DLA Piper EEOC Position Statement With Exhibits

October 29, 2019
VIA EEOC RESPONDENTS’ PORTAL
Ms. Rosa M. Salazar

Director, EEOC San Jose Local Office
96 North Third St., Suite 250
San Jose, CA 95112
Re: EEOC Charge No. 556-2020-00008
Dear Ms. Salazar:
We represent DLA Piper LLP (US) (“DLA Piper” or “the Firm”) in the above-referenced
matter. DLA Piper hereby submits its position statement to assist the Equal Employment
Opportunity Commission (“Commission”) with its impartial investigation of the Charge of
Discrimination of Ms. Vanina Guerrero 1 (“Charge”). If you have any questions or requests for
further information in connection with this matter, please do not hesitate to contact us.
DLA Piper provides this position statement based on its knowledge and investigation to date.
The facts set forth below are subject to change, revision, or supplementation based on the
receipt or discovery of additional information or the further clarification of Ms. Guerrero’s
allegations. This position statement is not intended to include all facts, defenses, or arguments
responsive to the Charge. Finally, DLA Piper denies all Charge allegations not specifically
admitted herein.
In addition, several letters have been filed that purport to supplement the above-referenced
Charge, including an October 21, 2019 supplement filed by “Jane Smith,” an October 23, 2019
supplement filed by Leah Christensen, and an October 24, 2019 supplement filed by Ms.
Guerrero. While this position statement addresses some portions of those submissions, DLA
Piper will respond fully to all such “supplements” in due course, and does not waive—and
instead expressly reserves—all rights related thereto.
1
Ms. Guerrero’s attorney previously demanded that DLA Piper change all Firm-related references to Ms.
Guerrero to her married name, Vanina de Verneuil. However, because Ms. Guerrero has chosen to file her
Charge using her maiden name (Guerrero), DLA Piper will refer to her as Ms. Guerrero herein.
Ms. Rosa M. Salazar
October 29, 2019
Page 2
I. INTRODUCTION
This matter arises from a close personal relationship between two equity partners 2 at DLA
Piper—Louis Lehot and Vanina Guerrero. The two had known each other since 2004 when
they briefly worked in the same office of another firm. Ms. Guerrero joined DLA Piper’s Palo
Alto Office in September 2018 and worked closely with Mr. Lehot in the Palo Alto office.
In her Charge, Ms. Guerrero alleges claims under federal law for gender discrimination, hostile
work environment based on sexual harassment, and retaliation. Her Charge focuses on four
alleged sexual assaults she claims she suffered at the hands of Mr. Lehot between September
and November 2018. She alleges that, after a fifth purported attempted assault in “late winter,
early spring,” she “made it clear” that she would never “be in an intimate relationship with Mr.
Lehot.” After this, she claims, Mr. Lehot repeatedly threatened her job. Ms. Guerrero also
claims that, after reporting Mr. Lehot’s alleged conduct to the Firm in July, DLA Piper
retaliated against her by moving Mr. Lehot to a nicer office and allegedly “contriving”
information about inappropriate conduct by Ms. Guerrero herself.
When Ms. Guerrero filed her Charge with the EEOC, she concurrently released it to the public
and the press. Since then, she has continued to play this matter out in various publications,
with new articles, instigated by her attorneys, published nearly daily. However, among the
various Charges and supplements filed with the EEOC and public statements, Ms. Guerrero
has provided no corroborating evidence establishing the alleged assaults, discrimination,
harassment, or retaliation because those allegations are false.
Ms. Guerrero’s own emails show that she was not subject to abuse or assault by Mr. Lehot. 3
In fact, dozens of emails and messages show that Ms. Guerrero was a willing participant in a
lengthy emotional flirtation with Mr. Lehot that she orchestrated to advance her career. By
just one example, on November 1, 2018—which is, according Ms. Guerrero, after Mr. Lehot
already had assaulted her three times—Ms. Guerrero sent Mr. Lehot a link to an article on the
reviews of the “best [bed] sheets” and, when Mr. Lehot responded there were “too many
choices,” she suggested they go together to Macy’s or Bloomingdales and “pick live.” Exh.
1.
2
Contrary to Ms. Guerrero’s suggestion, all partners at DLA Piper are equity partners; there are no non-equity
partners. Nor are there any formal designations as to seniority of partners, i.e., there are no “Senior Partners”
or “Junior Partners.”
3
DLA Piper has not had access to Ms. Guerrero’s text messages, WhatsApp messages, or other communica-
tions on her personal devices and accounts, which the Firm believes will contain further evidence disprov-
ing Ms. Guerrero’s claims.
Ms. Rosa M. Salazar
October 29, 2019
Page 3
On November 8, 2018, Ms. Guerrero sent an email to Mr. Lehot outlining proposed questions
for him to ask his lawyer as he began the process of negotiating the divorce from his wife (e.g.,
“Mitigating alimony payments—what are my best options?”). Exh. 2.
Notably, a confessional email Ms. Guerrero sent only to herself on Saturday, November
10, 2018 reveals her inner thinking—that Mr. Lehot “will help me” and that she should
“control him” and “leverage” him by offering him “friendship w/o anything”:
Exh. 3. Again, according to Ms. Guerrero’s Charge, at the time she crafted this email, Mr.
Lehot already had sexually assaulted her three times. Yet, in this candid email only to herself,
Ms. Guerrero says nothing about assault or fear or retaliation, and instead reveals her intent to
“get where [she] need[s] professionally” by giving Mr. Lehot, who was “in love” with her,
“friendship w/o anything.”
A month later, on December 7, 2018, after Mr. Lehot allegedly had assaulted her four times,
Ms. Guerrero confided to a friend that she’d had “amazing support from Louis and the
partnership,” and that the men at the Firm had been “super” to her, but “the woman not so
much :).” Exh. 25.
Perhaps most telling of all, Ms. Guerrero has conveniently omitted from her Charge and all of
her public accounts that she planned and took a personal trip with Mr. Lehot to Machu Picchu
in March 2019—after the four purported assaults she alleges in her Charge. Ms. Guerrero
planned the trip, working closely with a travel agent to make the arrangements—she prepared
a multi-day itinerary, ensured that she and Mr. Lehot had seats together on their flights and
stayed in the same hotels, and arranged for the charges to be placed on Mr. Lehot’s credit card.
Exhs. 26, 28. A photograph of Ms. Guerrero and Mr. Lehot shows them happily smiling in
front of the scenic vista and her wearing a Cartier Love Bracelet and a Bulgari ring he had
purchased for her (Exh. 27):
Ms. Rosa M. Salazar
October 29, 2019
Page 4
Ms. Guerrero even went out of her way to thank the travel agent who had helped her plan the
trip, emailing the agent: “Louis and I want to say thank you so much for putting together such
a wonderful tour. We’ve had such an amazing time and every detail was so well planned and
thought of by you.” Exh. 28.
That Ms. Guerrero would plan, take, and have an “amazing time” on a personal trip with Mr.
Lehot completely belies Ms. Guerrero’s assertion that, after the first two purported assaults in
Shanghai and Brazil, she “forfeit[ed] opportunities” to travel with Mr. Lehot because she was
“[a]fraid that [Mr. Lehot] would sequester her in a hotel room and physically force himself on
her” and “believed that not travelling with him was necessary to her physical health.”
DLA Piper takes very seriously claims of harassment, retaliation, and unprofessional conduct.
In fact, the Firm separated with Mr. Lehot on October 11, 2019 due to Mr. Lehot’s poor
judgment, including his undisclosed emotional relationship with Ms. Guerrero, another partner
in his practice group. However, as explained herein, Ms. Guerrero was neither assaulted nor
harassed; nor was she the subject of discrimination.
There was also no retaliation against Ms. Guerrero. Even if she had participated in protected
conduct by making a good faith complaint (she did not), the acts she characterizes as retaliatory
either did not happen or were taken for legitimate reasons. For example, Ms. Guerrero alleges
that DLA Piper retaliated against her by “contriving” information about inappropriate conduct
by Ms. Guerrero herself. In reality, in the course of investigating Ms. Guerrero’s allegations,
DLA Piper received credible allegations of inappropriate conduct by Ms. Guerrero.
Specifically, a subordinate reported that Ms. Guerrero engaged in inappropriate behavior
toward, and harassed, that individual. In light of these allegations, as well as other troubling
Ms. Rosa M. Salazar
October 29, 2019
Page 5
allegations about Ms. Guerrero’s conduct in the office, 4 and her ongoing refusal to participate
in the Firm’s investigation of those allegations, DLA Piper placed Ms. Guerrero on paid
administrative leave. This decision thus was not retaliation for Ms. Guerrero’s complaints
about Mr. Lehot, which she made more than two months before being placed on leave.
In fact, in the two months that passed after Ms. Guerrero made her allegations public (August
and September 2019), but before she was first asked to participate in an interview about her
own behavior (on September 30, 2019), she had continued working in the office without
incident. During that time, Ms. Guerrero had even continued working on transactions with
Mr. Lehot, at her own request, and he was complimentary of her work. The decision to place
Ms. Guerrero on paid administrative leave was not retaliation for the claims she made; rather,
it was a decision prompted by the new and serious allegations against her, and her refusal—
despite her obligations as a partner—to cooperate in the investigation of those allegations.
II. OVERVIEW OF THE EVIDENCE
A. Ms. Guerrero’s Interest in DLA
Ms. Guerrero and Mr. Lehot have known each other since 2004 when they met as associates
in the Paris office of Shearman & Sterling. Between 2004 and 2017, they kept in touch with
occasional correspondence, including for example a request from Ms. Guerrero to Mr. Lehot
for a letter of recommendation in 2009 and a similar email exchange in 2011.
But this matter begins in September 2017 during a work trip Mr. Lehot took to Hong Kong
where Ms. Guerrero and her family were living. At the time, Ms. Guerrero was working as an
in-house lawyer at Reliance Communication and Global Cloud Xchange. Mr. Lehot was in
Hong Kong for business and, as was his practice, sent emails to his contacts in the area inviting
them to meet him at the conference he was attending. Ms. Guerrero and Mr. Lehot decided to
meet for dinner before his flight home. At dinner, the two discussed a number of topics,
including Ms. Guerrero’s interest in leaving her current in-house position for a position as a
partner at a law firm in the United States. At some point in the prior year or two, Ms. Guerrero
had applied to Cooley and DLA Piper, though neither job had materialized.
Over the course of the following months, with Mr. Lehot’s sponsorship, Ms. Guerrero received
an offer to join the DLA Piper partnership. Throughout the spring of 2018, Mr. Lehot and Ms.
Guerrero exchanged friendly emails. See, e.g., Exh. 4. Ms. Guerrero arrived in the United
States in July 2018 to take the California Bar exam. She continued to express her excitement
4
These allegations are currently the subject of an independent investigation by a separate law firm. DLA
Piper reserves the right to supplement this response with the results of that investigation following its con-
clusion.
Ms. Rosa M. Salazar
October 29, 2019
Page 6
at joining the Firm and working with Mr. Lehot. In a July 31, 2018 email, for example, Mr.
Lehot wrote, “Vanina and I have to be back in SF for a Saturday night dinner.” Ms. Guerrero
responded to Mr. Lehot, saying, “Love how ‘Vanina and I’ sounds. Excited :).” Exh. 5.
B. Ms. Guerrero’s and Mr. Lehot’s Working Relationship
1. September 2018 Trip to Shanghai and Hong Kong
Ms. Guerrero joined DLA Piper as a partner and started work at the Firm in September 2018.
During her first week at the Firm, Ms. Guerrero, Mr. Lehot, and an associate went on a business
trip to Shanghai and Hong Kong. Ms. Guerrero’s presence during the week-long trip was
particularly important because she had just moved from Hong Kong and speaks Mandarin.
Ms. Guerrero’s Charge alleges that Mr. Lehot sexually assaulted her on the first evening of the
trip, i.e., Monday, September 10, 2018. Specifically, she alleges that they went to Mr. Lehot’s
hotel room and, “before she knew what was happening, [Mr. Lehot] had her lying down . . .
and was physically hugging and groping her. Upset and in shock, Ms. Guerrero told him no
and ran out of the room.” However, the following day, Ms. Guerrero sent an email to her
assistant regarding the return flight from China to San Francisco asking her assistant: “Can
you help make sure that Louis and I have seats together on the way back?” Exh. 6. 5
A few days after they returned home from China, on September 18, 2018, Mr. Lehot emailed
Ms. Guerrero to let her know that she was helping him reach people he could not reach before.
She responded: “Love it[.] You’re vibrating even higher than before :).” Exh. 7. Then, on
September 21, 2018, Mr. Lehot wrote “Feel the vibrations? The whole organization is working
for you.” Ms. Guerrero responded, “I feel them and am loving them =).” Exh. 8.
2. September 2018 Trip to Brazil and Argentina
On September 22, 2018, Ms. Guerrero and Mr. Lehot traveled on a business trip to Brazil and
Argentina, and when they landed, they met two Palo Alto associate attorneys who had arrived
on an earlier flight. Ms. Guerrero frames her participation on this trip as another example of
Mr. Lehot’s alleged bullying, asserting that, “[a]lthough the four lawyers were slated to sit
together, Mr. Lehot bumped he and Ms. Guerrero up to business class to allow him to be alone
with her.” But it is impossible that “the four lawyers were slated to sit together” because the
two associates who accompanied Mr. Lehot and Ms. Guerrero on the trip flew to Brazil on an
entirely different flight. Moreover, an email sent on September 21, 2018—the day before the
5
DLA Piper has confirmed that this email was sent at 8:08 a m. UTC on September 11, 2018, or 4:08 p m.
local time in Hong Kong.
Ms. Rosa M. Salazar
October 29, 2019
Page 7
trip—shows Ms. Guerrero providing her assistant with her mileage and frequent flyer infor-
mation in an attempt to secure for herself an upgrade to business class in order to sit with Mr.
Lehot. Exh. 9.
Ms. Guerrero claims that the second of the sexual assaults she allegedly suffered occurred
during this trip. Mr. Lehot and Ms. Guerrero had several business and team dinners during the
course of the trip. They also had dinner together alone on Wednesday, September 26, which
appears to be the night Ms. Guerrero alleges Mr. Lehot “touched and groped her” in his hotel
room, making her feel “trapped” and “in distress.” Early the next morning, however, Ms.
Guerrero sent a message via WhatsApp, a messaging platform that functions similarly to group
text messages, to the “South America Trip” WhatsApp group, consisting of Mr. Lehot, herself,
and the two associates. Ms. Guerrero’s message read: “Good morning! I’m heading up in 5
for breakfast in case anyone is hungry.” Exh. 10.
On September 29, 2018, the day after their return home from Latin America, Ms. Guerrero
messaged the same WhatsApp group saying: “Lou, [Associate], [Associate]! 6 Thanks again
for a wonderful productive trip!! So happy and grateful to be part of the team. Have a good
weekend!!” followed by a smiley and fist bump emoji. Exh. 11. Shortly thereafter, she sent
Mr. Lehot an email, which she closed with “Big hug.” Exh. 12.
Ms. Guerrero alleges that Mr. Lehot “preyed on what he saw as an opportunity to harm a
vulnerable junior female” and that as a result, “after Shanghai and Brazil, Ms. Guerrero opted
out of at least four subsequent business trips . . . she believed that not travelling with him was
necessary to her physical health, even if it impacted her performance.” However, numerous
emails show that Ms. Guerrero herself suggested extending or taking trips with Mr. Lehot. For
example, on October 3, 2018, Mr. Lehot forwarded to Ms. Guerrero and others an email about
a legal conference in Miami. Despite allegedly having been assaulted twice already, Ms. Guer-
rero nevertheless responded exclusively to Mr. Lehot: “Oooh if we go, I want to stay the
weekend in Miami or go to Bogota =).” Mr. Lehot responded: “I’ve never been to
Bogota. . .” Ms. Guerrero replied: “You’ll love it.” Exh. 13. 7
6
Respectful of their right to privacy, DLA Piper has redacted the associates’ names.
7
As discussed in more detail below, Ms. Guerrero’s emails also indicate that she expressed interest in a trip
to New York with Mr. Lehot in early December 2018 and that she did the lion’s share of planning a personal
trip for herself and Mr. Lehot to Machu Picchu in March 2019.
Ms. Rosa M. Salazar
October 29, 2019
Page 8
3. October Trip to Chicago and Ms. Guerrero’s and Mr. Lehot’s Deepening
Relationship
Ms. Guerrero and Mr. Lehot attended the DLA Piper Global Women’s Leadership Summit in
Chicago on October 16 and 17, 2018. Ms. Guerrero claims Mr. Lehot again sexually assaulted
her on this trip. Thus, according to Ms. Guerrero’s Charge, heading into November, she had
suffered three sexual assaults by Mr. Lehot.
However, emails from that time period indicate that Mr. Lehot and Ms. Guerrero had a close
relationship, with intimate correspondence, often initiated by Ms. Guerrero. For example, on
November 1, 2018, Ms. Guerrero sent Mr. Lehot a link to “best [bed] sheets” reviews. When
he responded that there were too many to choose from, she replied that he should pick the first
one, or that together they could “go to Macy’s, Bloomings [sic] and pick live” (Exh. 1):
Ms. Rosa M. Salazar
October 29, 2019
Page 9
Also on November 1, 2018, Mr. Lehot forwarded to Ms. Guerrero an email about a chef “VIP
experience” event and asked, “Interested?” Ms. Guerrero responded, “LOVE it! Let’s do it.
Want me to get [our assistant] to register us both? V.” Exh. 14. That same day, Mr. Lehot
forwarded an invitation to Ms. Guerrero to a featured car event in Boca Raton, to which Ms.
Guerrero responded, “I want in.” Exh. 15.
On November 2, 2018, Mr. Lehot forwarded to Ms. Guerrero, without comment, an email from
another DLA Piper partner calling Ms. Guerrero “amazing.” Ms. Guerrero responded:
“ :)! Wanted to say hi but you’ve been on calls all day. V.” Exh. 16.
On November 8, 2018, Ms. Guerrero sent to Mr. Lehot, whom she knew was in the process of
separating from his wife, a list of questions for him to ask his divorce attorney in an email to
his personal email account (Exh. 2):
Ms. Rosa M. Salazar
October 29, 2019
Page 10
These represent just a few of the friendly or even intimate emails between the two from this
time period. Others include notes such as “You rock! Craving a cookie!” (Guerrero to Lehot);
“Let’s get an iced coffee and cookie when [sic] in 5” (Lehot to Guerrero); “Ready when you
are” (Guerrero to Lehot); “Say bye if u end up leaving bf me” (Guerrero to Lehot); and “Sleep
well and enjoy the weekend” (Guerrero to Lehot). See Exhs. 17-19.
Mr. Lehot also bought Ms. Guerrero many gifts at her urging, including dresses, shoes, and
jewelry. For example, Mr. Lehot purchased a Hermes bracelet for Ms. Guerrero for approxi-
mately $600, which she later lost. To replace it, he purchased for her a $9,000 Cartier Love
Bracelet, along with a Bulgari ring, both of which she can be seen wearing in this picture from
a December 2018 Firm event, where Ms. Guerrero is standing next to Mr. Lehot (Exh. 20):
Ms. Rosa M. Salazar
October 29, 2019
Page 11
All of this evidence of romantic and flirtatious interaction is consistent with Mr. Lehot’s stated
position: that he never assaulted Ms. Guerrero and claims instead that they had a consensual,
emotional relationship with no sex or sexual activity.
4. Ms. Guerrero Reveals Her True Intentions in a November 10, 2018 Email
to Herself
Most telling of all is a stream-of-consciousness style email Ms. Guerrero sent only to herself
on November 10, 2018. The subject of the email is “Letizia.” 8 Exh. 3. The first paragraph
opens: “I need to focus on making decisions at work” and concludes “so beautiful – wake up
sexuality wherever I go. People are all over me – wakes up other women’s jealousy.” Further
in the email, Ms. Guerrero expressed her candid thoughts about Louis Lehot:
According to Ms. Guerrero’s Charge, at the time she crafted this email, Mr. Lehot already had
sexually assaulted her three times. But as her email demonstrates, when writing her own
candid thoughts for an audience only of herself—not Mr. Lehot, not her husband, and not DLA
Piper 9—Ms. Guerrero did not describe Mr. Lehot as abusive, bullying, or controlling. To the
contrary, Ms. Guerrero viewed herself as having the control, revealing her intent to “control”
8
Although it is not entirely clear what this subject line means, given the reference later in her email to “Reina,”
which means “Queen” in Spanish, it may be a reference to the current Queen of Spain, Queen Letizia Ortiz
Rocasolano.
9
There can be no question Ms. Guerrero never intended this email to be read by anyone but herself—not only
was she the only recipient, but the email reveals candid and potentially harmful statements about people very
close to her, including her husband.
Ms. Rosa M. Salazar
October 29, 2019
Page 12
Mr. Lehot by offering him “friendship w/o anything”; to “leverage” his love for her to obtain
his “help”; and to “get where [she] need[s] professionally.”
This is consistent with an earlier portion of the email, where Ms. Guerrero wrote: 10
Ms. Guerrero viewed her role to be to “inspire but don’t allow touch”—“not even a kiss.”
Again, this is consistent with Mr. Lehot’s recitation of the facts: that he and Ms. Guerrero had
a consensual, emotional relationship with no sex or sexual activity.
In short, the “Letizia” email, when read in its entirety, cannot be squared with Ms. Guerrero’s
Charge, or her allegations that she had suffered three separate sexual assaults leaving her fear-
ful and without recourse. Mr. Lehot was not hurting her; in her own words, “this man will
help me”—and by her own design.
5. Ms. Guerrero Learns She Has Failed the Bar Exam
On Friday, November 16, 2018, six days after she sent herself the “Letizia” email, Ms. Guer-
rero learned that she had failed the bar exam. In her Charge, she alleges that “[i]n response to
Ms. Guerrero failing the bar and knowing that Ms. Guerrero has a very low alcohol tolerance,
Mr. Lehot insisted on throwing a ‘Globe party’ at his home in Palo Alto for Ms. Guerrero.
Already upset and in a vulnerable state, Mr. Lehot used this opportunity to push a never-ending
supply of alcohol into her hands.” She alleges that he assaulted her at the event after the other
guests left, including trying to prevent her from leaving. Despite naming numerous individuals
in her Charge, she does not mention the name of any of the other guests at this alleged party.
Notably, “Globe parties” were known throughout the office as team-wide happy hours that Mr.
Lehot hosted on Friday afternoons in his office—not at his home. And Ms. Guerrero was a
10
“Panuelo” is a Spanish word for “handkerchief.”
Ms. Rosa M. Salazar
October 29, 2019
Page 13
regular and enthusiastic participant in these Globe parties. For example, Ms. Guerrero sent
the following What’sApp message in January 2019—after she allegedly had been assaulted
four times—to Mr. Lehot and the two associates from the South America trip (Exh. 21):
Emails following the purported November 16 assault reveal that Ms. Guerrero was still behav-
ing in a friendly, if not flirtatious, manner with Mr. Lehot. Thus, on November 19, the Monday
following the alleged “Globe party” assault, Ms. Guerrero emailed Mr. Lehot asking: “Can I
Ms. Rosa M. Salazar
October 29, 2019
Page 14
hitch a ride to [potential client] pitch? If not no worries I can UBER. Not sure if you have
something between now and then.” Exh. 22. Later in that same week, Ms. Guerrero sent Mr.
Lehot an email re “NYC dates” in which she says: “Hi Lou, Can’t remember if you said you
were good for NYC trip for Dec 4 5 and 6th.” When he responded yes and that he thought it
was a “brilliant plan,” she replied with a smiley face. Exh. 23. And a month and a half later,
on January 3, 2019, Mr. Lehot forwarded Ms. Guerrero an invitation to a “TechLaw” confer-
ence in India, asking “[s]hould we field trip to India?” Ms. Guerrero responded “BIG BIG
YES.” Exh. 24.
Moreover, on December 7, 2018, after the fourth alleged assault, Ms. Guerrero, responding
to a question from a friend about how life was going, said: “I've had amazing support from
Louis and the partnership but let’s just say my joining has also been a bit disruptive to the
team. Men super, the woman not so much :).” Exh. 25.
6. The Omitted Personal Trip to Machu Picchu in March 2019
Ms. Guerrero alleges that “[i]n late winter, early spring, Mr. Lehot, unable to take no for an-
swer made an aggressive attempt to sexually advance [sic] on Ms. Guerrero.” Ms. Guerrero
states that she made it clear to Mr. Lehot that she would never “be in an intimate relationship
with Mr. Lehot.” She says that, “[u]nlike prior rejections, as described above, this time after
being rejected, Mr. Lehot threatened her job, position at the Firm and compensation and told
her their working relationship would never be the same” (emphasis in original.)
But the reality is that, on March 22 and 23, 2019, Ms. Guerrero and Mr. Lehot took a personal
trip together to Machu Picchu—a fact Ms. Guerrero conveniently omits from her Charge. Ms.
Guerrero planned the trip, working closely with a travel agent to make the arrangements:
Ms. Rosa M. Salazar
October 29, 2019
Page 15
Exh. 26. The itinerary she proposed included a Saturday spent at Machu Picchu, either a sec-
ond day at Machu Picchu or back to Cusco, and Monday in Lima with dinner for her and Mr.
Lehot at a Michelin Star restaurant. Additional email correspondence shows Ms. Guerrero
overseeing payments being placed on Mr. Lehot’s credit card for their expenses, attempting to
obtain seats together on their flights, and requesting reservations for the two of them at the
same hotels. (Consistent with Ms. Guerrero’s plan to pursue a “friendship w/o anything” with
Mr. Lehot, she asked for separate rooms.) Exhs. 26, 28. For example:
Ms. Rosa M. Salazar
October 29, 2019
Page 16
A photograph from the trip shows them happily smiling in front of a scenic view of the ruins
(Exh. 27):
Again, this photograph is from a non-business trip which took place in March 2019 and which
Ms. Guerrero planned—after Ms. Guerrero alleges she was assaulted by Mr. Lehot four times.
It is also after she claims she “forfeit[ed] opportunities” to travel with Mr. Lehot because she
was “[a]fraid that [Mr. Lehot] would sequester her in a hotel room and physically force himself
on her” and thus “believed that not travelling with him was necessary to her physical health.”
Ms. Rosa M. Salazar
October 29, 2019
Page 17
Notably, Ms. Guerrero can be seen in this picture wearing the Cartier Love Bracelet and Bul-
gari ring Mr. Lehot purchased for her:
Following the trip, on March 24, 2019, Ms. Guerrero went out of her way to send a “thank
you” email to the travel agent (Exh. 28):
7. In June 2019, Mr. Lehot Hosts a Birthday Event for Ms. Guerrero
Mr. Lehot and Ms. Guerrero continued their flirtatious relationship through June 2019, when
Mr. Lehot hosted a birthday event for Ms. Guerrero at a jazz club in San Francisco. Emails
show them planning the event together, including the guest list, which did not include either
of their spouses (Exh. 29):
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October 29, 2019
Page 18
C. “The Deal” Matter Conflict
In early July 2019, Mr. Lehot and Ms. Guerrero had a falling out over a difference of opinion
regarding a work-related matter (the “Deal”). Specifically, they disagreed over whether her
time and the Firm’s resources were best spent pursuing work a transaction where the client had
not yet received sufficient funding to pay the Firm’s anticipated fees for the matter. It was
following this disagreement that Mr. Lehot’s and Ms. Guerrero’s relationship changed sud-
denly.
Ms. Rosa M. Salazar
October 29, 2019
Page 19
Ms. Guerrero alleges that the day after she and Mr. Lehot had this argument, she felt “she had
no choice but to tell Sang Kim, another partner on the Deal, about some of the things Mr. Lehot
had done since she started at the Firm.” While Ms. Guerrero did in fact tell Mr. Kim that she
found Mr. Lehot to be controlling, she never mentioned to Mr. Kim that she had been as-
saulted. 11 And Ms. Guerrero’s assertion that Mr. Kim told her that “she was lying and that this
was clearly a case of ‘she said, he said’” is simply untrue. Ms. Guerrero further claims that
“[o]utrageously, after disclosing the horrific treatment by Mr. Lehot to Mr. Kim, Mr. Kim
subsequently told her she was being taken off of the Deal.” In fact, Ms. Guerrero was removed
from the Deal at the client’s request, for the client’s own reasons.
D. Developments After Ms. Guerrero Made Her Complaints
Contrary to Ms. Guerrero’s Charge, in which she claims that Firm management did nothing in
response to her complaints, DLA Piper took several actions after learning of her allegations in
late July. The Firm moved Mr. Lehot to an office further away from Ms. Guerrero during its
investigation. This office is not “larger” than the office he previously occupied, as Ms.
Guerrero claims; the two offices are the same size. In addition, during the months of August
and September 2019 when they were both still working for the Firm, DLA Piper instructed
Mr. Lehot to limit contact with Ms. Guerrero to necessary client matters, and not to have any
one-on-one meetings or emails with her. On repeated occasions, however, when Mr. Lehot
emailed Ms. Guerrero and copied others who were also working on the matter, as he had been
instructed to do, she chose to respond exclusively to him, removing others from the email
chain. DLA Piper also requested that Ms. Guerrero sit for an interview so the Firm could fully
explore and understand her allegations. Through her counsel, Ms. Guerrero repeatedly refused
this request.
In late September, in the process of investigating Ms. Guerrero’s claims despite her lack of
cooperation, the Firm learned of credible allegations made by a subordinate against Ms.
Guerrero. Specifically, the subordinate reported that Ms. Guerrero had engaged in
inappropriate behavior toward, and harassed, that individual, and that Ms. Guerrero had
engaged in other serious misconduct.
Upon receipt of these allegations, on September 30, 2019, DLA Piper’s General Counsel,
Elisha King, notified Ms. Guerrero’s attorney that the Firm had been made aware that Ms.
Guerrero may have engaged in serious, inappropriate behavior toward a subordinate, and that
11
Ms. Guerrero also suggests in her Charge that two other Palo Alto partners “marginalize[d],” and “did
nothing” in response to, a report from Ms. Guerrero, but she does not even claim to have brought a com-
plaint to either of them, and in fact she never did so.
Ms. Rosa M. Salazar
October 29, 2019
Page 20
Ms. Guerrero would need to be interviewed immediately. Less than two days later, on October
2, Ms. Guerrero released her EEOC Charge to the press and public, claiming that DLA Piper
had “contrived” an investigation “[w]ithout disclosing any information” to Ms. Guerrero about
the allegations. That same day, DLA Piper’s outside counsel emailed Ms. Guerrero’s counsel
stating, “I think it is important for you to know more about the report of Ms. de Verneuil’s
[a/k/a, Ms. Guerrero’s] inappropriate conduct that we received while investigating her
allegations against Mr. Lehot. You have portrayed the existence of allegations against her as
contrived, which suggests to us that there is information regarding your client’s activities about
which you have not been made aware. Are you available for a call in the morning at 9:30 EST
tomorrow (Thursday)?” Ms. Guerrero’s attorney, Jeanne Christensen, refused to engage in
such a call and demanded instead that the Firm put the specific allegations in writing to her—
a demand she has repeated many times.
Such a demand is not consistent with best practices regarding internal investigations. An
individual accused of inappropriate conduct is not entitled to an advance written copy of the
allegations before being interviewed as part of an investigation. See, e.g.,
https://www.dfeh.ca.gov/wp-content/uploads/sites/32/2017/06/DFEH-Workplace-
Harassment-Guide.pdf (“The accused party is entitled to know the allegations made against
him/her, however it is good investigatory process to reveal the allegations during the interview
rather than before the interview takes place.”). Accordingly, DLA Piper has declined to
provide such a writing and continues to request Ms. Guerrero’s participation in an
investigation. To date, through counsel, Ms. Guerrero has refused to participate.
In light of the allegations of misconduct against Ms. Guerrero regarding inappropriate conduct
toward a subordinate, other troubling allegations against Ms. Guerrero which are currently
being investigated by an outside law firm, and Ms. Guerrero’s refusal to participate in that
investigation, DLA Piper placed Ms. Guerrero on paid administrative leave on October 14,
2019. Ms. Guerrero has filed a separate supplemental charge related to this action and her
claim of retaliation, to which DLA Piper will respond in accordance with the EEOC’s provided
schedule.
On October 11, 2019, the Firm terminated its relationship with Mr. Lehot, finding that he had
shown poor judgment in, among other things, forming an overly personal relationship with
Ms. Guerrero, which was not disclosed to the Firm.
III. DLA PIPER’S RESPONSE TO MS. GUERRERO’S CHARGE
The aforementioned evidence, which is only a portion of the information DLA has amassed to
establish the falsity of Ms. Guerrero’s Charge, demonstrates that Ms. Guerrero sought, in her
own words, to “[c]ontrol” Mr. Lehot through a relationship of “friendship w/o anything.” Her
self-confessed intention was to use him to “get [her] where [she] need[ed] professionally.”
Ms. Rosa M. Salazar
October 29, 2019
Page 21
When their relationship deteriorated and she felt she could no longer “[l]everage” his feelings
for her for her own gain—apparently after the two had a disagreement over the Deal—she
reacted by bringing serious allegations against Mr. Lehot and later publicizing them.
A. Ms. Guerrero Is Not an Employee, and Therefore She Cannot Avail Herself of
Title VII or Similar State Laws
The U.S. Supreme Court has recognized that there is a material distinction between a partner
and an employee for purposes of Title VII, and that only employees may avail themselves of
the protections of the statute. Clackamas Gastroenterology Assocs., P. C. v. Wells, 538 U.S.
440 (2003); see also Hishon v. King & Spalding, 467 U.S. 69, 79 (1984) (Powell, J., concur-
ring) (cautioning that Court’s holding that a law firm associate could sue under Title VII should
not be read to extend to law firm partners because “[t]he relationship among law partners dif-
fers markedly from that between employer and employee—including that between the part-
nership and its associates”).
Ms. Guerrero is an equity partner at DLA Piper. There are no non-equity partners at the Firm.
Nor are there any formal designations as to the seniority of partners, i.e., there are no “Senior
Partners” or “Junior Partners.” As an equity partner at the Firm, Ms. Guerrero participates in
profits and losses, faces exposure to liability, is invested in the Firm, and maintains partial
ownership of Firm assets. Under such circumstances, she does not qualify as an employee for
purposes of Title VII. See Bluestein v. Central Wis. Anethesiology, S.C., 769 F.3d 944, 956
(7th Cir. 2014) (affirming summary judgment for defendant after finding that plaintiff, a full
partner with equal voting rights in an anesthesiology practice, was not an “employee”). As
such, she cannot avail herself of the protections of that statute, nor of similar state statutes such
as the California Fair Employment and Housing Act.
B. Ms. Guerrero, as the Architect of Her Relationship with Mr. Lehot, Was Not
Subject to Unwelcome Sexual Harassment
Even if Ms. Guerrero could bring a harassment claim under Title VII or another statute, to
make a prima facie case of a hostile work environment, she would have to show “that: (1) she
was subjected to verbal or physical conduct of a sexual nature, (2) this conduct was
unwelcome, and (3) the conduct was sufficiently severe or pervasive to alter the conditions of
[her] employment and create an abusive working environment.” Fuller v. City of Oakland, 47
F.3d 1522, 1527 (9th Cir. 1995) (internal quotations omitted). “The gravamen of any sexual
harassment claim is that the alleged sexual advances were ‘unwelcome.’” Meritor Sav. Bank,
FSB v. Vinson, 477 U.S. 57, 68 (1986) (citing 29 CFR § 1604.11(a) (1985)).
Ms. Rosa M. Salazar
October 29, 2019
Page 22
Ms. Guerrero fails to make out even a prima facie case because, to the extent there was any
verbal conduct of a sexual nature, she was the architect of this conduct, seeking to “[l]everage”
Mr. Lehot’s feelings for her that she cultivated in order to use him to “get [her] where [she]
need[ed] to be professionally.” One cannot “leverage” such feelings and then in the next breath
claim that “this conduct was unwelcome.”
Moreover, the law recognizes that complicated, romantic entanglements happen in the
workplace, and that these entanglements can occur between consenting adults. While these
relationships may create challenges, they are not inherently coercive. And the fact that such
entanglements often go awry does not transform such conduct into actionable violations of
Title VII. “Clearly, the end of [an] ill-fated relationship br[ings] with it hurt feelings and
bruised egos—perfect ingredients for the bearing of a grudge.” Succar v. Dade County School
Bd., 60 F.Supp.2d 1309, 1314 (S.D. Fla. 1999). But “[p]ersonal animosity is not the equivalent
of sex discrimination,” and a “plaintiff cannot turn a personal feud into a sex discrimination
case by accusation.” McCollum v. Bolger, 794 F.2d 602, 610 (11th Cir. 1986), cert. denied,
479 U.S. 1034 (1987).
C. Ms. Guerrero’s Claim of Retaliation Is Frivolous
There was no retaliation against Ms. Guerrero. Even if she had participated in protected
conduct by making a good faith complaint (she did not), the acts she characterizes as retaliatory
either did not happen or were taken for legitimate reasons.
Title VII makes it illegal for “an employer to discriminate against any of his
employees . . . because [the employee] has opposed any practice made an unlawful
employment practice by [Title VII]” or “because he has made a charge, testified, assisted, or
participated in any manner in an investigation, proceeding, or hearing under [Title VII.]” 42
U.S.C. § 2000e–3(a). To state a claim for retaliation under Title VII, “a plaintiff must show
(1) involvement in a protected activity, (2) an adverse employment action, and (3) a causal link
between the two.” Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir. 2000) (citing
Payne v. Norwest Corp., 113 F.3d 1079, 1080 (9th Cir. 1997)).
1. Ms. Guerrero Did Not Engage in Protected Activity
Ms. Guerrero’s retaliation claim fails right out of the gate. She cannot show involvement in a
protected activity because she has made knowingly false allegations in both her Charge and to
the Firm. The confessional email she emailed to herself on November 10, 2018, outlining her
approach to controlling Mr. Lehot, makes this clear. “[T]o constitute protected activity, a
complaint must be based on an employee’s ‘reasonable belief’ that he is reporting conduct that
violates Title VII.” E.E.O.C. v. Go Daddy Software, Inc., 581 F.3d 951, 967 (9th Cir. 2009).
To satisfy this standard, an employee must subjectively and reasonably believe the facts he or
Ms. Rosa M. Salazar
October 29, 2019
Page 23
she is reporting are true. See id.; see also Villa v. CavaMezze Grill, LLC, 858 F.3d 896, 901–
02 (4th Cir. 2017) (knowingly false report cannot be protected activity).
Although it is the rare case where an individual will self-report conduct that he or she knows
to be false, bad-faith reporting does occur, and adverse employment actions taken thereafter
are not actionable. In Burke v. Soto, the court explained that “[t]he opposition clause does not
protect reporting false allegations that the reporter knows are false. Indeed, an employee who
complains about conduct he knows did not actually occur is not ‘oppos[ing] any practice made
an unlawful employment practice by [Title VII].’” No. 2:16-CV-01311-KJM-AC, 2017 WL
4811832, at *3 (E.D. Cal. Oct. 24, 2017) (quoting 42 U.S.C. § 2000e–3(a)); see also Gilooly
v. Mo. Dep’t of Health and Senior Servs., 421 F.3d 734, 741–45 (8th Cir. 2005) (Colloton, J.,
concurring in part and dissenting in part) (explaining “[i]n terms of the text of the statute, an
employee who makes false allegations has not ‘opposed any practice made an unlawful
employment practice,’ because only good faith, reasonable opposition is protected by the
statute” (citations omitted)). To hold otherwise would be to permit individuals reporting in
bad faith to hold their employers hostage. See Burke, 2017 WL 4811832, at *4 (“To deem
self-reporting of knowingly false allegations as protected activity could create a perverse
incentive: Employees could self-report office rumors to inoculate themselves against adverse
employment decisions.”); Brooks, 229 F.3d at 928 (acknowledging the legitimate “worry that
employers will be paralyzed into inaction once an employee has lodged a complaint under
Title VII, making such a complaint tantamount to a ‘get out of jail free’ card for employees
engaged in job misconduct”).
In sum, because Ms. Guerrero has made knowingly fabricated allegations, her report is not
“protected activity” that can serve as the basis for a viable retaliation claim. See, e.g., Sias v.
City Demonstration Agency, 588 F.2d 692, 695 (9th Cir. 1978) (emphasizing there must be a
reasonable belief that reported facts are true at time of report).
2. Even If Ms. Guerrero Engaged in Protected Activity, There Was a Sound

Reason for Her Being Taken Off the “Deal” and Ultimately Placed on
Administrative Leave
Even if Ms. Guerrero’s knowingly false accusations could be deemed protected conduct, there
were legitimate reasons why she was removed from the Deal and why she was placed on
administrative leave from the Firm. On this basis as well, her retaliation claim fails. If an
employee meets her burden of showing that she engaged in protected conduct, the burden then
“shifts to the employer to present legitimate reasons for the adverse employment action. Once
the employer carries this burden, plaintiff must demonstrate a genuine issue of material fact as
to whether the reason advanced by the employer was a pretext.” Brooks, 229 F.3d at 928; see
also Nidds v. Schindler Elevator Corp., 113 F.3d 912, 919–20 (9th Cir. 1996) (finding for
Ms. Rosa M. Salazar
October 29, 2019
Page 24
defendant where defendant articulated legitimate, nondiscriminatory reasons for discharge and
the plaintiff failed to establish those reasons were pretextual).
As explained above, Ms. Guerrero was removed from the Deal at the client’s request, not
because of any complaint she made. And the decision to place Ms. Guerrero on administrative
leave was based solely on the receipt of credible allegations of inappropriate behavior by Ms.
Guerrero regarding a subordinate and her refusal to participate in the investigation of those
allegations. It was entirely unrelated to her decision to lodge an internal report or an EEOC
charge. Accordingly, even to the extent that Ms. Guerrero’s making false allegations
constitutes “protected activity” (and it does not), DLA Piper has demonstrated “legitimate
reasons for the adverse employment action.”
IV. A NOTE REGARDING LEAH CHRISTENSEN’S SUBMISSION
Finally, we address, in part, 12 the recent letter submitted by Leah Christensen to the EEOC.
Leah Christensen (not to be confused with Jeanne Christensen, Ms. Guerrero’s attorney) is an
attorney who worked in DLA Piper’s Office of General Counsel for several years. She was
responsible for advising the Firm and its partners and associates about conflicts resolution,
client engagement letters, and attorney advertising and licensing. To be clear, Ms. Christensen
was one of DLA Piper’s lawyers in these areas.
While serving in this role, Ms. Christensen had a limited scope of responsibility. She was not
privy to any investigations of partners, nor the discipline of partners. She played no role
whatsoever and did not have access to files concerning employee conduct and disputes, and
she did not have a “staff” assigned to her, as she falsely claims. And while she claims she was
“one of the people around” Mr. Lehot to witness his supposedly bullying behavior, she worked
in the Firm’s San Diego office, yet Mr. Lehot worked in Palo Alto. In short, Ms. Christensen’s
job responsibilities (which consisted solely of attorney-client and work product
communications) would not have put her in a position to learn the information she claims to
know.
That helps to explain why so many of Ms. Christensen’s statements are inaccurate. For
example, she claims Mr. Lehot was at the top of a “top ten” list of partners that Ms. Christensen
and her fictional “staff” “should not bother.” Without divulging the substance of the privileged
communication at issue, suffice it to say this was a communication from one of DLA Piper’s
lawyers to Ms. Christensen in her role as DLA Piper’s conflicts counsel to outline how she and
others in the legal department could screen more effectively the large number of conflicts
12
Ms. Christensen’s letter was sent on October 23, 2019, just days before this submission. DLA Piper re-
serves all rights in regards thereto, including to supplement this statement to more fully address her letter.
Ms. Rosa M. Salazar
October 29, 2019
Page 25
inquiries received by certain partners with many clients, as those partners naturally received
the most conflict-related requests. Ms. Christensen’s carefully-crafted submission suggesting
that the list of partners (who, by the way, were both male and female) pertained in any way to
their behavior is false and misleading.
In addition to her EEOC submission, which purports to disclose privileged communications,

Ms. Christensen has made several public statements which likewise are based on (although
often inaccurately recounted) communications that are governed by the attorney-client privi-
lege and work product doctrine. Accordingly, Ms. Christensen’s letter to this Commission, as
well as her public statements, are in direct violation of her duty of confidentiality and her duty
of loyalty, among other ethical and tortious transgressions. She was and remains obligated by
law to maintain inviolate the confidences of her former client. See CAL BUS. & PROF. CODE,
§ 6068, subd. (e); see also Rules of Prof. Conduct, rule 1.6. That includes not only attorney-
client privileged communications, but also information relating to every aspect of the legal
representation, whatever its source. In the Matter of Johnson (Rev. Dept. 2000) 4 Cal. State
Bar Ct. Rptr. 179; Goldstein v. Lees (1975) 46 Cal.App.3d 614, 620–21. This obligation con-
tinues even after the attorney-client relationship ended, and applies to in-house attorneys like
Ms. Christensen, just like every other attorney in California. General Dynamics Corp. v. Su-
per. Ct. (1994) 7 Cal.4th 1164, 1190.
Similarly, attorneys owe an absolute and complete duty of loyalty to their clients. “It is . . . an
attorney’s duty to protect his client in every possible way, and it is a violation of that duty for
him to assume a position adverse or antagonistic to his client without the latter's free and in-
telligent consent[.]” Santa Clara County Counsel Attys. Ass’n v. Woodside (1994) 7 Cal.4th
525, 548. As with the duty of confidentiality, that fiduciary duty of loyalty continues after
termination of the attorney-client relationship. Oasis W. Realty, LLC v. Goldman (2011) 51
Cal.4th 811, 821. That means Ms. Christensen was and is “forbidden to do either of two things
after severing [the] relationship with a former client. [She] may not do anything which will
injuriously affect [the] former client in any matter in which [she] formerly represented [the
client] nor may [she] at any time use against [the] former client knowledge or information
acquired by virtue of the previous relationship.” Id. (citation omitted).
By referencing privileged and protected matters in statements to this Commission and then
publicizing them, not only has Ms. Christensen violated her duties of confidentiality and
loyalty to DLA Piper, but she also has foisted upon the Firm the Hobson’s Choice of waiving
privilege to correct her misrepresentations or allowing her outright falsehoods to remain
unrefuted. While this is not the proper forum to hold her accountable for those transgressions,
we respectfully suggest that the Commission not in any way condone her malfeasance,
including by accepting her demonstrably false accusations.
Ms. Rosa M. Salazar
October 29, 2019
Page 26
***
In short, because the evidence overwhelmingly shows that Vanina Guerrero has suffered no
harassment, discrimination, or retaliation, DLA Piper respectfully requests that the
Commission dismiss the Charge and issue a finding of no probable cause to believe any
violation of the law occurred. Please do not hesitate to contact us if you believe additional
information would be of assistance to the Commission. As explained above, DLA Piper plans
to supplement its submission as appropriate.
Sincerely,
Gibson, Dunn & Crutcher LLP

Michele L. Maryott
Katherine V.A. Smith
Kevin S. Rosen
Enclosures
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DLA Piper EEOC Position Statement With Exhibits

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DLA Piper EEOC Position Statement With Exhibits

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October 29, 2019

VIA EEOC RESPONDENTS’ PORTAL

Ms. Rosa M. Salazar

Re: EEOC Charge No. 556-2020-00008

Dear Ms. Salazar:

II. OVERVIEW OF THE EVIDENCE

A. Ms. Guerrero’s Interest in DLA

B. Ms. Guerrero’s and Mr. Lehot’s Working Relationship

1. September 2018 Trip to Shanghai and Hong Kong

2. September 2018 Trip to Brazil and Argentina

5. Ms. Guerrero Learns She Has Failed the Bar Exam

6. The Omitted Personal Trip to Machu Picchu in March 2019

C. “The Deal” Matter Conflict

D. Developments After Ms. Guerrero Made Her Complaints

III. DLA PIPER’S RESPONSE TO MS. GUERRERO’S CHARGE

C. Ms. Guerrero’s Claim of Retaliation Is Frivolous

1. Ms. Guerrero Did Not Engage in Protected Activity

2. Even If Ms. Guerrero Engaged in Protected Activity, There Was a Sound

IV. A NOTE REGARDING LEAH CHRISTENSEN’S SUBMISSION

In addition to her EEOC submission, which purports to disclose privileged communications,

Gibson, Dunn & Crutcher LLP

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Explorre our new webs SHUDFFHOHUDWHFR

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Explorre our new webs SHUDFFHOHUDWHFR

'ŽŽĚ ŶĞǁƐ͕ƐĞƌǀŝĐĞƐĂƌĞĐŽŶĨŝƌŵ ŵĞĚĨŽƌǇŽƵƌWĞƌƵƚƌŝƉ͘ŶŶĐůŽƐĞĚĨŝŶĚƚƚŚĞĐŽŶĨŝƌŵĞĚ

^ĞŶƚĨƌŽŵŵǇůĂĂĐŬĞƌƌǇͲƚŚ ƵƌĞŵŽďŝůĞĚ ĞǀŝĐĞ

Explorre our new webs SHUDFFHOHUDWHFR

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