In the complaint filed May 10 in San Francisco Superior Court (which is embedded below in its entirety), Pao claims that she was the victim of sexual harassment by Ajit Nazre, a former Kleiner Perkins investment partner who left the firm late last year. When contacted today, a Kleiner Perkins spokesperson declined to detail the specifics of why he departed.
The suit also alleges that Pao, along with other female employees at the firm, were regularly left out of meetings held by the firm’s male partners and that she was unfairly passed over for promotions because of her gender and her response to Nazre’s advances. High profile Kleiner Perkins partners John Doerr, Ray Lane, Bing Gordon, Ted Schlein, Chi-Hua Chien, are among those named in the suit.
The legal complaint names Kleiner Perkins as the defendant, on the basis of gender discrimination and retaliation. Pao is requesting economic damages including her allegedly lost back pay and punitive damages as allowed by law, among other reliefs. She is being represented by Rudy, Exelrod, Zieff & Lowe, LLP.
When reached for comment by TechCrunch, Kleiner Perkins provided the following response:
In response to a discrimination complaint filed in the Superior Court of San Francisco by Ellen Pao, Christina Lee, a Kleiner Perkins spokesperson, stated the Firm regrets that the situation is being litigated publicly and had hoped the two parties could have reached resolution, particularly given Pao’s 7-year history with the firm. Following a thorough independent investigation of the facts, the firm believes the lawsuit is without merit and intends to vigorously defend the matter. The Firm has been a diversity pioneer in its industry and was one of the first venture capital firms to hire women as partners. The number of women partners at the firm is one of the highest within the venture capital arena and the firm has actively supported women in all respects.
Here are other TechCrunch posts regarding the suit:
- Key Details Of The Kleiner Perkins Gender Discrimination Lawsuit
- Women At Kleiner Perkins: By The Numbers
- Kleiner Perkins Partner John Doerr Speaks Out On Lawsuit: “Our Firm Does Not Discriminate Based On Gender”
Here is Pao’s complaint in its entirety: