It is important to note that Kleiner’s reply is not a line-by-line refutation of Pao’s charges. Instead, it is a fairly general denial with a sprinkling of specifics. For example, it claims that females were in attendance at a firm dinner that Pao had claimed was all-male. It also rejects Pao’s allegation that partner Ray Lane “encouraged” her to “marry” Ajit Nazre, a former colleague who Pao accuses of harassing and retaliatory behavior. Finally, Kleiner Perkins asserts that Pao is effectively making up a series of past communications related to Nazre’s  behavior, apparently including an alleged investigation into the matter in May 2007.

Nazre is not specifically identified in the Kleiner Perkins response, nor is there any explanation of why he quietly left the firm either late last year or early this year. Also not addressed is an alleged discrepancy in pay between junior male and female partners, or Pao’s assertion that she was improperly denied a performance review in 2008. Finally, there is no response to Pao’s assertion that another junior female partner complained about Nazre’s behavior, or that there were earlier discrimination concerns voiced by administrative assistants.

Kleiner’s response also argues that Pao is suing in an inappropriate venue, and that her suit violates existing arbitration and non-disparagement agreements. It is asking the court to dismiss Pao’s claims with prejudice, and to have Pao reimburse the firm for all related legal fees.

The entire response is posted below:

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