature and she never advised that she felt harassed by their exchanges," Cricket Tasmania's court documents said.
Two other men — Paine and venue operations general manager Stephen McMullen — also denied having sexually harassed Ms Ferguson.
Paine was cleared in an internal investigation into the claims.