Leticia Clark and Angie Alonso claimed that they was just obeying orders.

23. In April 2003, Matula directed her secretaries, Leticia Clark and Angie Alonso, to begin stalking Ms. Lopez and Mr. Benitez. Two days after the Committee hearing, Clark and Alonso followed Ms. Lopez and a friend to a Whataburger near the campus and attempted to eavesdrop on their conversation. This sort of stalking became a regular occurrence, as Clark went so far as to follow Ms. Lopez to her home in Aransas Pass and take photographs. Ms. Lopez became sufficiently upset that she filed criminal reports with the police departments in both Corpus Christi and Aransas Pass. Ms. Lopez would later file a lawsuit against Clark, but the suit was dismissed when Clark claimed that she was just obeying orders.

24. Matula also hired a law firm to assist in the stalking of Mr. Benitez and Ms. Lopez. On May 16, 2003, John D. Bell of the law firm of Wood, Boykin & Wolter sent a letter to Teresa Cox, the Dean of EEOC and Human Resources at Del Mar, identifying his firm as counsel for Matula and demanding that Ms. Lopez and Mr. Benitez be investigated. Among other things, the letter revealed that Mr. Benitez and Ms. Lopez had been stalked and photographed and that Mr. Benitez’s cell phone records had been obtained and examined for evidence of calls to Ms. Lopez.

25. At some point, Matula made contact with Elizabeth Reynolds, a woman who considered herself to be a jilted paramour of Mr. Benitez. Like Matula, Reynolds was out for revenge. On information and belief, Reynolds joined in the stalking of Ms. Lopez and Mr. Benitez, and provided photographs to Matula. On numerous occasions, Reynolds was seen in the vicinity of Matula’s office, even though she had no business being there. On information and belief, Matula and Reynolds had regular telephone conversations. Even though she knew that Mr. Benitez was being stalked by a person
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who she did not know well and who was not within her control, Matula failed to warn Mr. Benitez of the possible danger.

26. On July 28, 2003, Matula sent a memorandum to Dean Cox claiming that a mysterious “Mrs. Gonzalez” had called to complain that Mr. Benitez was sexually harassing her daughter and other students. The call had conveniently arrived when Matula was out of town, and most of the narrative consisted of a memorandum written by Clark, who took the call in Matula’s absence. However, Matula claimed to have spoken to “Mrs. Gonzalez” afterwards. Naturally, “Mrs. Gonzalez” declined to name her daughter, to give any identification information, or to provide a telephone number. Nevertheless, Matula demanded that Dean Cox investigate the allegations “[i]n order to protect the College.” Matula did not, and of course could not, provide Dean Cox with any information that would allow her to investigate the fabricated allegation. Mr. Benitez was not formally notified of these allegations until November 2003.

27. On August 5, 2003, Matula claimed to have received a letter written by Ms. Lopez. Matula took the letter to Dean Cox and asked her to open it. Matula said that she did not want to open it because of the increasingly contentious dealings between Matula and Ms. Lopez, even going so far as to claim that the letter might contain anthrax. Dean Cox declined to open the letter, and instead returned it to Ms. Lopez. Of course, the letter was a forgery and a fabrication. The letter – which contains confidential information about Ms. Lopez such as her social security number that would have been easily available to Matula – accuses Mr. Benitez of sexual harassment, theft, and drunkenness. It appears that the letter was written by Matula’s ally, Elizabeth Reynolds. Del Mar later admitted that the letter was a forgery.