The woman at the centre of the Tim Paine sexting saga made four separate complaints about alleged sexual harassment at Cricket Tasmania, more than a year before she engaged in a series of texts with the former Test captain, documents filed in the Federal Court of Australia allege.
Renee Ferguson, who worked as a receptionist at Cricket Tasmania from 2015 to 2017 claims she made four complaints to five different senior staff members, against three separate men in that same time period, alleging sexual harassment in the workplace dating back to 2015.
A notice of filing and hearing, lodged in the Federal Court of Australia in November alleges Ms Ferguson made a complaint to Human Resources manager Merv Saltmarsh in 2016 about comments made to her by Cricket Tasmania's acting membership manager, Jon Adams, in 2015.
The document has been filed in a claim for damages by Ms Ferguson against Cricket Tasmania for sexual harassment.
Ms Ferguson alleges Mr Adams said: "Hey everyone, Renee will be naked in my apartment at 11 today. Get your binoculars out and I will open the curtains" while in the presence of staff and ground curators while at reception where Ms Ferguson was posted.
The document claims she made the complaint about the comment to Mr Saltmarsh in early 2016.
It's alleged that Mr Saltmarsh dismissed Ms Ferguson and stated, "at least he has good taste in women".
Mr Saltmarsh left Cricket Tasmania in December 2016 for a Human Resources role with the Tasmanian Hospitality Association.
The document alleges Ms Ferguson complained again about Mr Adams in April 2016, this time to former Hobart Hurricanes general manager Michael Roberts who she says told her, "don't tell me those stories, they're gross" before suggesting she ignore Mr Adams's comments.
Mr Roberts left Cricket Tasmania in October of that year and was appointed chief executive of Tennis West. He is currently chief executive of the West Australian Football Commission.
About a year later, in mid-2017, Ms Ferguson allegedly complained to Cricket Tasmania's senior accountant corporate services Rodney Purves about the workplace culture at the organisation.
She alleges Mr Purves told her, "that's awkward and should not be happening", but that no action was taken.
At about the same time, Ferguson alleges she was being sexually harassed by Cricket Tasmania's venue manager Stephen McMullen and former high performance coach Shannon Tubb.
But the document states she did not make a complaint about Mr McMullen's comments. Mr McMullen has vehemently denied allegations he sexually harassed Ms Ferguson.
He is no longer employed by Cricket Tasmania, having left in August last year.
Text messages with Paine
In November 2017, on the morning of the first Ashes Test in Brisbane, Ms Ferguson exchanged text messages with former Test captain Tim Paine.
In response to a picture of his penis, Ms Ferguson replied: "One thing I can guarantee you, I am a vault. Never repeat a thing."
The document alleged that when Ms Ferguson raised the previous complaints with the organisation's People and Culture Manager, Zoe Rohrer, she alleges Ms Rohrer told her: "I was not here, I cannot manage [this] historically or retrospectively. I'm not saying it didn't happen, but you need to move forward."
The meeting with Ms Rohrer was requested by Ms Ferguson after she was placed on a performance improvement plan by the organisation in August 2017.
The meeting took place two days after the text exchange with Paine, but the court papers do not make mention of a complaint being made specifically against Paine.
The document claims the performance improvement plan was enacted after a drop in Ms Ferguson's work output, which she says was due to a "loss in confidence" after her complaints about sexual harassment were allegedly rebuffed.
Ms Rohrer became general manager of corporate services at Cricket Tasmania in 2018, before becoming head of employee experience at Cricket Victoria in 2021.
She works alongside Cricket Victoria chief executive Nick Cummins, who was Cricket Tasmania chief executive from April 2017 until December 2019.
The document outlines a fourth complaint that was allegedly made by Ms Ferguson to accounting and payroll officer Kat Carroll, who worked in the same branch of the organisation as Ms Ferguson.
Ms Ferguson is currently fighting criminal allegations she stole from Cricket Tasmania.
She has pleaded not guilty in the Hobart Magistrates Court to 63 counts of stealing and two counts of dishonestly acquiring a financial advantage through the procurement of Cricket Tasmania and Hobart Hurricanes memberships.
The charges date back to September 2017, more than a year after she allegedly made her first sexual harassment complaint, and a month after she was placed on the performance improvement plan.
In a meeting with Ms Rohrer and her branch head David Paynter in December 2017, Ms Ferguson was told she would be suspended from work pending an investigation into financial discrepancies. She resigned shortly after.
At a Federal Court hearing earlier this month, Justice Mordecai Bromberg encouraged Cricket Tasmania and Ms Ferguson to attempt to settle the civil proceedings out of court.
Mediation has also been set for the two parties for March 17, despite Cricket Tasmania's lawyers originally expressing doubt that an outcome would be reached through those means.
