United States District Court, D. South Carolina, Orangeburg Division
REPORT AND RECOMMENDATION
Kaymani D. West United States Magistrate Judge.
Deanna Evans (“Plaintiff” or “Evans”)
filed this action in the Richland County Court of Common
Pleas against her former employer, Defendant International
Paper Company (“Defendant” or “IP”),
alleging race discrimination, gender discrimination, unequal
pay, and retaliation in violation of Title VII of the Civil
Rights Act of 1964, as amended, and the Equal Pay Act of
1963, an amendment to the Fair Labor Standards Act, 29 U.S.C.
§ 201, et seq. (“EPA”). Compl., ECF
No. 1-1. Defendant removed the matter to this court. ECF No.
1. This matter is now before the undersigned pursuant to 28
U.S.C. § 636(b) and Local Civil Rule 73.02(B)(2)
(D.S.C.) for a report and recommendation
(“Report”) regarding Defendant's Motion for
Summary Judgment. ECF No. 64. Plaintiff filed a response to
the Motion, ECF No. 71, to which Defendant filed a Reply, ECF
No. 73. Having reviewed the parties' submissions and the
applicable law, the undersigned recommends Defendant's
Motion, ECF No. 64, be granted in part and denied in part.
establishing the briefing schedule for dispositive motions
the court instructed the moving and nonmoving parties to set
out their statements of undisputed and disputed facts in
paragraph form, including detailed record citations to such
facts. ECF No. 62; see Fed. R. Civ. P.
26(c)(1).The parties have largely complied with the
court's instructions. Having reviewed the facts as set
out by the parties, the court considers the following facts,
which are either undisputed or taken in the light most
favorable to Plaintiff, to the extent they are supported by
the record. To the extent practicable, the following
facts are set out in paragraphs that conform to those
paragraph numbers provided by the moving party.
IP's Equal Employment Opportunity policy provides,
“There will be no discrimination or any type of
harassment because of race, ethnicity, color, religion, sex,
sexual orientation, marital status, age, disability, gender
identity or expression, genetic information, national origin,
military or veteran status, or any other classification
protected by law.” ECF No. 64-2.
has an established complaint procedure (as well as a Help
Line) and Company policy prohibits retaliation for making
complaints or participating in investigations thereof. ECF
Plaintiff, a Black female, never called the Help Line
herself. Pl. Dep. 210. Plaintiff was interviewed by Human
Resources (“HR”) during an “Eastover EEO
Charge Investigation” based on complaints of
discrimination from Plaintiff and other black employees at
the Eastover Mill, including other employees' calls to
the Help Line. Pl. Dep. 224-25,  ECF No. 71-1; ECF No. 71-2 at
5-15, 21-22 (exs. from Deposition of HR employee/investigator
Audrey Bright, including HR Investigator Sabrina
Townsend's Oct. 2014 Findings in “Eastover EEO
Charge Investigation” and Bright's Dec. 2011
Investigation Summary of complaints by employee Tommie
Garrett. Both of these investigative reports indicate
Plaintiff was interviewed.).
hired Plaintiff as a Process Engineer in Vicksburg,
Mississippi in May 2007 and Plaintiff began working at
IP's Eastover, South Carolina Mill in November 2009 as an
Engineer II. Pl. Dep. 20, 106, 140. Plaintiff's
qualifications in her field include a Six Sigma green belt
certification, American Society of Quality Certified Quality
Auditor Certification, ISO 9001 & 14001 Lead Auditor
Certification, Bachelor of Science degree in chemical
engineering, and Master's degree in Business
Administration from Gardner-Webb University. Ex. 4 to Pl.
Dep., ECF No. 64-5 at 4-5; see also Dep. of Eastover
Mill Manager Hai Ninh 16-20, ECF No. 71-25.
the time at issue, Paul Varadi (White male) was the CPS
Business Unit Manager at Eastover Mill. Varadi Decl. ¶
1, ECF No. 64-7. Hai Ninh (Asian male) was Mill Manager.
Id. ¶ 11. Gary Nyman (White male) was the
Finished Products Department's (FPD) Business Unit
Manager. Id. ¶ 2.
. Months after starting as a Process
Engineer at the Eastover Mill, Evans heard Matthew Vail
(White male) and Rocky Mucci (White male) talking about her
and saying, “We didn't want her; we were forced to
take her.” Pl. Dep. 139-40. Taft Gaymon (Black male)
heard Brian Cronin (White male) make similar comments. Gaymon
Dep. 61-62. Gaymon understood Cronin's comment to mean
Plaintiffs hire had been “a corporate decision and the
mill had no say so.” Id. at 62.
June 23, 2010, Plaintiff was promoted to an Area Process
Manager (APM) position. Pl. Dep. 107. Derrick Dingus (White
male), a purported comparator in this litigation, had also
been a candidate for that position. Id. Salary data
provided indicates Plaintiff consistently earned more than
Dingus. Ex. 5 to Pl. Dep., ECF No. 64-5 at 6; Decl. of
Eastover Mill's HR Manager, Walt Partrich ¶ 3, ECF
No. 64-9. Plaintiff maintains that Dingus has “had more
opportunities” for advancement than she had. Pl. Dep.
106. In his deposition, FPD's Business Unit Manager Gary
Nyman testified that he did not consider Dingus “the
other potential application” for the APM position,
noting Dingus had other interests and the APM position was
not in his career path. Nyman Dep. 158-59, ECF No. 71-3.
Plaintiff states that Dingus had a position “created
for him” and that his last role at the Eastover Mill
was a position that had not been posted and that he
“went from a shift manager to a role similar to area
process manager, and then from there he went to an overseas
assignment.” Pl. Dep. 107. She noted she did not want
an overseas assignment. Id.
. During Plaintiffs second maternity leave
(no date specified by Plaintiff), Nyman sent an email
announcing that Mark Jones was Plaintiffs replacement during
the maternity leave. Virginia Gail Sims, the Administrative
Assistant III who provides secretarial support to the FPD,
heard Rocky Mucci talking to Mark Jones about Plaintiff and
said “now we'll have a real manager in Chem.
Add.”. Aff of Virginia Gail Sims, ¶ 64, ECF No.
. After returning from maternity leave in
2011, Nyman informed Plaintiff that people thought that she
was not coming back to the Eastover Mill; she was told that
they thought that they had “run her off.” Pl.
. In 2012, Evans participated in some of the
A-level promotions reviews of Tommie Garrett, George Koumas,
Renee Belton, and Mike Hill. During the same meeting, Mark
Jones (White male), a manager, made a comment that Renee
Belton (Black female) acted as “if she is from a shoot
em up, bang bang neighborhood.” Pl. Dep. 226. After the
meeting, Emma Sebeey (Black female) and Plaintiff went to
Nyman's office and informed him that they felt Mark
Jones' comment was very offensive. Id. Nyman
said, “yeah, ” but did not do anything about it.
Id. Plaintiff indicates she was excluded from
A-level promotional interviews after that.
Plaintiff headed major projects at Eastover Mill to achieve
International Standard for Organization (“ISO”)
9001 and ISO 14001 certifications, the latter of which
allowed Eastover Mill's products to be sold in Europe.
Pl. Dep. 80-81, 108; Partrich Decl. ¶ 18.
. In 2012, after the ISO 9001 certification
had been obtained in fewer than nine months, Plaintiff
received a “meets expectations” evaluation
rating. Evans told Nyman that she had ‘worked my butt
off and asked what would it take to get an
“exceeds.” Ex. 9, Answer to Interrogatory No. 12,
ECF No. 71-9 at 31. Nyman responded by telling Plaintiff she
would have to be lucky. Id. Nyman also made the
statement that “people should be happy they have a
Varadi worked closely with Plaintiff as a management sponsor
of these ISO projects. Varadi Decl. ¶ 2. At the time she
worked on the ISO projects, Plaintiff was assigned to FPD
under the supervision of Nyman. Id. Varadi indicated
that Nyman thought highly of Plaintiff s capabilities and
recommended her to lead these ISO initiatives “despite
her relative youth.” Id.
These ISO projects were significant to Plaintiffs career
development, and she was recognized for those achievements.
Pl. Dep. 81, 109; Varadi Decl. ¶ 2; Partrich Dep. 18-20,
ECF No. 64-10. Plaintiff was the face of the projects and
always presented ISO information at mill-wide meetings. Pl.
. During a one-on-one meeting with Varadi in
September 2013, when Evans accepted the role of Technical
Quality Leader, Varadi communicated that Evans would receive
a 4% raise and a lateral move to the position. Ex. 9, Answer
to Interrog. No. 12. Evans asked for additional compensation
and asked about the PL15 position that Partrich communicated
to her. Id. In response, Varadi said that,
“This is a new role and we had to post the PL low to
see who all was interested.” Id. After further
questions from Evans, Varadi said he was not changing the
offer to Evans. Id. Varadi also communicated that he
knew that Evans was looking for other opportunities within
the company and that he needed a commitment. Id. At
the time, a PL15 position was vacant under Varadi's
October 2013, Plaintiff was promoted to the new position of
Technical Quality Leader (“TQL”), which meant she
was responsible for the interface between FPD and the
customer to ensure that the products consistently conformed
to the customer's specifications. Pl. Dep. 68, 113,
Varadi Decl. ¶ 3. Plaintiff worked with Varadi to create
the job description for that position; she noted that
“in some ways” the job requirements of that
position had been written to match her skill set. Pl. Dep.
98, 219-20. Plaintiff had no doubt in her mind she would get
that job, nor did she believe there was any doubt in
Varadi's mind that she would receive that position.
Id. at 219-20.
Varadi selected Plaintiff for the TQL position, and she began
reporting to him at that point. Varadi Decl. ¶ 3. He
selected Plaintiff because he had seen her performance on the
ISO certifications, they had worked closely together on the
ISO 9001 project, and Varadi wanted to work with Plaintiff.
Varadi Decl. ¶ 4, Pl. Dep. 97-98. Varadi was aware of
Plaintiff s race and sex when he selected her for the
position and when he worked with Plaintiff to create the job
description. Varadi Decl. ¶ 4, Pl. Dep. 98-99.
While working under Varadi, IP's CEO awarded Plaintiff
the prestigious Chairman's Coin award and a Key Driver
Award. Pl. 99, 233; Ninh Dep. 19-20, ECF No. 32; Nyman Dep.
80; Varadi Decl. ¶ 5. Varadi sponsored Plaintiff for
these awards and worked to ensure that management at Eastover
Mill support her as well. Varadi Decl. ¶ 5. Varadi was
proud of Plaintiff for obtaining these awards so early in her
career; he noted it had taken him 33 years with IP to earn
the Chairman's Coin award. Id. Varadi noted it
was very rare for IP employees to receive these rewards at
all. Id. Plaintiff noted Varadi had told her he was
excited and proud to be supervising someone who received the
coin, particularly at such an early stage in her career; she
had no reason to believe Varadi was being insincere. Pl. Dep.
January 10, 2014, Plaintiff acknowledged receiving her
Contribution Summary Assessment or “CSA” (annual
performance evaluation) prepared for 2013 by Varadi. Ex. 6 to
Pl. Dep., ECF No. 64-5. Plaintiffs Overall Rating was
“Results Exceeded Commitment.” Id. at
Plaintiff acknowledged that only a small percentage of
Eastover Mill employees receive an “exceeds”
rating. Pl. Dep. 154.
July 22, 2014, Varadi emailed Plaintiff thanking her for her
efforts in an ISO meeting and telling her that she did a good
job. Ex. 7 to Pl. Dep., ECF No. 64-5 at 13.
August 20, 2014, Varadi emailed Plaintiff telling her that
she did “[g]reat work” and asking her to pass his
thanks along to the rest of the team. Ex. 9 to Pl. Dep., ECF
No. 64-5 at 14.
. In October 2014, Defendant's corporate
office sent Sabrina Townsend (“Townsend”) (Black
female) an HR Manager from Virginia to the Eastover Mill to
conduct an investigation due to discrimination complaints
originating from the FPD. HR employee Audrey Bright Dep. 40,
ECF No. 71-12; Partrich Dep. 29-33, ECF No. 71-24. Townsend
and Bright interviewed about ten employees, including
Plaintiff, at the Eastover Mill. Plaintiff told Townsend
about the “uninclusion” she experienced from
Nyman and how he did not engage with her and give her
leadership roles as he did White male employees. Pl. Dep.
224-25. Plaintiff noted Nyman did not use racial slurs, but
noted he had been in the room when his manager said that
certain Black employees “act like they're from a
shoot ‘em up bang bang neighborhood.” Pl. Dep.
226. Plaintiff also told Townsend that Nyman avoided talking
to Black employees, avoids promoting them, and that his
actions show that he is racist. Id. at 223.
November 7, 2014, Plaintiff emailed Nyman thanking him for
his comments that day and for supporting the team. Ex. 10 to
Pl. Dep., ECF No. 64-5 at 16.
January 22, 2015, Plaintiff emailed the “Sumter
Team” to summarize the Eastover Mill's action plan.
Ex. 13 to Pl. Dep., ECF No. 64-5 at 22. Varadi responded to
Plaintiff, copying Ninh, on January 23, 2015, “Deanna,
good followup and characterization of the issue.
January 30, 2015, Plaintiff acknowledged receiving her 2014
Final CSA prepared by Varadi. Ex. 12 to Pl. Dep., ECF No.
64-5 at 17-21. This was the last CSA Plaintiff received while
employed at IP. Plaintiffs overall rating was, “Results
Met Commitment.” Id. at 20. Plaintiff noted
Varadi had told her that employees did not receive
back-to-back “exceeds” performance ratings and
that he would characterize her 2014 overall rating as a
“high meets” rating. Pl. Dep. 172-73. Plaintiff
noted the 2014 rating was lower than what she had received
for 2013, but acknowledged the “results met
commitment” rating was “still a good
rating.” Id. at 154, 172-73. Varadi indicated
Plaintiff had continued to perform at a high level in 2014
and that he considered whether to give her a second
“exceeds” rating, although he did not do so given
the “limited amount of such ratings managers are
allowed to give[.]” Varadi Decl. ¶ 7.
When asked in deposition about the 2014 Final CSA, Plaintiff
indicated she had not taken exception to the “results
met” rating, but that she did take exception to certain
comments within that CSA. Pl. Dep. 154-55. In particular,
Plaintiff took exception to this comment by Varadi:
“Deanna needs to continue to develop her interfacing
and technical skills to be viewed as a reliable and
troubleshooting resource by the FP team. This year has been a
transition year, and hopefully she can build further upon
these skills in the coming year. On the positive side, the
envelope business performance has had a good trend, and
Deanna has helped define key improvement
opportunities.” ECF No. 64-5 at 19, see Pl.
Dep. 154-55. When asked generally about whether she took
issue with her CSAs since 2007, she indicated she agreed with
the ratings but noted her disagreement with the above
statement from the 2014 CSA. Pl. Dep. 40-41, ECF No. 64-4.
More particularly, Plaintiff stated the following when asked
in deposition about her objection to the above comment:
A: . . . Reading the sentence, there were no data points to
support reason why I'm not considered, one, technical,
and also reliable and a troubleshooting resource, And the
perception again is in here, the theme, finished products
Q. Are you aware where Mr. Varadi had given similar feedback
to Mr. Cummings at the time that he began working alongside
Ed Smith in the department?
A. I know he had some struggles.
Q. But are you aware of whether Mr. Varadi made similar
comments for Mr. Cummings at the time that he was getting
started in that role?
Q. Are you aware of whether he has indicated similar comments
to Anthony Seamon on his CSA's?
Pl. Dep. 155-56.
. Varadi noted in his declaration that he
understood Plaintiff “took exception to some issues in
her review and felt they were not warranted.” Varadi
Decl. ¶ 10. He notes Plaintiffs testimony that she was
unaware of whether Varadi had made similar comments on other
employees' CSAs, see Def. Mem. 5-6, and declares
that he has made similar comments on the CSAs of white male
employees, including Roy Cummings and Anthony Seamon, Varadi
Decl. ¶ 10 (providing examples of such similar
comments). Plaintiff notes that the CSAs of her white male
comparators are not in the record. Pl. Mem. 2.
. In an email dated January 21, 2015,
Plaintiff noted her concerns about the comment in her 2014
CSA about “being a reliable technical resource for the
FP team.” Jan. 21, 2015 email, ECF No. 71-14. Plaintiff
stated, “I am viewing this as negative vs. opportunity
based on no specific examples. It seems more like a personal
attack versus constructive feedback. I have demonstrated
excellent people skills along with strong technical skills
and the ability to work with people in all levels of the
organization. I have a hard time digesting making deposits or
building trust in an environment not accepting. This seems
like a no win scenario. Let's discuss tomorrow or Friday
if your schedule allows. Thanks for listening.”
Id. Varadi responded the following morning that he
would be happy to meet with Plaintiff and noted he viewed it
“as an opportunity. You are viewed as a valuable
resource and are just looking for opportunities to continue
to leverage your skills and insights.” Id.
After Varadi gave Plaintiff her “meets” review on
her 2014 Final CSA in January 2015, Plaintiff met with
Eastover Mill Manager Ninh on January 28, 2015. Pl. Dep.
168-70, 207-08; Ninh Dep. 47, ECF No. 64-6; Ninh Dep. 50-57,
ECF No. 71-25. Ninh's notes from that meeting,
stated verbatim, follow:
1) Deanna stated: the working environment has become
uncomfortable & offensive. For example:
-FPMPM- Comment: “your hair cut made you look older
-Not allow enough facetime with customers/Memphis visits
-Does not feel being included or part of the team because FP
people do not respond to her requests or emails -Roy gets
more attention to her - F.P. usually go to Roy instead of her
-Can't work in the environment that not being accepted -I
am not shutdown yet like Emma!!
-Need communicate daily on Roles & Responsibilities to
everyone, especially to F.D.
-I [Ninh] told her [Plaintiff] I will talk to HR & then
supervision & get back to her!!
Notes from 1-28-15 Meeting, ECF No. 71-4.
. As to the comment about her hair,
Plaintiff told Ninh that Varadi specifically made a comment
about her changed hairstyle, which Plaintiff had changed to a
natural Afro style. Ninh Dep. 32; see Pl. Dep.
206-08. In her deposition, Plaintiff noted she had told Ninh
about the hairstyle comments, made both by Varadi and Johnny
Barfield. Pl. Dep. 206-08. Plaintiff indicated that she had
been told her hair was unprofessional. Pl. Dep. 207. Barfield
told Plaintiff that her new nickname was “Angela
Davis.” Pl. Dep. 207. When Plaintiff asked Barfield who
Angela Davis was, Barfield indicated she was a “civil
rights activist that was known for Black Panther. She was a
female with an afro.” Pl. Dep. 208 (relaying
. Although testimony provided to the court
does not indicate when Barfield made those comments, both the
Complaint and Plaintiffs discovery responses indicate the
encounter took place on February 16, 2015. Compl. ¶ 66;
ECF No. 71-9 at 11. In responding to interrogatories,
Plaintiff noted that this encounter with Barfield took place
on February 16, 2015. ECF No. 71-9 at 11. Plaintiff told
Varadi about the “Angela Davis” comment.
Ninh spoke with Varadi about the various issues raised by
Plaintiff, and Varadi and Plaintiff met. Pl. Dep. 170, Ninh
notes of his follow-up meeting with Plaintiff are part of the
record but are largely illegible. ECF No. 64-7 at 14. In his
declaration, Varadi indicates how he responded to Plaintiffs
concerns. See generally Varadi Decl
. Plaintiff had several discussions with
Varadi in follow-up to her 2014 CSA. See Jan. 21,
2015 email, ECF No. 71-14 (Plaintiffs expressing concerns to
Varadi). Plaintiff noted she advised Varadi his instruction
to build rapport with FPD was difficult because FPD managers
were unwilling to work with her. See id; see
generally Answer to Interrog. No. 2; Pl. Dep. 165-72.
Plaintiff cried and reiterated concerns about the
discriminatory treatment she received. See Pl. Dep.
Plaintiff disputes whether her 2014 “meets”
rating on her 2014 Final CSA affected her recognition as a
“high performer” candidate, her being highly
regarded by Eastover Mill management, and the Mill
management's belief that she was ready for advancement to
a role with greater responsibility.
of February 2, 2015, Plaintiff was contemplating resigning
from her employment with IP and she had already interviewed
with two other companies, Invista and Caraustar. She was also
considering other positions within IP. Pl. Dep. 38-40.
Plaintiff noted she was not contemplating litigation at that
time. Id. at 39.
response to Plaintiffs February 4, 2015 email to several
individuals at IP about a scheduled audit for the ISO 9001
recertification, Varadi, copying Ninh and Nyman, told
Plaintiff “well done” and “thanks for your
effort.” Ex. 14 to Pl. Dep., ECF No. 64-5 at 25.
Ninh testified that Plaintiff had been considered one of
Eastover's “high performers” since he had
been at that mill and that, as of early 2015, he considered
Plaintiff one of two “high performer” employees
at Eastover Mill. Ninh Dep. 19-30, 36-37, 40.
Plaintiff testified that she had been informed that IP
identified her early as a potential leader. Pl. Dep. 104.
Ninh and Varadi indicated Plaintiff was on a “move
list” as an employee that Eastover Mill management had
identified as ready for promotion within the Company to a
position of higher responsibility. Ninh Dep. 36-37, 45-46;
Varadi Decl. ¶ 12. Both Varadi and Ninh indicated they
had worked with Plaintiff and with other managers at Eastover
Mill to target summer 2015 as the time to move Plaintiff into
a new role. Ninh Dep. 36-37, 45-46; Varadi Decl. ¶ 12.
Partrich (HR) indicated Plaintiff was being put onto a
“move” list in 2015, which identified her as
someone to be promoted within 12 months. He indicated she had
not been on that list before she resigned. Partrich Dep.
98-100, ECF No. 64-10.
. Plaintiff “disputes” these
statements in that she notes that she “repeatedly
expressed an interest in obtaining another position.”
Pl. Mem. 4. Plaintiff notes that in 2014 she had applied for
two Manufacturing Managers positions for Box Plants and was
declined for both positions, Pl. Mem. 4 (citing 2014 Job
Applications printout, ECF No. 71-5 at 2). Further, Plaintiff
notes that when her employment with IP ended, “another
position was not available to [her] ” Pl. Mem. 4.
Pursuant to discussions with Varadi, on February 17, 2015
Plaintiff completed a Career Development Worksheet
(“CDW”), which Varadi approved. Ex. 4 to Pl.
Dep., ECF No. No. 64-5 at 4-5; Varadi Decl. ¶ 13. Varadi
commented that Plaintiff had transitioned well into her new
role, that Plaintiff was successful in helping IP achieve ISO
certification, that she had solid people and organizational
skills, and that she had a passion to succeed and excellent
management potential. ECF No. 64-5 at 4. Varadi further
commented that Plaintiff was ready to be challenged with a
new assignment after the third quarter. Id. Varadi
and Ninh indicated that the CDW is available throughout the
Company, and Eastover management used the CDW to facilitate
Plaintiffs movement to a position of higher responsibility.
Varadi Decl. ¶ 13; Ninh Dep. 36-37.
Plaintiff noted that Varadi and others inside and outside
Eastover had congratulated her several times on her
performance on both ISO certification projects and that
Varadi thanked her and told her she had done a good job when
deserved. Pl. Dep. 88-89, 145.
March 10, 2015, Plaintiff submitted her Notice of Resignation
to Varadi, Walt Partrich (HR Manager, White male), and Ninh.
Ex. 3 to Pl. Dep., ECF No. 64-5 at 3; Pl. Dep. 61-62; Ninh
Dep. 36-37; Partrich Decl. ¶ 4. Plaintiffs letter was
addressed to Varadi and stated in full as follows:
I am writing to submit my resignation from the position of
Technical Quality Leader at International Paper effective
March 24, 2015. It was not easy to make the decision to leave
after seven years. Although my time with International Paper
has been, on the whole, satisfying and productive; it also
had its challenges.
I would like to thank you for the great experience you have
provided me and I believe I have fulfilled my duties to the
best of my ability. One of the highlights of my career was
implementing the quality and environmental management system
that resulted in ISO 9001 & 14001 certification.
If there is anything I can do to make this transition easier
for the company over the next two weeks, please let me know
and I'd be more than happy to assist! This includes
assisting in recruiting and training my replacement.
Thank you again for the opportunity to work with
International Paper. I wish you and the staff all the best
with your future endeavors!
ECF No. 64-5 at 3.
Plaintiff testified that Varadi acted “stunned [but]
not ill mannered” toward her when she tendered her
resignation. Pl. Dep. 198. She noted that he did not try to
stop her from resigning and that “through all of these
behaviors and events, it wasn't a shocker” to her
and “should not have been to him.” Id.
Ninh indicated Plaintiffs resignation was a “big
shocker for all of us ” Ninh Dep. 46. Partrich
characterized the resignation as a “surprise.”
Partrich Decl. ¶ 4.
March 11, 2015, Plaintiff emailed Partrich and Ninh
requesting an exit interview. Ninh replied, “I am not
ready to accept the reality. Are you sure nothing I can do or
help? IP is a huge company and I am sure we can accommodate
your needs. You are very talented and well regard[ed].”
Ex. 17 to Pl. Dep., ECF No. 64-5 at 27. Plaintiff
acknowledged that this email indicates Ninh did not want her
to leave IP. Pl. Dep. 195.
Plaintiff testified that neither Nyman nor Varadi ever stated
that they wanted her to leave IP. Pl. Dep. 87. Plaintiff
indicated that, by his behavior, Varadi made her believe he
wanted her to leave. Id. Plaintiff noted she
received nice communications from employees who were saddened