Peter Lewiston was terminated on July 15, 2004, by the governing board of the Pine Circle Unified School District (PCUSD) for violation of the district sexual harassment policy. Prior to Lewiston termination he was a senior maintenance employee with an above-average work record who had worked for the PCUSD for eleven years. He had been a widower since 1998 and was described by his co-workers as a friendly, outgoing, but lonely individual. Beverly Gilbury was a fifth-grade teacher working in the district Advanced Learning Program. She was 28 years old and married, and had worked for PCUSD for six years. At the time of the incidents, Lewiston and Gilbury both worked at the Simpson Elementary School, where their relationship was described as cooperative. The following sequence of events was reported separately by Lewiston and Gilbury during the district investigation of this sexual harassment case.

Question: If you were the district's EEOC officer, what would you conclude? What disciplinary action, if any, would you taken?