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Rodriguez v. Talworth Digital Solutions

Maria Rodriguez, Marketing Director at Talworth Digital Solutions, was placed on a Performance Improvement Plan three weeks after filing an HR complaint about discriminatory comments from her supervisor. Two months later, she was terminated. This is how she built her case.

Clients build a detailed timeline of events from their browser, on their schedule.

Fictional timeline data for illustration only.

Hired at Talworth Digital Solutions

March 2020Employment

Maria began employment as Marketing Manager at Talworth Digital Solutions in McLean, Virginia. Annual salary $95,000. Received offer letter and signed employmen...

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Promoted to Marketing Director

June 2023Employment

Maria promoted to Director of Marketing with salary increase to $128,000. Year-end performance review rated "Exceeds Expectations" across all categories. Derek ...

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Discriminatory Comments Begin

May 2025Discrimination

Description

After returning from maternity leave, Derek Huang began making comments about Maria's "fit" and "commitment level." In a team meeting on May 14, Derek said: "I need people who are here, not people whose heads are at home." James Okafor was present and heard the comments.

How Do You Know?

I was present for these comments. They were made directly to me and in front of my team.

People Involved

Derek Huang James Okafor

Harms

Emotional Distress

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Formal Complaint to HR

July 2025Protected Activity

Description

Maria submitted a written complaint to Patricia Wells, HR Director, detailing Derek's pattern of discriminatory comments following her return from maternity leave. HR acknowledged receipt by email but took no visible investigative action.

People Involved

Patricia Wells

Documents

HR Complaint Email23 KB · Sep 9, 2025 · Maria Rodriguez

HR Acknowledgment Email12 KB · Sep 9, 2025 · Maria Rodriguez

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Performance Improvement Plan Issued

August 2025Adverse Action

Description

Three weeks after the HR complaint, Derek placed Maria on a 60-day Performance Improvement Plan citing "declining performance metrics." No prior written performance warnings existed. Maria's Q2 numbers exceeded department targets.

How Do You Know?

I received the PIP document directly from Derek in a private meeting. I have the original with his signature.

People Involved

Derek Huang

Documents

PIP Document189 KB · Sep 10, 2025 · Maria Rodriguez

Q2 Performance Report456 KB · Sep 10, 2025 · Maria Rodriguez

Harms

Emotional DistressEconomic

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Contacted J. Madison PLC

September 2025Case Management

Maria began building her case file on Cloud Counsel. Identified key witnesses, uploaded employment documents, and started constructing a detailed timeline of ev...

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Terminated

October 2025Adverse Action

Tom Archer (CEO) terminated Maria's employment citing "failure to meet PIP objectives." The termination letter references performance issues that directly contr...

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EEOC Charge Filed

November 2025Legal Proceeding

J. Madison PLC filed a dual EEOC charge on Maria's behalf: Title VII gender discrimination and Title VII retaliation for protected complaint activity. Charge in...

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Our AI engine identifies legal claims and assesses their strength.

Fictional claim analysis. Scores and assessments are illustrative, not legal advice.

Statute of Limitations

SAFE

Within filing period. EEOC charge filed timely. Title VII requires charge within 300 days of last discriminatory act — met with margin.

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Title VII Retaliation

85/100

Strong

Protected ActivityWritten HR complaint on July 2025

Employer KnowledgeHR acknowledged receipt by email

Adverse ActionPIP issued 3 weeks post-complaint; terminated

Causal ConnectionStrong temporal proximity (21 days)

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Title VII Gender Discrimination

68/100

Moderate

Protected ClassSex/gender; post-maternity-leave targeting

Qualified for PositionPromotion + excellent reviews pre-leave

Adverse ActionPIP and termination

Comparator EvidenceNeed evidence of male peers treated differently

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Attorney and client collaborate directly on the case file.

Fictional exchange. Not a depiction of actual privileged communications.

Discussion on: Performance Improvement Plan Issued

Maria Rodriguez

The PIP document says my Q2 numbers were "below target" but I have the actual Q2 report showing I exceeded every metric. Derek never mentioned performance concerns before my HR complaint.

Sep 15, 2025 at 3:42 PM

Attorney Small

That's very helpful. Do you have any emails from before the complaint where Derek praised your work or acknowledged strong results? Those would directly contradict the PIP narrative.

Sep 15, 2025 at 4:18 PM

Maria Rodriguez

Yes! He sent a company-wide email in April calling my Q1 campaign "the best launch we've ever had." I'll upload it now.

Sep 15, 2025 at 4:31 PM

Learn about secure collaboration

Witnesses contribute their own accounts, building a multi-perspective case file.

James Okafor

Witness & Contributor

Star Witness

Corroborating Statement: Discriminatory Comments

"I was in the May 14 team meeting when Derek made those comments about Maria. He specifically said 'I need people who are here' while looking at Maria. It was uncomfortable for everyone in the room. Two other team members exchanged looks. Derek had never said anything like that before Maria went on maternity leave."

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