| 23. A sexual harassment case can sometimes boil down to a credibility battle between the parties, in which "the existence of corroborative evidence or the lack thereof is likely to be crucial." Henson v. City of Dundee, 682 F.2d 897, 912 n.25 (11th Cir. 1982). If there are no eyewitnesses, it can be critical for a plaintiff to learn in discovery whether the defendant has committed the same kind of acts before or since. Thus, the Equal Employment Opportunity Commission explained in a 1990 policy statement that the plaintiff's allegations of an incident of sexual harassment "would be further buttressed if other employees testified that the supervisor propositioned them as well." EEOC Policy Guidance (1990). The rules of evidence establish that such corroboration may be used to show the defendant's "motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident." Fed. R. Evid. 404(b). In short, a defendant's sexual history, at least with respect to other employees, is ordinarily discoverable in a sexual harassment suit. |