In Beyda v. City of Los Angeles (1998) 65 Cal.App.4th 511, the plaintiff claimed workplace sexual harassment and sought to introduce evidence that some of the defendant's other employees had also been sexually harassed. The Beyda court upheld the exclusion of the evidence, saying: "When offered on the theory that respondents are likely to have committed the conduct at issue in Beyda simply because they did the same thing before, the evidence goes to propensity, and is inadmissible under Evidence Code section 1101, subdivision (a)." (65 Cal.App.4th at p. 518.) The Beyda court stated that rather than lacking probative value, the evidence was actually too relevant and had too much probative value. (Ibid.) However, Beyda did not address whether the evidence could be admitted under the provisions of subdivision (b) of Evidence Code section 1101. As discussed below, many courts have held that evidence of the type sought to be introduced by the plaintiff in Beyda, and by the plaintiff in the instant case, is admissible under rule 404(b) of the Federal Rules of Evidence (28 U.S.C.) to show intent or motive, for the purpose of casting doubt on an employer's stated reason for an adverse employment action, and thereby creating a triable issue of material fact as to whether the stated reason was merely a pretext and the actual reason was wrongful under employment law. Evidence Code section 1101 provides in relevant part: "(a) Except as provided in this section ... , evidence of a person's character or a trait of his or her character (whether in the form of an opinion, evidence of reputation, or evidence of specific instances of his or her conduct) is inadmissible when offered to prove his or her conduct on a specified occasion. "(b) Nothing in this section prohibits the admission of evidence that a person committed a crime, civil wrong, or other act when relevant to prove some fact (such as motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake or accident ...) other than his or her disposition to commit such an act. "(c) Nothing in this section affects the admissibility of evidence offered to support or attack the credibility of a witness." Rule 404 of the Federal Rules of Evidence (28 U.S.C.) contains similar provisions. It states in relevant part: "(a) Evidence of a person's character or a trait of character is not admissible for the purpose of proving action in conformity therewith on a particular occasion, except: (3) ... Evidence of the character of a witness including character for truthfulness, as provided in Rules 607, 608, and 609. "(b) ... Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident ... ." In sum, the Court held that evidence of harassment endured by other employees is relevant to the question of a hostile environment. "'The plaintiff's work environment is affected not only by conduct directed at herself but also by the treatment of others. A woman's perception that her work environment is hostile to women will obviously be reinforced if she witnesses the harassment of other female workers.' " (Ibid.) The Beyda court added that it also believed that "a reasonable person may be affected by knowledge that other workers are being sexually harassed in the workplace, even if he or she does not personally witness the conduct." (Beyda, supra, at p. 519.) The Beyda court held that evidence of the harassment of others should be excluded if the plaintiff neither observes the other incidents nor knows that they occurred, because then they cannot affect his or her perception of the hostility of the work environment. (Beyda, supra, 65 Cal.App.4th at p. 519.) The Court held that evidence of harassment of other employees may be relevant to establishing claims of a hostile work environment, although such evidence is irrelevant to establishing a propensity for harassment. (Beyda, supra, 65 Cal.App.4th at pp. 518-519.) For evidence that others were harassed to be relevant, however, the plaintiff must become aware of the harassment during her employment. ( Id. at p. 519.) Witnessing the harassment is not required, but knowledge is. ( Id. at p. 521.) The court cautioned that "mere workplace gossip is not a substitute for proof. Evidence of harassment of others, and of a plaintiff's awareness of that harassment, is subject to the limitations of the hearsay rule. It is not a substitute for direct testimony by the victims of those acts, or by witnesses to those acts." (Ibid.)