SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
May-10-2012 3:01 pm

Case Number: CGC-12-520719 Filing Date: May-10-2012 2:58 Filed by: DEBORAH STEPPE Juke Box: 001 Image: 03610768

COMPLAINT

ELLEN PAO VS. KLEINER PERKINS CAUFIELD & BYERS LLC et al

001C0361 0768

Instructions:
Please place this sheet on top of the document to be scanned.

(CITAeION JUDICIAL)
NOTICE TO DEFENDANT: (AVISO AL DEMANDADO);

SU&NS

FOR COURT USE ONL Y (SOLO PARA uso DE LA CORTE)

KLEINER PERKINS CAUFIELD
LLC AND DOES] -20

& BYERS

YOU ARE BEING SUED BY PLAINTIFF: ELLEN (LO esrs DEMANDANDO EL DEMANDANTE);

PAD

NOTICE! You have been sued The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form If you want the court to hear your case. There may be a court form that you can use for your response You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp). your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an anorney referral service. If you cannot afford an attorney, you may be ehgible for free legal services from a nonprofit legal services program You can locate these nonprofit groups at the California legal Services Web site (www.lawhelpcalifomiaorg), the California Courts Online Self-Help Center (www.courtmfo.ca.govlselfhe/p). or by contacting your local court or county bar assoctanon. NOTE: The court has a statutory hen for waived fees and costs on any settlement or arbitration award of $1 0,000 or more in a civil case. The court's lien must be paid before the court Will dismiss the case IAVISO/ Lo han demandado Si no responde oetnro de 30 dies. fa corte puede decidir en su contra sin escuchar su version. Lea la informacion a contmuaci6n Tiene 30 alAS DE CALENDARIO oespues de que Ie enlreguen esla citacion y papeles legales para presentar una respuesta par escrito en esra corte y hacer que se en/regue una cotn« al demandante Una carta a una /lamada lelefomca no 10 protegen Su respuesta por escrito tiene que estar en formato legal correclo s! desea que procesen su caso en te corte. Es poslble que haya un formulario que usted pueda usar para su respuesla Puede encontrer estos formularios de la corte y mas informacion en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov). en /a blblioteca de teyes de SU condado 0 en /a corte que Ie quede mas cerea. Si no puede pagar la cuota de presentacion, pida al secretario de te corte que Ie de un formillario de exeocio« de pago de cuotes. Si no presenta su respuesta a tiempo, pueoe perder el caso par incumplimiento y te corte te podra qune: su suekio. dinero y bienes sin mas eavenencis. Hay otros requisitos legales. Es recomendable que lIame a un abogado tnmeoietemente Si no conoce a un abogado, puede lIamar a un servicio de remision a abogados. Si no puede pagar a un abogado, ss posible que cumpla can los requisitos para obtener servicios legales gratuitos de un program a de servicios legales sin fines de tucro. Puede encontrar estos grupos sin fines de iucro en el sitio web de California Legal Services, (www.lawhelpcahfornia.org), en el Centro de Ayuda de las Cortes de California, (www,sucorte.ca.gov) 0 poniendose en contacto con la corte 0 el colegio de abogados locales AVISO. Par ley la corte tiene oerecno a rectemer las cuotas y los costos exenlos par imponer un gravamen sabra cualquier recuperaclon de $10.000 0 mas de valor recibida mediante un acuerdo a una concesion de arbitraje en un caso de derecho CIVil Tiene que nr"v"n~"n de te corte antes de la corte desechar el caso.

name an
(EI nombre y direccion de la corte est

400 McAllister

San Francisco Superior Court
Street

San Francisco, CA 94102
The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (EI nombre, la iiireccior. y el numero de tetetono del abogado del demandante, a del demandante que no tiene abof!ado, es):

Alan B. Exelrod (SBN: 50467) RudX, Exelrod, ZiefT & ~oweO LLP

§;~ ?:~~fci~~ 7 0 ~t;{e~'4~O~e
1 0 2012

CLERK OF THE COURT

(415) 434-91500

(415) 434-0513

DATE (Fecha) ~~ (For proof of servic~this (Para prueba .

Clerk, by (Secreta rio) summons, use Proof of Service of Summons (form POS-010).) de esta citati6n use el formulario Proof of Service of Summons, (POS-010)), NOTICE TO THE PERSON SERVED: You are served 1, ~_j as an individual defendant. 2. [~ as the person sued under the fictitious name of (specify):

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D. STEPP ~

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Deputy (Adjun to)

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Form Adopted lor Mandatory Usa Jud ic: al C ouncrl 01 Calitorru a SUM·10G IRe, July 1 20091

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CCP 416.20 (defunct corporation) CCP 41640 (association or partnership) , . other (specify)," by personal delivery on (date):

J CCP

CCP 416,60 (minor) 416.70 (conservatee) CCP 416.90 (authorized person)
Pag.1 0'1
Code of Civil Procedure

SUMMONS

§§ 412 20,465

SOkm~1S ~Plus

Alan B. Exelrod (SBN: 50467) Rudy, Exelrod, Zieff & Lowe, LLP 351 California Street Suite 700 San Francisco, CA 94104 NO ~ 15) 434-9800
COURT OF CALIFORNIA,
ADDRESS STREET

OR PARTY WITHOUT

ATTORNEY

(Name.

number,

and address)

FOR COURT USE ONL Y

A'''~DT."E=LvEPHONE

FAX NO.

(415) 434-0513

SUPERIOR

COUNTY OF San Francisco 400 McAllister Street

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CIVIL CASE COVER SHEET
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Complex Case Designation Counter -Joinder
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Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.400-3.403)
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Filed with first appearance (Cal. Rules of Court,

Items 1-6 below must be completed (see instructions
1. Check one box below for the case type that best describes Contract this case: (06)
Auto Tort

II

i Auto (22)
Uninsured motorist (46)

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Other PI/PDIWD (PersonallnjurylProperty DamagelWrongful Death) Tort

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Product liability (24) Medical malpractice PIIPDIWD (23)

Real Property

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Non-PIIPDIWD l__

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L__! Business tort/unfair business practice (07) Civil rights (08) Defamation Fraud (16) property (19) negligence (25) tort (35) (36) (13)

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,____; Eminent domain/Inverse condemnation (14) Wrongful eviction (33) real property (26)

! Insurance coverage claims arisinq from the above listed provisionally complex case types (41) Enforcement ~ Miscellaneous of Judgment of judgment (20) Civil Complaint
(27)

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Detainer (31) (32)

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Commercial Residential Drugs (38) Review

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Other non-PIIPDIWD termination

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Asset forfeiture (05) re arbitration award (11)

J Partnership

Other petition (not specified above) (43)

---1 Writ of mandate (02) . , Other judicial review (39) complex under rule 3.400 management: represented parties d. raising difficult or novel e. f. to resolve evidence monetary of the California , Large in other Rules of Court. If the case is complex. mark the

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This case i__ ~ is ! X j is not factors requiring exceptional judicial a. [I large number of separately b. c.

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Alan B. Exelrod (SBI\: 50467)

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• Plaintiff must file this cover sheet with the first paper filed in the action or under the Probate Code, Family Code. or Welfare and Institutions Code). in sanctions. • File this cover sheet in addition to any cover sheet required by local court • If this case is complex under rule 3.400 et seq. of the California Rules of other parties to the action or proceeding. • Unless this is a collections case under rule 3.740 or a complex case, this
Form Adopted for Mandatory Use JudiCial Couoc.: of Calrtornla CM-010 [Re, July 1 20071

proceeding (except small claims (Cal. Rules of Court, rule 3.220.) rule. Court. cover

cases or cases filed Failure to file may result

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Page 1 of 2

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CIVIL CASE COVER SHEET

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Cat. Rules of COJrt. rules 2 30. 3220.3400-3403.3740 Cal Standards of Judrcra! Acrmmsuat-cn. sto 310

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JOHN T. MULLAN (SBN: 221149) RUDY, EXELROD, ZIEFF & LOWE, L.L.P. 351 California Street, Suite 700 San Francisco, CA 94104 Telephone: (415) 434-9800 Facsimile: (415) 434-0513 abe@rezlaw.com dal@rezlaw.com jtm@rez1aw.com

ALAN B. EXELROD (SBN: 50467) DAVID A. LOWE (SBN: 178811)

~NOOn8EE.r
511n FrAncisco

F I CCU"'Y Sup~rjcr LED

Court

MAY 1 0 2012

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SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND fOR THE COUNTY OF SAN FRANCISCO

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ELLEN PAO, Plaintiff:

Case No~

G C- 1 2 - 5 2 0 7 1 9
FOR DAMAGES

14

vs.

COMPLAINT

KLEINER PERKINS CAUFIELD & 15 BYERS LLC AND DOES 1-20.

JURY TRIAL DEMANDED

17

-------------------------------

Defendants.

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Plaintiff complains and alleges as follows: INTRODUCTION 1. Plaintiff Ellen Pao is an accomplished venture capital professional at Defendant This case concerns KPCB's discriminatory

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21 22 23 24 25
26

Kleiner Perkins Caufield & Byers, LLC ("KPCB").

treatment of Plaintiff and other female employees, specifically in advancement and compensation, because of their gender. Moreover, Plainti ff experienced continuing retaliation after she complained about sexual harassment to the highest level of management of KPCB. KPCB violated its obligation to take all reasonable steps to prevent discrimination and retaliation from occurring. III II I
COMPLAINT FOR DAMAGES

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1

PARTIES AND JURISDICTION

2
3 4 5 6 7 8 9

2.

Plaintiff is an employee of KPCB. She has worked for KPCB in San Francisco

County, California and resides in San Francisco County. She meets with companies that KPCB has funded or considers funding and with entrepreneurs and executives in San Francisco County, and she works from her home in the evenings and weekends. 3. Plaintiff is informed and believes, and thereon alleges, that KPCB is a corporation

doing business in San Francisco County, California and at relevant times has had an office in San Francisco County at which Plaintiff has at times worked. KPCB funds companies in San Francisco County and frequently hosts events for entrepreneurs in San Francisco County. 4. Plaintiff is further informed and believes, and thereon alleges, that each defendant

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named herein Does 1 through 20, inclusive, was, at all times relevant to this action, the agent, employee, or joint venturer of the remaining defendants and was acting within the course and scope of that relationship. The true names and capacities of the defendants named herein Does 1 through 20, inclusive, whether individual, corporate, associate, or otherwise, are unknown to Plaintiff, who therefore sues such defendants by fictitious names pursuant to California Code of Civil Procedure section 474. Plaintiff will amend this Complaint to show such true names and capacities of Does 1 through 20, inclusive, when they have been determined . FACTS COMMON TO ALL CAUSES OF ACTION 5. Plaintiff is a graduate of Princeton University with a degree in Electrical

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Engineering and a certificate from the Woodrow Wilson School of Public and International Affairs. Following her undergraduate education, she received a Juris Doctor degree from Harvard Law School with honors. She then worked as a lawyer at Cravath, Swaine & Moore. After Cravath, she entered Harvard Business School and graduated with a Masters of Business Administration degree with distinction. Following her graduation from business school, she worked at technology-related firms, including Microsoft Corporation, Tellme Networks, Danger Research and BEA Systems, Inc., for seven years with increasing responsibility. member of the 2007 class of Henry Crown Fellows at the Aspen Institute. III 2
COMPLAINT FOR DAMAGES

She is also a

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6.

KPCB is a venture capital firm. and its own employees,

It raises funds from institutional

investors, companies. to It

wealthy individuals

and invests the money in technology and sometimes

invests amounts ranging from $100,000 help fund their growth. Its investments

to $50,000,000

more in companies Inc. and Genentech.

include Google Inc., Facebook

KPCB also provides strategic advice and a network of relationships and KPCB employees invests in companies companies distributing

to the companies

it supports, KPCB When these

usually hold seats on the Boards of Directors of its companies. in the digital technology, greentech, and life sciences sectors.

generate returns by being acquired, by going public and issuing stock or by gains. KPCB generates returns for itself and the investors from whom it raised funds. its investment team of

KPCB is headed by Managing

Partners, who manage the firm, including

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Senior Partners and Junior Partners. 7. of the Managing In February 2005 KPCB was seeking to hire a Chief of Staff for John Doerr, one Partners. process. Plaintiff applied for the position and was hired in June 2005 after an Her title was Junior Partner, and initial job responsibilities of Mr. Doerr, to identify potential digital technology to help raise financings, to serve as a were to

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manage projects and new initiatives investments

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for KPCB to fund, to interview executives,

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board observer, to help write Mr. Doerr's She was told if she was successful three years. 8.

speeches and articles, and to support finn activities.

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in this role, she would move to a full-time investing role after

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In February 2006 Plaintiff and another Junior Partner, Ajit Nazre, went on a Mr. Nazre had the same job title as Plaintiff, but had been with the

business trip to Germany.

firm since 2003, two years longer than Plaintiff, and directed some of her work, including the Germany trip. Mr. Nazre made inappropriate rebuffed his advances. and distant. Mr. Nazre responded sexual approaches to Plaintiff on that trip. She by becoming brusque

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to her rebuff of his advances

He also had strong influence over how other partners at the firm would view Ray Lane, a Managing Partner and Mr. Nazre's sponsor and mentor. From

Plaintiff, specifically

27
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March to October 2006, Mr. Nazre continued

to pressure Plaintiff to have a sexual relationship When Plaintiff refused his

with him. Mr. Nazre falsely told her that his wife had left him.

3
COMPLAINT FOR DAMAGES

1 advances, Mr. Nazre engaged in offensive, obstructionist

and difficult behavior toward Plaintiff. on sexual relations on two or three

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Plaintiff eventually occasions.

succumbed

to Mr. Nazre's

insistence

In October 2006 Plaintiff inforrned Mr. Nazre that she would no longer have a with him. Mr. Nazre started a consistent pattern of retaliation against her. against

personal relationship 9. Plaintiff.

Over the course of more than five years, Mr. Nazre engaged in retaliation He excluded her from numerous business meetings.

He removed her from business required

email discussions for her job.

where she had initially been included. her from interviewing

He failed to share information

He prevented

potential new employees.

In one case, Mr.

Nazre approached

the CEO of a company sponsored

sponsored

by Plaintiff and asked the CEO to join the Mr. Nazre failed to consult or inform

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board ofa different company

by Mr. Nazre.

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Plaintiff. When Plaintiff reported Mr. Nazres would never have happened

actions. she was told that it was unfair, that it

to a male partner, but that she should just accept it. Day 2007 Senior Partner Randy Komisar came into Plaintiff's by Leonard Cohen, inscribed with a

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office and gave her a book entitled "The Book of Longing" handwritten note from Mr. Komisar to Plaintiff.

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poems with strong sexual content.

At about the same time, Mr. Komisar asked Plaintiff out to a Plaintiff turned down dinner

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Saturday night dinner, telling Plaintiff that his wife would be out of town. his offer of dinner. Plaintiff considered the book and the one-on-one,

weekend-night

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invitation to be inappropriate

in the workplace. and belief, at least three administrative assistants complained After

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11.

Upon information

that they were being harassed or discriminated hearing of these complaints, Plaintiff expressed

against by KPCB partners in May 2007. concern and warned KPCB's

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Chief Operating KPCB assistants.

Officer about Mr. Nazre with the intent of helping the finn avoid future problems. engaged an outside investigator The investigator interviewed in response to the complaints of the administrative

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Plaintiff, but did not ask any questions

related to inappropriate

behavior by Mr. Nazre.

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12.

In late June 2007 Plaintiff reported Mr. Nazre's

sexual harassment

and retaliatory

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behavior to two Managing

Partners, Ted Schlein and Ray Lane, and to a Senior Partner, Juliet de

4
COMPLAINT FOR DAMAGES

1

Baubigny. After weeks without a response, Plaintiff told John Doerr about Mr. Nazres inappropriate behavior. Plaintiff also told Mr. Doerr that Randy Komisar had given her a book with sexualized content and had asked her out to dinner, and that she found this behavior inappropriate. She requested that the firm provide sexual harassment training as required by law. 13. Upon information and belief, Ray Lane and John Doerr discussed how to respond While acknowledging that Mr. Nazre 's behavior was

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to Plaintiff. Ray Lane met with Plaintiff

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inappropriate, Mr. Lane pressured Plaintiff to drop the matter because ofMr. Lane's close ties

8 with and mentorship of Mr. Nazre. Though Plaintiff had formally complained about Mr. Nazre's
9 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 Plaintiffs report of sexual harassment. 14. KPCB was aware of and did not take reasonable steps to prevent retaliation and KPCB management was aware of and did not prevent Mr. Nazre from

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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 empowered by KPCB to further retaliate against her. 15. In early December 2007, Plaintiff reported Mr. Nazre's continuing retaliatory acts

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to Ted Schlein and John Doerr and asked for their help to find a solution. She received no response. Instead, a few weeks later, Mr. Nazre. was promoted from Junior Partner to Senior Partner. This promotion made Mr. Nazre a Senior Partner in the Greentech Group where Plaintiff worked and gave him more direct control over her. 16. In early January 2008, KPCB retaliated against Plaintiff for her complaints by first

requesting that Plaintiff change the location of her office -- from the central corridor near John

27 Doerr to the back annex of the building in a group of mostly empty and guest offices -- because 28
5
COMPLAINT FOR DAMAGES

Mr. Nazre was being moved near Plaintiff s office. Plaintiff refused. KPCB nevertheless moved

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Mr. Nazre to a larger office across the hall from Plaintiff.

In addition.

KPCB asked Plaintiff to

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move to the China office to separate her and Mr. Nazre, who would remain in Northern California.

Plaintiff refused this blatant retaliation as well.
In mid-January 2008, Plaintiff went to Mr. Schlein and asked him ifhe had spoken she raised in December 2007. She described again to him the

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to Mr. Nazre about the retaliation retaliatory

actions by Mr. Nazre to which she had been subject. to do anything.

Mr. Schlein said he had not done

anything and asked ifit was still necessary conduct to Juliet de Baubigny

Plaintiff also reported Mr. Nazres at KPCB. Plaintiff

in her capacity as head of Human Resources

was told by one Senior Partner not to work on any projects with Mr. Nazre and by another Senior Partner to report directly to Mr. Nazre and have him review all her activities. 18. Shortly after her conversation continued with Juliet de Baubigny,

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Plaintiff told John Doerr
she wanted to

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that because of Mr. Nazre's

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despite her multiple complaints,

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move to the Digital Group -- away from Mr. Nazre and the Greentech of expertise and interest.

Group, and toward her area

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Mr. Doerr told Plaintiff he thought Mr. Nazre was treating Plaintiff Mr. Doerr told

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even worse than before because Plaintiff seemed happy in her recent marriage.

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Plaintiff that he would take care of the situation, but that he wanted Plaintiff to continue working
in the Greentech Group. In 2008 KPCB did not give Plaintiff her annual performance review. Typically,

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KPCB reviews every Junior Partner each year to assess performance used to determine gave PlaintitTher bonus, raise and promotion performance status. For example,

for the prior year, which is in 2007, when John Doerr of the

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review, he told her that because she was the top performer she would receive a

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Junior Partners and that she had the most positive internal feedback, significant bonus and raise.

In 2008, KPCB had told her she was going to receive her review maternity leave in mid-July. That did not happen, nor did she

before she left for a three-month

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receive her review upon her return. have an opportunity

Her exclusion

from the review process meant she did not or for additional compensation, or to hear

to present her case for promotion

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or refute feedback or criticism. retaliation

KPCB' s refusal to give Plaintiff a performance about retaliation 6
COMPLAINT FOR DAMAGES

review was

for her multiple complaints

by Mr. Nazre and about KPCB for its

1

refusal to do anything about Mr. Nazre. 20. In October 2008, after Plaintiff had returned from maternity leave, Ajit Nazre

2 3 4

continued to retaliate against Plaintiff. Plaintiff informed John Doerr in November of the continued retaliation and cited an example of Mr. Nazre excluding her from an important investment decision meeting. 21. Because of Ajit Nazre's continuing retaliation against Plaintiff, Plaintiff told John

5
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Doerr and Ted Schlein again in August 2009 that she did not want to be in the Greentech Group any longer. On August 6, Mr. Schlein asked whether Mr. Nazre was continuing to retaliate. Plaintiff responded that he was and that no one was doing anything about it. 22. On August 7,2009 Plaintiff sought advice from KPCB"s external human resources

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consultant. Plainti ff told the consultant about the discriminatory and retaliatory treatment she had been receiving from Ajit Nazre and other partners. The consultant told Plaintiff that she would not be successful at KPCB because she had complained and that going forward she should drop her complaints, because no one would do anything about them. 23. In September 2009 KPCB continued the retaliation with Plaintiffs performance

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review. Typically at KPCB, a Junior Partner is reviewed by his or her direct boss and also by other partners with whom the employee has worked closely, based on a list of proposed reviewers prepared by the employee. In contrast, for Plaintiffs 2009 performance review, many of the people that Plaintiff had worked with and proposed as reviewers were not assigned to her evaluation. Inexplicably, John Doerr, her direct boss, was not assigned to be one of her reviewers, despite her position as his Chief of Staff. This was not rectified until Plaintiff complained. People that Plaintiff had worked very little with were included. though she was not similarly asked to review them. Consequently, Plaintiffs 2009 performance review focused on the negative feedback of partners who did not work most closely with her and whom she had not proposed to review her. John Doerr, Ray Lane and Ted Schlein, three Managing Partners, met with Plaintiff to give her the review and told her that other partners gave her negative feedback. This review was further retaliation for her complaints about KPCB' s refusal to do anything about

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7
COMPLAINT FOR DAMAGES

1
2

24. compensation

Plaintiff believed that the retaliation at KPCB, because women generally For example,

and gender discrimination were not treated equivalently

were affecting her or promoted to

3 4 5 6
7

Senior Partner based on their gender.

male Junior Partners were allowed to add sponsorships each year, while female affected compensation, and the ability to

multiple Boards of Director positions and investment

Junior Partners were limited to just one. This difference because investment generate returns. 25. compensation Plaintiff also believed that retaliation through the assignment sponsorships

in treatment

impacted board positions,

outside perceptions

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and gender discrimination

were affecting her

of profits in the KPCB funds.

As is typical in venture fund that it manages. This

capital firms, KPC B retains a share of the profits of each investment share of the profits is commonly referred to as "carried interest". based on allocation

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The KPCB carried interest is made by KPCB Managing receives of each KPCB profits.

shared among the KPCB professionals Partners. investment

decisions

The larger the share of carried interest that a professional fund, the more money that professional Partners discriminated

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stands to make if that fund generates

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against women over time by allocating

smaller carried

from its various investment

funds to women than to men. The discrimination

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Women were not promoted

to higher levels within the firm that would have levels to women were allocated larger shares

resulted in high allocations, of carried interest. 26.

and men at comparable

19 20 21 22

Plaintiff communicated

her concern to John Doerr in October and November to the value she was delivering and to the

2009

that her KPCB compensation compensation outside KPCB.

was low compared

Mr. Doerr told her to stop complaining

about her compensation.

23
24

Plaintiff also stated as she had in the past that women were not being listened to at the firm and that she and other women were constantly identifiable Plaintiffs negative impact on KPCB's being interrupted performance. and ignored during meetings, despite

25
26 27

Although

no action was taken to increase Group to the From

compensation,

KPCB finally transferred

Plaintiff from the Greentech

Digital Group in December

2009 -- almost two years after her initial request for transfer.

28

then on, she reported to the leader of the Digital Group, Ted Schlein. 8
COMPLAINT FOR DAMAGES

1 2 3 4 5 6 7 8 9 10
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27.

On August 25, 2010, Ted Schlein gave Plaintiff her performance He described

review, which as

was again retaliatory. "appreciated

her work with CEOs of KCPB portfolio companies

and coveted".

However, the written review also cited "issues" with other partners. by Randy Komisar, whom Plaintiff had not

She later learned this feedback was spearheaded listed as a suggested 28. Plaintiff's

reviewer and whom she was not asked to review. treatment against Plaintiff related to technology company. Plaintiff

One example of KPCB' s discriminatory work on KCPB's investment

in a San Francisco-based of the investment

had been the primary contributor

and champion

at KPCB, but KCPB chose citing a "one Board per fund" maternity leave. In late 2010,

Randy Komisar rather than Plainti ff as its Board representative, policy for Junior Partners and Plaintiffs multiple Board members wanted him off the Board. expressed upcoming three-month

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unhappiness

with Mr. Komisar as a Board member and the company's concerns first to Mr. Komisar, then

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Plaintiff conveyed

to Mr. Schlein, who expressed

interest in serving on the Board himself, and then to Mr. Doerr. the investment, that she built the relationships Mr. Doerr told Rather than Plaintiff in with the with

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Mr. Doerr told Plaintiff that she championed the company's

team and that she had done almost all the work for KPCB.

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Plaintiff that she deserved the Board seat but that Mr. Komisar "needed a win", replace Mr. Komisar, KPCB responded to the company's concerns by instructing

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January 2011 to permanently

and without explanation

terminate

her relationship

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company so Mr. Komisar could build his own relationship. with the company perceived only because of her gender.

Plaintiff was ordered to stop working went public and was for this success,

In mid 2011, the company

as a great success for KPCB.

Plaintiff got minimal recognition

because KPCB had removed 29.

her from the relationship. a dinner event at

In early 2011, KPCB partners led by Chi-Hua Chien organized home of one of the partners. at KPCB-funded companies,

the San Francisco leading executives

The dinner was for select KPCB partners and as well as leading executives of other companies were invited and

KPCB thought were influential. attended. Mr. Chien deliberately Mr. Chien organized

Only male KPCB partners and male executives

excluded all KPCB women from the event solely on the basis of a second all-male dinner at the same partner's 9
COMPLAINT FOR DAMAGES

their gender.

home in August

1 2011. Women were excluded for the same reason. At a weekly Digital Group partner meeting
2 before the second dinner, Mr. Doerr brought up the all-male dinner in response to a female

3 partner's complaint; Mr. Chien replied that women were not invited because they would "kill the 4
buzz". The August 2011 dinner caused Plaintiff particular professional embarrassment because

5 6 7

she lived in the same apartment several of the attendees

building as the host of the dinner. The non-KPCB attendees

By chance Plaintiff ran into

in the lobby.

asked Plaintiff if she was joining

the dinner, and she had to say that she was not. She then ran into the CEO of a KPCB company She also had to tell him that she was not attending. review, which who gathered

8 on whose Board she served.
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On June 29, 2011, Ted Schlein gave Plaintiff her performance to the outside consultant

again focused on biased internal feedback. According

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internal input for the review process, Mr. Schlein had specifically Randy Komisar had added himself to Plaintiffs

added Chi-Hua Chien and

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reviewer list. Plaintiff had not listed Mr. Chien

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or Mr. Komisar as partners who worked closely with her and was not asked to review either of them. Plaintiffs written review included multiple criticisms of her interpersonal skills and

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interactions

with others at KPCB, including,

"The number of issues and clashes with your peers quite a bit, but acceptance by this

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and other partners that were discussed group is still not evident." other partner had problems Mr. Nazre and Mr. Komisar.

last year has decreased

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Mr. Schlein mentioned

verbally that every two years Plaintiff and one link, indirectly referring to

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and Plaintiff seemed to be the common

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31.
management

At around the same time, a female Junior Partner complained about sexual harassment by Mr. Nazre.

to KPCB senior

KPCB did nothing about it and allowed Mr. This failure to act allowed and of

Nazre to continue to direct the Junior Partner and her review. encouraged

23
24

Mr. Nazre to continue to retaliate against Plaintiff for her rejection and complaints actions towards her. In December about additional 2011 this same Junior Partner by Mr. Nazre. Upon about of

his sexually harassing complained

25
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to senior management

sexual harassment

hearing that the other woman had been harassed again, Plaintiff renewed Mr. Nazre and about KPCB's sexual harassment failure to address Plaintiffs

her complaints

27
28

and other employees'

complaints and following

and discrimination.

KPCB engaged an outside investigator 10
FOR DAMAGES

that

COMPLAINT

1

investigation, 32.

Mr. Nazre left KPCB. On October 25. 20 II Plaintiff flew to New York on a business trip with Ted private jet. Two business associates joined

2
3 4

Schlein and a male Senior Partner in Mr. Schlein's them for the flight. a two-day semiannual

Mr. Schlein. the Senior Partner and Plaintiff were traveling together to attend meeting with CIOs organized for the firm. Upon information associates and belief, Plaintiff,

5
6
7

Mr. Schlein and the Senior Partner joined business

for activities both nights.

even though she had left the two nights open and understood take place, was not invited. conference. semiannual 33.

business related activities were to from the firm at the dis invited from the May

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She was the only female representative and was subsequently

Plaintiff reported the exclusion CIO meeting. Plaintiff continued for her complaints

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to be excluded of harassment

from business activities and discrimination.

because of her gender She was not included in She was not and other

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and in retaliation interviews

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of two potential

new partners who were given offers at the end of2011.

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included in an all-male KPCB-sponsored important business associates

ski trip that included flying KPCB employees in January 2012.

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by private jet to Vail, Colorado

In December

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a Senior Partner, told Plaintiff that the personalities

of women do not lead

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because women are quiet. internally that three men, Chi-Hua Chien, Amol to General Partner. In addition, Plaintiff and

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Deshpande

In March 2012 KPCB announced

and Wen Hsieh, and no women, were promoted because they are women. reported harassment,

20
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other women were not promoted promoted because she repeatedly

Plaintiff was not and retaliation over the In

discrimination

22 23
24

past several years.

Plaintiff was employed

at KPCB longer than any of the men promoted.

fact, Mr. Hsieh had been hired into KPCB in a similar role as Plaintiff: supporting 35. extremely In March 2012 KPCB also reorganized important investment committee and changed the composition

John Doerr. of the

25

for the new fund KPCB was raising. All three recently promoted is extremely

Only one

26
27

woman was invited to join the committee. of the fund and are on that committee. decisions about which new companies

men are General Partners because it makes

The committee

important

28

to invest in for the new investment 11 FOR DAMAGES

fund being raised.

COMPLAINT

1 Participation
2 compensation her exclusion

on that committee that committee

and inclusion members

as a General Partner of the fund also affects the Plaintiff complained about

and other partners receive.

3 4 5 6
7

from the investment

committee

and about the failure to designate

her as a General

Partner for the new fund to John Doerr, Ted Schlein and Bing Gordon. Operating 36. comparably Officer, Eric Keller, responded KPCB discriminates to men, by compensating that KPCB was unwilling

The current Chief

to include her.

against Plaintiff and other women by failing to promote them them less than men through lower salary, bonus and carried that women are allowed to make as compared or discrimination are made, by sponsorship or

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interest, by restricting

the number of investments

to men, by failing to act when complaints excluding

of sexual harassment

women from meetings and discussions,

by failing to provide equivalent

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women as of men, by failing to include junior women comparably process, and by failing to provide opportunities firm for women as compared 37. Department to men. for visibility

to junior men in the interview

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Plaintiff has filed a charge of discrimination of Fair Employment

with the State of California The agency issued a Notice of

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and Housing in a timely manner.

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Case Closure and this lawsuit is brought within a year of the date of the Notice.

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FIRST CAUSE OF ACTION (Gender Discrimination in Violation of Gov't Code § 12940(a»
Plaintiff hereby incorporates by reference Paragraphs 1 through 37 of this Complaint as if

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fully set forth herein, and for a cause of action alleges as follows: 38. At all times herein mentioned, Code § 12940 California's Fair Employment and Housing Act,

21
22

Cal. Government KPCB.

et seq., was in full force and effect and fully binding upon
by that statute, in particular based on gender. section

23

Plaintiff was a member of a group protected discrimination in employment

24

12940(a), prohibiting 39. investment

25
26

The denial of promotion,

the denial of wages and carried interest in KPCB' s in the number of investments Plaintiff and other

funds to Plaintiff, the differences

27
28

women as compared

to men are allowed to make, the exclusion

of Plaintiff and other women of Plaintiff and other women

from business events, meetings and opportunities, 12
COMPLAINT

and the exclusion

FOR DAMAGES

1 2 3 4 5 6 7 8 9 10
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from important

managerial Code

functions

at KPCB constitutes

discrimination

based on gender and

violates Government 40.

§ I 2940(a).
and proximate result of KPCB 's unlawful actions, losses in compensation and other

As a direct, foreseeable

Plaintiff has suffered and continues employment

to suffer substantial

benefits and has incurred other economic funds.

losses including but not limited to loss of

wages and loss of carried interest in KPCB's

41.
oppressively, amounting

KPCB committed with the wrongful

the acts herein despicably,

maliciously,

fraudulently,

and

intention of injuring Plaintiff, disregard of Plaintiff

from an improper and evil motive s rights to be free from

to malice, and in conscious on the basis of gender.

discrimination

Plaintiff is thus entitled to recover punitive damages from

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KPCB in an amount according

to proof. SECOND CAUSE OF ACTION

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(Retaliation
Plaintiff hereby incorporates

in Violation of Gov't Code § 12940(h»
by reference Paragraphs 1 through 37 of this Complaint as if

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fully set forth herein, and for a cause of action alleges as follows: 42. At all times mentioned Code § 12940 herein California's Fair Employment and Housing Act,

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Cal. Government KPCB.

et seq., was in full force and effect and fully binding upon
by that statute, in particular forbidden section

s.

Plaintiff was a member of a group protected retaliation for opposing

12940(h), prohibiting Government 43. investment Code.

practices

under Part 2.8 of the

The denial of promotion,

the denial of wages and carried interest in KPCB' s in the number of investments Plaintiff as compared

funds to Plaintiff, the differences

to men are allowed to make, the exclusion opportunities, constitutes and the exclusion

of Plaintiff from business events, meetings and managerial functions at KPCB Code in

of Plaintiff from important practices forbidden

25
26 27

retaliation

for opposing

under Part 2.8 of the Government

violation of Govemment 44.

Code § 12940(h). and proximate result of KPCB's unlawful actions,

As a direct foreseeable

28

Plaintiff

has suffered and continues

to suffer substantial

losses in compensation

and other employment

13 COMPLAINT FOR DAMAGES

1
2

benefits and has incurred other economic loss of carried interest in KPC B' s funds. 45. oppressively, amounting KPCB committed with the wrongful

losses including

but not limited to loss of wages and

3 4 5 6 7 8 9

the acts herein despicably,

maliciously,

fraudulently,

and

intention of injuring Plaintiff, disregard of Plaintiffs

from an improper and evil motive rights to be free from retaliation. to

to malice, and in conscious

Plaintiff is thus entitled to recover punitive damages from KPCB in an amount according proof.

THIRD CAUSE OF ACTION (Failure To Take All Reasonable Steps To Prevent Discrimination From Occurring In Violation Of Gov't Code § 12940(k»
Plaintiff hereby incorporates by reference Paragraphs 1 through 37 of this Complaint as if

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fully set forth herein, and for a cause of action alleges as follows: 46. At all times mentioned herein California's Fair Employment and Housing Act

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Cal. Government KPCB.

Code § 12940 et seq., was in full force and effect and fully binding upon by that statute, in particular section from occurring.

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12940(k), prohibiting 47. termination, investment

failure to take all steps to prevent discrimination

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Allowing

Ajit Nazre to retaliate against Plaintiff over the years until his the denial of wages and carried interest in KPCB' s in the number of investments Plaintiff as compared

s. 18
19

the denial of promotion,

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funds to Plaintiff, the differences

20 21 22
23

to men are allowed to make, the exclusion opportunities, constitutes Government 48. and the exclusion

of Plaintiff from business events, meetings and managerial functions at KPCB from occurring violates

of Plaintiff from important

failing to take all reasonable Code § 12940(k). As a direct foreseeable

steps to prevent discrimination

24
25
26
27

and proximate

result of KPCB' s unlawful actions, Plaintiff and other employment

has suffered and continues

to suffer substantial

losses in compensation

benefits and has incurred other economic loss of carried interest in KPCB's funds.

losses including

but not limited to loss of wages and

28

III
14 COMPLAINT FOR DAMAGES

1 2

49.

KPCB committed the acts herein despicably, maliciously. fraudulently, and

oppressively, with the wrongful intention of injuring Plaintiff, from an improper and evil motive amounting to malice, and in conscious disregard of Plaintiff s rights to be free from retaliation. Plaintiff is thus entitled to recover punitive damages from KPCB in an amount according to proof. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendant as follows: 1. For compensatory economic damages, including but not limited to, lost back pay (including, but not limited to, salary and bonus wages), lost carried interest in KPCB's investment funds and future lost earnings; with legal interest, according to proof as allowed by law;

3
4

5 6
7 8
9

10
11 12

2.
3.

For punitive damages allowed by law; For an award to Plaintiffs of costs of suit incurred herein and reasonable attorneys' fees;

13 14 15 16 17 18 19

4. 5.

For an award of prejudgment and post-judgment interest; For injunctive relief to prevent sexual harassment, discrimination and retaliation; and.

6.

For an award to Plaintiff of such other and further relief as the Court deems just and proper.

20
21 22 DATED: May 10,2012 RUDY, EX ELROD, ZIEFF & LOWE, LLP

23
24 ALAN B. EXELROD Attorneys for Plaintiff

25
26

27

28
15
COMPLAINT FOR DAMAGES

1 2 3

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury.

4 5
6 DATED: May 10,2012 RUDY, EXELROD, ZIEFF & LOWE, LLP

7 8
9

BY@_p~4
ALAN B. EXELROD Attorneys for Plaintiff

10 11 12 13 14 15 16 17 18
19

20 21 22 23 24 25 26 27 28
16
COMPLAINT FOR DAMAGES

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