Kleiner Perkins denies Ellen Pao's harassment complaint

Kleiner Perkins filed a seven-page response that denied the gender discrimination and retaliation charges brought by junior partner Ellen Pao in a lawsuit last month, stating that her complaints were "without merit."

In other words, Kleiner Perkins has made good on its promise to "vigorously defend our reputation," as Kleiner's senior partner John Doerr said in a statement last month.

The issue at hand is a gender discrimination complaint that junior partner Ellen Pao filed against the venture capital firm in the Superior Court of California on May 10. The complaint alleges that Pao endured five years of retaliation for rebuffing sexual advances from senior partners and that the company discriminated against her and other female employees when it came to promotions and pay.

In its response filed today (see below), Kleiner Perkins wrote, "KPCB vigorously denies that it discriminated against plaintiff, retaliated against plaintiff after she complained about harassment or discrimination, or that it violated its obligation to take reasonable steps to prevent discrimination from occurring." It also added, "As is consistent with the other flawed and false allegations in her complaint, plaintiff has twisted facts and events in an attempt to create legal claims where none exist."

The response lists Pao's yearly performance reviews, which say she is "territorial," too "passive," and not a "good team player."

In addition to asking the court to dismiss the complaint and grant Pao nothing, the venture capital firm is also claiming "affirmative defenses." This means it is trying to make a case that the lawsuit itself is invalid and that Pao "fails to state a claim upon which relief may be granted."

Despite bringing the complaint against her employer, earlier this month Pao said she didn't have any plans to quit the firm.

Ellen Pao v Kleinders Perkins - June 13,2012