Here Is the Complaint Ellen Pao Filed in California Before She Sued Kleiner Perkins for Sexism

"My working conditions have become intolerable," Ms. Pao wrote in a complaint filed with the state of California.

Ms. Pao.

In her gender discrimination lawsuit against managers at Kleiner Perkins Caulfield & Byers, junior partner Ellen Pao didn’t seem to be holding back. But a complaint she filed with the state of California first includes some accusations that never made it into the lawsuit.

Betabeat obtained a copy of the complaint, which Ms. Pao filed with the California Dept. of Fair Employment and Housing a month before her discrimination lawsuit was filed. The complaint requested an immediate right-to-sue, a standard procedure in California in which the department accepts complaints but does not investigate them. The department granted Ms. Pao the automatic right to take the issue to court.

In the complaint, Ms. Pao says she believes managers at Kleiner Perkins had complained about her to others outside the firm “by among other things making unjustified critical comments about me to others in positions to affect my access to new employment and business opportunities.”

That accusation did not make it into the lawsuit, which focuses only on Ms. Pao’s experience inside Kleiner Perkins. In the suit, Ms. Pao accuses Kleiner Perkins of systematically disadvantaging women and fostering an environment where she could be sexually harassed by a coworker and then professionally and socially shunned by a group of male coworkers.

“My working conditions have become intolerable,” she wrote.

Another accusation in the complaint, that women at Kleiner Perkins “are denied their legal rights in connection with pregnancy and childbirth and are discriminated against when they become pregnant,” is glossed over in the lawsuit.

In the lawsuit, Ms. Pao alleges that she was pregnant around the time that she was supposed to get an annual review, which she never received. However, she does not explicitly say that she and other women were discriminated against based on pregnancy.

A clerk at DCFEH said Ms. Pao’s discrimination complaint was the first filed against Kleiner Perkins, one of the 30 largest venture capital firms in the country. Kleiner Perkins, which prides itself on having a higher than average number of women partners, has said the lawsuit is without merit “following a thorough independent investigation of the facts.”

Ms. Pao continues to work at Kleiner Perkins, where things are reportedly a bit awkward at the moment. Her accused harasser left the firm a year ago.

[scribd id=95230593 key=key-2mc16qxxqv4k47zbe21e mode=list] Here Is the Complaint Ellen Pao Filed in California Before She Sued Kleiner Perkins for Sexism