Culture of blame forces HR of Transperfect (www.translations.com) to resign. Frequent harassment of Co-CEO Phillip Shawe has created a toxic workplace.

1. 40. Robert DeNoia ("DeNoia"), the head of HR, was "appalled and disgusted" by
Shawe's email and said that Shawe's conduct "needs to stop" because "Nt's out of control at this
point" and "something needs to be done." (Ex. 10).
41. Later that day, Shawe purported to unilaterally suspend Boodram and told her to
remove herself from the property. (Ex. 11). Over the weekend of October 19, 2013, Shawe
secretly changed the locks on Boodram's office door. By locking Boodram out of her office,
Shawe nearly caused TransPerfect to miss making its regular payroll.
42. In an email dated October 20, 2013 (Ex. 12), DeNoia threatened to quit because
of the hostile environment Shawe's conduct had created:
We need to assess how I can legally, morally and professional
continue in my role as VP of HR.
I cannot be complicit in this pervasive and continuous hostile
environment where inappropriate behavior impacts the morale,
health and well-being of myself and the staff continues. My
continued counsel concerning this behavior has had no effect to
remedy the situation.
Therefore we need to address what, if any role I will continue to
play and in what capacity, with this organization.
43. As set forth below, DeNoia subsequently did submit a letter of resignation,
because of Shawe's continued and relentless mistreatment of Boodram.
44. On Monday, October 21, 2013, at 1:52 a.m., Shawe emailed Boodram to remind
her not to "come onto company property on Monday or until further notice and to tell her: "Your
office and your computer have been quarantined for investigation, and are also off-limits." (Ex.
13).
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