California, United States of America
The following excerpt is from Mabin v. Kindred Healthcare Operating, Inc., B265712 (Cal. App. 2016):
In Brennan v. Townsend & O'Leary Enterprises, Inc. (2011) 199 Cal.App.4th 1336, 1359, the appellate court held that the plaintiff could not rely on harassing conduct against other employees which did not occur in her presence or immediate work environment, and which she was not aware of until she decided to investigate whether other incidents had occurred.
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