when an employer first learns that an employee is harassing a coworker, an oral warning (coupled with the threat of future disciplinary action should the harassing behavior continue) may be sufficient to satisfy the employer’s obligation to take appropriate steps to end the harassing behavior. See, e.g., Scarberry v. Exxonmobil Oil Corp., 328 F.3d 1255, 1259 (10th Cir.2003) (“[A]fter an investigation, [the harassing employee] was individually counseled regarding inappropriate behavior and company policy regarding harassment. He was also warned that [the employer] would not tolerate harassment in the workplace nor retaliation as a result of the investigation. This response was prompt and adequate as a matter of law.”); Intlekofer v. Turnage, 973 F.2d 773, 779-80 (9th Cir.1992) (<HOLDING>). In other circumstances, harsher disciplinary
holding part performance of an oral agreement necessary to take the oral agreement out of the statute of frauds must be consistent only  with the existence of the alleged oral contract holding that an oral warning may be sufficient where the harassing conduct is not extremely serious recognizing that the standard is extremely difficult to apply holding that connecticut may criminally punish harassing phone calls because the statute punishes both harassing conduct and speech holding that harassing conduct not sufficiently severe and pervasive where conduct would not have affected the work environment of a reasonable person