Footnote 70

See, e.g., Peterson v. Draper & Kramer Mortgage Corp., No. 00 C 3889, 2002 WL 1769987, at *5 (N.D. Ill. Aug. 1, 2002) (describing the senior vice-president accused of sexual harassment as "an equal opportunity yeller"). See generally Sturm, Second Generation, supra note 5, at 472 ("Under some circumstances, the boundaries between legitimate and illegitimate behavior will be quite difficult to draw.").