throwawaytemp

    Without knowing more details, how can you state the above so confidently?

    Upon information and belief, Ray Lane and John Doerr discussed
    how to respond to to Plaintiff. Ray Lane met with Plaintiff.
    While acknowledging that Mr. Nazre's behavior was inappropriate
    Mr. Lane pressured Plaintiff to drop the matter because of
    Mr. Lane''s close ties with and mentorship of Mr. Nazre.
    Though Plaintiff had formally cmplained about Mr. Nazre's behavior,
    Mr. Lane encouraged Plaintiff to engage in a personal relationship
    with Mr. Nazre and even to marry him. Mr. Lane said, however,
    that in such case, either Plaintiff or Mr. Nazre would have to
    leave the firm because two spouses could not work together at KPCB.
    Mr. Lane said he and Mr. Nazre had discussed Plaintiff's report
    of sexual harrassment.
    
    KPCB was aware of and did not take reasonable steps to prevent
    retaliation and gender discrimination. KPC management was aware
    of and did not prevent Mr. Nazre from engaging in repeated
    retaliatory behavior for nearly five years. Following her formal
    complaint described above, Ray Lane insisted that Plaintiff
    have a one-on-one lunch with Mr. Nazre outside the office
    to discuss their relationship. Plaintiff saw no choice but
    to comply with the demand of a Managing Partner. Unsurprisingly,
    Mr. Nazre made inappropriate comments and engaged in unprofessional
    behavior, and seemed to be further empowered by KPCB to further
    retaliate against her.

    The number of issues and clashes with your peers and
    other partners that were discussed last year has
    decreased quite a bit, but acceptance by this group
    is still not evident.

    In February 2006 Plaintiff and another Junior Partner,
    Ajit Nazre, went on a business trip to Germany. Mr. Nazre
    had the same job title as Plaintiff, but had been with
    the firm since 2003, two years longer than Plaintiff, and 
    directed some of her work, including the Germany trip.
    Mr. Nazre made inappropriate sexual approaches to 
    Plaintiff on that trip. She rebuffed his advances.
    Mr. Nazre responded to her rebuff of his advances by
    becoming brusque and distant. He also had strong 
    influence over how other partners at the firm would view
    Plaintiff, specifically Ray Lane, a Managing Partner and
    Mr. Nazre's sponsor and mentor. From March to October
    2006, Mr. Nazre continued to pressure Plaintiff to have
    a sexual relationship with him. Mr. Nazre falsely told
    her that this wife had left him. When Plaintiff refused
    his advances, Mr. Nazre engaged in offensive, obstructionist
    and difficult behaviour toward Plaintiff. Plaintiff eventually
    succumbed to Mr. Nazre's insistence on sexual relations
    on two or three occasions. In October 2006 Plaintiff 
    informed Mr. Nazre that she would no longer have a personal
    relationship with him. Mr. Nazre started a consistent
    pattern of retaliation against her.