The accusation

On August 08, 2008, Mike Armas handed me a hostile workplace/sexual harassment accusation notice (see attached Accusation.jpg document). He told me that he couldn’t give me more details about the accusation, nor the name of the accuser. I had to leave the company’s building immediately after, and I was placed on company’s paid leave for the period of the investigation. The accusation notice was handed to me during a meeting that Mike had set-up the day before, called The Future - see The Future meeting.pdf document. The meeting took place in the HR office, ONLY between Mike and I, no HR person was involved. The accusation letter is ONLY signed by Mike Armas.

I later learned from LaRee Kinney (working for ADP Total Source, a HR service provider contracting with Raydiance) on August 13, 2008 that the accuser was Carolyn Martinez. Here are the three events that Carolyn based her accusation on, as revealed to me by LaRee Kinney during my interview with her on August 13, 2008.

First alleged event: January 2008

Carolyn and I were in the lab working on two different stations spatially separated by around 2-5 meters. We were under pressure, preparing for an imminent customer visit. She asked me some questions while I was concentrated on my work and I give her a short answer while continuing working. Carolyn answered back with an attitude seeking my full attention. I looked at her and with a hard tone I asked "what is the matter Carolyn, do you have problems in your life?".

Up to this point my recollection corresponds with Carolyn’s accounts. Carolyn also added that I also said "do you have your period?".

I have a vivid memory of this incident and I know that I did not mention anything about her period or anything else referring to something specific of a woman.

Second alleged event: End of June 2008

Carolyn and I were in a meeting room, talking about work related problems and about our work relation problems. Carolyn was at this point in time in charge of the lab; therefore she was my supervisor. Carolyn stated, according to LaRee Kinney, that I said during this meeting that because she is a woman, and because she has to raise a kid alone, and because she moved to California from the East coast for this job, she is unable to handle work pressure.

I remember this meeting and I remember telling Carolyn that Tintin (not his real name) and I feel a lot of pressure from Mike Armas, and that I thought she must also feel a lot of pressure. I also compassionately told her that I understand how much this job is important for her, because she is raising a kid alone, and because she made a big effort moving form the east coast to California for this job. I did not refer to her as being a woman, nor told her that because she is a woman she cannot take work pressure.

Third alleged event: 3 July 2008

During a meeting with Carolyn a few days prior to this third alleged event Carolyn told me that her anxiety peaks two times a day, the first time during the morning meeting when people ask her how is the applications lab going. At the time of this meeting Carolyn was in charge of the lab. She says that a few days after this meeting, while being in the lab with Tintin and I, she repeated the same line about her anxiety peaking two times a day, and that I made a joke about this asking if it was also during her period, and that we have to put it on the board or calendar. I remember Carolyn talking about her anxiety peaking two times a day during our meeting, but I don't remember the event in the lab a few days later. During the Investigation Tintin was also interviewed and he stated that he has no recollection of the situation described by Carolyn.