In short, Goguen is calling Baptiste an infatuated ex-mistress who became vindictive upon realizing that Goguen would not leave his wife. As for the $40 million settlement, Goguen argues that it was the result of extortion, and that he stopped payments after Baptiste violated a condition that she not contact Goguen save for correspondence directly related to the settlement (he claims “thousands” of subsequent text messages). His counter-complaint also includes a few risque photos that he claims Baptiste sent over the course of their “relationship” ― something that smells a lot like vindictiveness.

Here is a copy of the counter-complaint:

[scribd id=304679097 key=key-MSXTqdRi0LkHSXvl7wDg mode=scroll]

Goguen’s attorney isn’t commenting further, except to reiterate that Baptiste was a legal adult when the pair originally met. Some media reports have incorrectly said that she was 15 years-old at the time, but that actually was the age at which she entered the U.S. (in her words, in the serve of sex traffickers).

As I wrote yesterday, it is too early to arrive at conclusions. To be sure, Sequoia had every justifiable reason to part ways with Goguen if, as it claims, the firm had no knowledge of his settlement with Baptiste. In small partnerships, that could reasonably be viewed as a breach of trust. And clearly Goguen has broader troubles with fidelity. Nonetheless, as my colleague Kristen Bellstrom writes, this can’t help but reflect negatively on Sequoia. And don’t be surprised if certain aspects of the firm’s finances wind up as part of the court record (assuming an actual trial).

Upon re-reading both suits, it is clear that there is a massive chasm between many of Baptiste’s claims and many of Goguen’s claims. This isn’t Ellen Pao vs. Kleiner Perkins, where the ultimate verdict was more about interpretation of facts than the facts themselves. In this case, one of them is outright lying about some of the most disturbing details. And we don’t yet know which one.