FORTUNE -- Three executive assistants with San Francisco-based venture capital firm CMEA Capital have sued the firm and one of its former partners for sexual harassment, in a vivid complaint that also alleges racial harassment and retaliation.
The three plaintiffs -- Dawn-Shemain Weeks, Margaret Hines and Shannon Schlagenhauf -- tell of a hostile work environment and detail 35 different alleged examples of inappropriate sexual comments and advances. Some of the examples are shockingly lurid, and far more explicit than what is normally found in a Silicon Valley harassment lawsuit.
Most of the accusations center around John Haag, who served as CMEA's chief operating partner between 2006 and 2012.
The plaintiffs allege that CMEA management was aware of the ongoing situation, and that firm founder Tom Baruch had once warned one of them that Haag was a "predator." But they formally presented their concerns to CMEA's three managing partners on April 30, 2012.
The firm hired an outside organization to conduct a review, which allegedly resulted in corroboration of their allegations. CMEA then chose to "buy-out" Haag's interests in existing CMEA funds in coordination with him leaving the firm. According to his LinkedIn profile, Haag currently is running a consultancy called CourseChange.
The plaintiffs further allege that, despite Haag's departure, they were subsequently exposed to retaliation. For example:
One of the three plaintiffs, Dawn-Shemain Weeks, gave notice back in January. The other two appear to remain employed by the firm, but say they do not believe "they will be allowed to remain employed at CMEA for any amount of time longer than CMEA believes it must retain them to avoid the appearance that they were terminated as a result of reporting the blatant misconduct of Defendant Haag."
Fortune reached out to both CMEA and John Haag, and received statements from their attorneys:
Lara Villarreal Hutner, representing CMEA: "For the record, CMEA flatly denies each and every allegation of wrongdoing. In reality, this lawsuit is the result of the least 'sexy' of its allegations: the plaintiffs' curtailment of overtime in late 2012 as the result of a new Firm-wide overtime policy. CMEA's appropriate handling of this matter is evidenced by the fact that for the last 8 months plaintiffs continued working for the Firm without incident, each of them resigning only after the across-the-board change in the Firm's overtime policy, and only after filing this lawsuit last month. CMEA is absolutely confident that it will prevail and continue its reputation as a trusted and innovative builder of solid financial and scientific relationships."
Rachel Pusey, an attorney for John Haag: "John Haag cannot comment on this matter as it is in active litigation other than to say he looks forward to the truth coming out in the course of this lawsuit. He is prepared to defend himself vigorously and trusts the justice system will thoroughly vindicate him."
Below is the entire suit:
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