The plaintiffs — Dawn-Shemain Weeks, Margaret Hines, and Shannon Schlagenhauf — formerly worked as executive assistants for CMEA and are making 35 different allegations regarding inappropriate sexual behavior. Most of the complaints are direct at John Haag, who served as CMEA’s chief operating partner between 2006 and 2012.

“Throughout the duration of their employment at CMEA, Haag spoke and/or behaved in sexually and racially inappropriate ways. Comments and ‘jokes’ about women, sex, and race were a common and tolerated part of the work environment at CMEA. CMEA’s owner and partners also spoke and behaved in ways that inappropriately injected sex into the workplace,” the lawsuit outlines.

Allegations the three made against Haag include watching porn on his work computer, rude nicknames, explicit and vulgar gestures, and threats to fire the plaintiffs if they “did anything to displease him.”

On April 30, the plaintiffs decided to report Haag’s conduct to CMEA’s three managing directors, who were allegedly aware of it through the reports of other women. They reportedly conducted an investigation through the third-party human resources providers, which uncovered years of the alleged behavior, and negotiated a “buy-out” of Haag’s interest in CMEA’s funds. The firm then took measures to improve the workplace atmosphere, but it allegedly continued to act inappropriately and make comments implying the plaintiffs’ jobs were on the line. Weeks resigned at the end of January.

The plaintiffs are claiming to have suffered significant injuries, trauma, and distress that have adversely impacted their mental and emotional health as well as financial loss. They are asking for a jury trial for all causes of action, general and compensatory damages, attorney’s fees and costs, punitive and exemplary damages, and prejudgment interest on all amounts claimed.

Sexual harassment and gender discrimination are pervasive problems in the male-dominated tech world, and part of this is due to the lack of women in the industry. A study conducted by Stanford in conjunction with the Kauffman Foundation and Women 2.0 found that nearly 18 percent of women in tech had experienced discrimination, and the average tech workplace is not an inviting environment for women and minorities.

Last year, another major sexual harassment scandal hit tech when Ellen Pao brought a sexual harassment and gender discrimination suit against her employer, well-known venture capital firm Kleiner Perkins Caufield & Byers. Mistreatment of women in tech extends all the way from executive offices in Sand Hill road to offhand jokes in co-working spaces.

Women represent less than 10 percent of venture capitalists, 3 percent of startup founders, and 14 percent of executive officer positions.

Warning! Not for innocent eyes- read the full suit below:

Haag Case

Photo Credit: Shutterstock

Today on “As Silicon Valley Turns,” we learn the true reason for Square chief operating officer Keith Rabois’ departure: He’s being accused of sexually harassing a Square employee.

In a very personal blog post this afternoon, Rabois detailed the story of meeting and befriending a man who would eventually go on to work at Square. Seemingly out of the blue, a New York attorney representing the employee threatened Rabois and Square with a lawsuit last week, accusing him of a nonconsensual relationship and “some pretty horrible things.” The lawyer claimed the accusation would be dropped if Rabois paid millions of dollars.

“I realize that continuing any physical relationship after he began working at Square was poor judgment on my part,” Rabois wrote. “But let me be unequivocal with the facts: (1) The relationship was welcome. (2) Square did not know of the relationship before a lawsuit was threatened; it came as a complete surprise to the company. (3) He never received nor was denied any reward or benefits based on our relationship. And (4), I did not do the horrendous things I am told I may be accused of. While I have certainly made mistakes, this threat feels like a shakedown, and I will defend myself to the full extent of the law.”

Rather than making the situation worse for Square, Rabois said he decided to leave the company, which is now breaking into the mainstream via Starbucks and sitting on a new $200 million funding round at a $3.25 billion evaluation.

“I deeply regret that I let my personal and professional lives to become intertwined, and I apologize to my colleagues and friends (at Square and elsewhere) who I’ve let down, and who will bear the brunt of some of the unnecessary, negative attention this situation will likely bring,” Rabois wrote.

But he won’t stay quiet for long — Rabois hints that he’s working on a new project to be announced in February.

Square offered the following statement to VentureBeat and other news outlets:

The first we heard of any of these allegations was when we received the threat of a lawsuit two weeks ago. We took these allegations very seriously and we immediately launched a full investigation to ascertain the facts. While we have not found evidence to support any claims, Keith exercised poor judgment that ultimately undermined his ability to remain an effective leader at Square. We accepted his resignation.

Photo: Yaniv Golan/Flickr

In May, a shocker came out of big-time venture capital firm Kleiner Perkins. Partner Ellen Pao accused the firm of gender discrimination and sexual harassment and filed a lawsuit for damages. In her suit, Pao alleged that in 2006, fellow partner Ajit Nazre pressured Pao to have sex with him on a trip to Germany. She also said KPCB partner Randy Komisar gave her a sexually graphic book (“Book of Longing” by Leonard Cohen) and invited her to dinner while his wife was away. Pao also contended that she was denied performance reviews and received negative feedback from individuals with whom she had not worked with extensively.

Several days after the news broke, Komisar responded to the allegations, calling them false, but this is the first fully detailed response from the defendants.

The six page rebuttal filed in court by Kleiner Perkins’ law firm Orrick, Herrington & Sutcliffe addresses each of Pao’s accusations with detailed denials. It says Pao was not pressured to be in a relationship with or marry the KPCB partner she is accusing of harassment, Ajit Nazre. Instead, it says Pao told her superior Raymond Lane when the relationship was over, that he and the other partners supported her, and she “thanked Lane for his help and understanding.”

As for the book from Komisar, the filing says it was actually purchased for Pao by Komisar’s wife. It also points to the book’s rave reviews, and claims Pao didn’t return or object to the gift in the years after receiving it.

KPCB says there was no retaliation via performance reviews, and that the 2009 negative feedback (such as speak up more effectively, present more investment ideas) was “hardly retaliatory input.” Overall, the reviews hammered on Pao not being a team player and needing to speak up and be more proactive.

Via BetaBeat

Kleiner Perkins Caufield and Byers managing partner John Doerr responded to partner Ellen Pao’s lawsuit against the company, involving sexual harassment and retaliation.

“The last several days have been a difficult time for me and my partners at Kleiner Perkins Caufield & Byers,” said Doerr in the statement. “It is not easy to stand by as false allegations are asserted against the firm, especially because legal constraints prevent us from responding fully at this time.”

Pao, who remains a partner at the firm, filed the lawsuit earlier this month, saying that fellow partner Ajit Nazre began courting her for a sexual relationship in 2006. Allegedly Pao rejected Nazre’s advances, but gave in and began a sexual relationship with him that same year. She claims that when she ended the relationship, Nazre set out to retaliate against her, and that she received no help from the managing partners, naming Doerr in the complaint.

This is a big hit against the venture firm, which has been known for bringing women into the male-dominating investing industry. The company currently has 12 female partners at the firm.

Pao also claims that she was denied performance reviews and was receiving negative feedback from individuals with whom she had not worked with extensively. Kleiner’s lawyers are likely to argue that this lawsuit is a product of that negative feedback. In his statement, Doerr mentions that the firm has hired on an investigator who (obviously) believes the “allegations are without merit.”

See Doerr full statement below:

The last several days have been a difficult time for me and my partners at Kleiner Perkins Caufield & Byers, a firm I’m proud to have been a part of for 32 years. It is not easy to stand by as false allegations are asserted against the firm, especially because legal constraints prevent us from responding fully at this time. But we have been heartened to hear from so many people – including many women – who have reached out to convey their support.

We have taken great care to treat this situation seriously, swiftly, and with integrity. We hired an expert, independent investigator to conduct a thorough inquiry. The investigator’s report concluded that the allegations are without merit and that our firm does not discriminate on the basis of gender.

In the end, facts – not unfounded claims – will determine the outcome of the suit filed against us. We will vigorously defend our reputation and are confident we will prevail.

But until this matter is resolved I hope those judging Kleiner Perkins will remember one thing about us: our pioneering track record in diversity.

We have long believed the best thinking comes from a diverse set of minds and have highly valued diversity in our partnership and ventures. We are proud of our track record. Our firm today is one of the most diverse in gender, age and ethnicity, as is our equally diverse network of great entrepreneurs, including the women who founded or lead companies such as Auxogyn, Coursera, Genomic Health, Lockerz, One King’s Lane, Plum District, Rent the Runway and Veracyte, among others. Most importantly, we’re backing them not because they are women, but because they are the best at what they do.

That is the same reason we have a dozen female partners at our firm – the most of any leading venture capital firm – including women who are leaders across our Digital Growth Fund, our newest venture fund, our Life Sciences Venture Team, our Human Capital Team, and our Marketing and Communications and Finance functions. They are outstanding executives and leaders.

We are fortunate and grateful to have so many supporters who continue to believe in Kleiner Perkins and our values. Thank you all for your unwavering and heartfelt support.

John Doerr

The letter prompted HP’s board to investigate Hurd. While it found no evidence of sexual harassment, the board concluded that Hurd acted inappropriately in failing to disclose his close personal relationship with Fisher, a former soft-porn actress who got a job showing Hurd around at HP’s marketing events. HP accused Hurd of falsifying expense reports, and Hurd admitted he did not live up to HP’s standards.

The letter reportedly accuses Hurd, who has since become co-president of Oracle, of disclosing company secrets to Fisher, such as HP’s pending $13 billion acquisition of EDS. However, Fisher acknowledged that the letter contained many inaccuracies. That is one reason Hurd has fought to keep it secret.

In the opinion (embedded below), Delaware Chancery court judge Donald Parsons said that much of the information was already public and that he determined the contents of the letter were not protected.

Amy Wintersheimer, attorney for Mark Hurd, said in a statement,”We are disappointed with the court’s ruling and will appeal the matter. We believe the letter, which was clearly marked ‘confidential,’ should remain that way. As has been admitted, the letter contains many inaccuracies. Mr. Hurd long ago resolved the matter and has moved on.”

The opinion discloses a few of the letter’s details, such as Hurd being accused of using corporate funds to “wine and dine” Fisher and leaking “potentially material” secrets about the company.

While some allegations are candid, they are not graphic or lurid, Parsons said. The judge did say that some “intimate details” about Hurd’s private life and his relationship with his family were legitimate topics to be kept private. So it is likely that some material will be redacted from the letter.

The dispute over the letter stems from a lawsuit by a shareholder, Ernesto Espinoza. His attorney wants HP’s records related to Hurd’s resignation and severance. HP itself agreed that the letter is not confidential.

Mark Hurd letter order// < ![CDATA[
//

The allegation was contained in the letter that Fisher’s attorney, Los Angeles celebrity attorney Gloria Allred, wrote to Mark Hurd during July of this year. The allegation is not independently substantiated, but the fact that it was contained in the initial letter to HP shows why the HP board, which has been mocked for its behavior, acted so quickly to investigate the matter. That letter set off a chain reaction of events that led to HP’s firing of Hurd on Aug. 6. (HP, incidentally, maintains that Hurd resigned and was not fired; but he was forced to resign).

Hurd’s firing was so shocking — since he had helped turn HP into the world’s largest tech company — HP’s stock value lost $9 billion by the end of Aug. 9. The story took a not-so-lurid turn when Fisher (pictured right) came forward to say that — despite the fact that she filed a sex harassment lawsuit against Hurd — she never had sex with Hurd and was sorry he lost his job over the matter. Hurd admitted to failing to live up to HP’s code of conduct. Then HP’s PR nightmare grew as nude Playboy photos of Fisher and her soft porn career turned up.

Throughout the whole media maelstrom that followed, the EDS matter never came up; allegedly, the Allred letter said that Hurd told Fisher about the deal in March, 2008. The $13.9 billion deal was disclosed to the public until May, 2008. That allegation was likely something that the board knew would draw the attention of regulators at the Securities and Exchange Commission, since it represents a breach of fiduciary duty and likely violates insider trading laws. The story does not say if the board substantiated that the leak happened.

The salacious story consumed Silicon Valley until Hurd (pictured right) got hired at Oracle on Sept. 6 and HP’s board replaced him with former SAP chief executive Leo Apotheker. Then the story died out. Just when everyone thought it had died down, this pair of stories will surely get tongues wagging again.

Both stories say they have reconstructed the events that led to Hurd’s firing as closely as they can, but they don’t have on-the-record interviews with the two people who have a lot of the answers: Hurd and Fisher. While Fortune alludes to the fact that the attorney letter revealed Hurd had disclosed a “professional secret” to Fisher — which is probably why HP’s attorneys had to take the allegation as seriously as they did — the Wall Street Journal discloses more details of the letter and spills the facts about the EDS leak.

Fortune chose to print considerable detail about Fisher, including her divorce details, a judgment against her for failing to pay rent, and just about everything except the address of the staffing agency where she worked for her mother in New Jersey. The detail is interesting, but it’s not particularly enlightening. Hurd admitted being alone with Fisher in each other’s hotel rooms. But there was no evidence to support Fisher’s claim that Hurd violated HP’s harassment policy. As has been reported, the board eventually became alarmed that Hurd wasn’t telling the full truth about the matter. He was fired because the board lost confidence that he was being honest with them.

For instance, Hurd allegedly told directors that he didn’t know Fisher had acted in adult movies. But HP investigators found that he had used his computer to visit web pages showing her in pornographic scenes, including a site called “erotic4u.com.” Hurd had also said he didn’t know Fisher well, but the letter had eight pages of details of meetings between the two in hotels around the world. And subsequent investigations showed that he had dined with her and, in expense reports filed by someone else, did not disclose that. In fact, the two had met on a couple of occasions when HP did not have any relevant marketing event hosted by Fisher.

Hurd was introduced to Fisher in 2007 by the CEO’s unofficial chief of staff, who was named Caprice McIlvaine by the WSJ and Caprice Fimbres by Fortune. (Evidently her name is Caprice Fimbres McIlvaine). McIlvaine, who resigned a few days after Hurd, told investigators she had spotted Fisher on the reality TV show Age of Love and thought she would be appropriate to help prioritize the HP customers at various HP marketing events. The events ended in late 2009.

When the letter arrived and HP began investigating, the board was inclined to believe Hurd. But as the probe proceeded, the support eroded. While Hurd wanted to keep the matter quiet, HP’s board recalled the spying scandal that cost then-chairman Pattie Dunn her job. Hurd knew that HP’s investigators spied on journalists, but he emerged unscathed in the 2006 scandal. Concerned that regulators would criticize the board for not disclosing an important matter — including the EDS allegation — the board took the investigation seriously.

Fortune said that two HP directors, former Medtronic CFO Robert Ryan and Lucille Salnany, were convinced that Hurd had to be fired. They had been in daily contact with HP’s investigators on the matter. Two other directors, former IBM chief financial officer John Joyce and legal services firm founder Joel Hyatt, believed that Hurd should stay. The others, including Netscape founder Marc Andreessen, former Rohm & Haas CEO Rajiv Gupta, former Wachovia CEO G. Kennedy Thompson, and McKesson CEO John Hammergren, began the fateful board session undecided. After the investigation was over, all 10 directors had swung against Hurd, Fortune said.

At one point, Andreessen visited Hurd at home and told him, regarding the hiring of a porn actress, that, “You have created a situation ideally suited for TMZ,” a reference to the tabloid TV show and web site, the Journal reported. Hurd tried to hang on to his job and settled the lawsuit with Fisher on the eve of his firing. Fisher said in the settlement that her earlier letter had “many inaccuracies” without saying what they were. She added, “I do not believe that any of your behavior was detrimental to HP or in any way injured the company or its reputation.”  When Hurd’s attorneys told the board of the settlement with Fisher, some directors felt Hurd had cut the investigation off. Then, on the morning of Aug. 6, Hurd resigned. The announcement came out after the stock market closed that day. The Journal said the question of what Hurd had disclosed about the EDS deal remains unresolved.

Left unsaid is why these full investigative pieces are appearing now. Perhaps the lawsuit over piracy between SAP and Oracle has turned dirty and sources on both sides are helping the journalists in question.