The Butler County Court system has responded to a lawsuit filed by a county probation officer accusing President Judge Thomas Doerr of sexual misconduct and other county employees of workplace discrimination, attempting to dismiss several of the charges in the complaint.

The motion to dismiss, filed on behalf of the court and deputy court administrator Thomas Holman, attempts to have several of the counts involved in the second amended complaint, which was filed in January in U.S. District Court, removed.

Plaintiff Crystal Starnes alleges a years-long sexual affair with Doerr that began shortly before she was hired as a county probation officer, which in turn led to the workplace discrimination by Holman.

She filed the first amended complaint Nov. 8. The second amended complaint was filed in January, removing Douglas Ritson, chief probation officer, as one of the named defendants in the lawsuit.

The motion filed on behalf of Holman and the court states that Starnes “validly released all claims regarding her extramarital affair that occurred before May 12, 2014,” when she signed a legal document with the county to secure a probation officers position with the Domestic Relations Office following a pregnancy and reassignment, that “unconditionally and forever release, remise and discharge the Butler County Court of Common Pleas ... from any and all claims, demands and causes of action that Starnes has, had or may have ever had, arising out of the events that have transpired from the beginning of Starnes employment with the Court until the date of this Release,” a brief in support of the motion states.

“Even assuming Starnes can establish a breach of the Release which resurrects her pre-2014 claims, those claims are time-barred because she claims to have suffered discrete discriminatory acts, as opposed to an ongoing pattern of a hostile work environment,” the motion states.

The motion also attempts to have all counts against Holman dismissed, stating that “Starnes' Fourteenth Amendment equal protection claim based on gender must be dismissed because she fails to allege that Holman had any direct involvement in actions treating differently from similarly situated males.”

“First Amendment Retaliation for Engaging in Protected Activity must be dismissed because Starnes did not engage in protected activity as her actions involved purely personal matters and the allegedly retaliatory action was not sufficient to deter others from exercising their constitutional rights,” and “There are no facts alleged in the Second Amended Complaint to support a Fourteenth Amendment claim based on procedural due process.”

Starnes claims she met Doerr at a Christmas party in 2004, and discussed a possible job with the probation office in the county.

She eventually went to Doerr's chambers on a Friday evening in February 2005. The two were alone in the courthouse that evening and engaged in sexual intercourse, the lawsuit states.

Over the next several months, the lawsuit alleges Doerr used his influence to have Starnes hired in August 2005. After she was hired, the lawsuit claims Doerr continued a sexual relationship with her, and the woman “felt that she had little choice and did not resist his command,” when he summoned her to his chambers for sex.

When she ended the liaison with Doerr after four years she was subjected to workplace discrimination from the judge and several other people working in the county court system, the lawsuit alleges.

According to online court documents, Starnes has until Feb. 26 to respond to the motion to dismiss.