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.