MICHAEL D. MARCUS’S MEDIATION MESSAGE NO. 90 OTHER CONDUCT EVIDENCE Since Pantoja v. Anton (2011) 198 Cal.App.4th 87 held that an employer’s sexual harassment of employees other than the plaintiff was relevant, pursuant to Evid. Code sec. 1101, subd. (b), to prove both gender bias and to rebut defense assertions that the employer had a policy of not tolerating harassment (id. at p. 116), it has become popular to refer to such testimony as “me…