What do you mean, leaked? He sent it to the company. Whether or not it was released outside of the company has no bearing on whether it created a hostile enviro

What do you mean, leaked? He sent it to the company. Whether or not it was released outside of the company has no bearing on whether it created a hostile environment. In fact, it was "leaked" precisely because it was so offensive. And what misrepresentation? You're deluding yourself. The memo as written is what created the hostile work environment, not any "misrepresentation".