re": Trial Court Discretion and the Advocate— Witness Rule, 18 Whittier L.Rev. 447, 451 (1997 9 Jeffrey A. Van Detta, Lawyers as Investigators: How Ellerth and Faragher Reveal a Crisis of Ethics and Professionalism Through Trial Counsel Disqualification and Waivers of Privilege in Workplace Harassment

re": Trial Court Discretion and the Advocate— Witness Rule, 18 Whittier L.Rev. 447, 451 (1997 9 Jeffrey A. Van Detta, Lawyers as Investigators: How Ellerth and Faragher Reveal a Crisis of Ethics and Professionalism Through Trial Counsel Disqualification and Waivers of Privilege in Workplace Harassment

d "monkey noises" uttered in a common space or transmitted via plant-wide [146] radio can affect whoever hears them. See Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 762, 118 S. Ct. 2257, 141 L. Ed. 2d 633 (1998) ("[A]nyone who has regular contact with an employee can inflict psychological injurie