Former Undergraduate Council member Anjalee C. Davis '96 filed a complaint with a College official Tuesday charging that a council recommendation to send Davis to the Administrative Board for trespassing contained factual inaccuracies.

A council recommendation suggesting that Davis be Ad Boarded for tampering with council property and trespassing claimed that the former council member should have returned her council office key when she resigned last semester.

Davis used the key to open the council office two weeks ago to investigate rumors that the ballots on a campus-wide referendum were not secure.

The council recommendation was submitted to dean of the College L. Fred Jewett '57, with some changes, by council secretary Brandon C. Gregoire '95 last Thursday.

In a letter to Gregory Mobley, Gregoire's senior tutor, Davis wrote that there is nothing in the council's bylaws which requires her to return the key.

"Mr. Gregoire is well aware, as is every current and former member of the Harvard-Radcliffe Undergraduate Council, that there is neither a procedure nor a requirement for collecting keys from members who resign, graduate, decline to run for re-election or lose a bid for re-election," Davis' letter said.

Davis wrote that Gregoire told a "knowing lie" and that the recommendation constituted "political harassment."

"It is a malicious and purposeful lie, made with the intention to harm me, and which has caused me substantial harm," Davis wrote.

When informed yesterday of Davis's letter, Gregoire said he had heard nothing about it and thought it was a political tactic.

"It's obviously a retaliatory tactic and I think if anyone else had pursued the Ad Board procedure she would be pursuing similar charges against them," Gregoire said yesterday.

Gregoire admitted that the bylaws say nothing about former members returning keys. But he said Davis still should have returned the key.

"There's an unwritten rule in the U.C. saying you have to turn in you key to the Vice President when you resign or leave the council," Gregoire said yesterday. "She's not on the council anymore so she shouldn't have a key."

The Council resolution charged that Davis and Crimson reporter Todd F. Braunstein '97 entered the council office illegally and staged a picture showing blank ballots spilling out of an envelope.

The resolution also recommended that Crimson President Marion B. Gammill '95 and Managing Editor Joe Mathews '95 be Ad Boarded for "conspiracy to trespassing."

Council President Carey W. Gabay '94 suggested yesterday that Davis file charges against the entire council.