Full opinion text
MEMORANDUM OPINION AND ORDER SHEILA FINNEGAN, United States Magistrate Judge. Plaintiffs Elizabeth Castro, Michael A. Florez, and LaTonya Brooks filed a two-count complaint charging their former employer, DeVry University, with (a) subjecting them to a hostile work environment through derogatory racial and ethnic statements by their supervisor, and (b) terminating their employment in retaliation for complaining about the supervisor’s conduct, both in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., as amended by the Civil Rights Act of 1991. The parties consented to the jurisdiction of the United States Magistrate Judge pursuant to 28 U.S.C. § 636(c). DeVry has now filed separate motions for summary judgment as to each Plaintiff. In their consolidated response, Plaintiffs concede that the hostile work environment claims should be dismissed but argue that the retaliatory discharge claims must be decided by a jury. For the reasons set forth below, the Court grants DeVry’s motions for summary judgment as to all claims. OVERVIEW In April 2007, Plaintiffs went to Human Resources (“HR”) and jointly complained about their manager, Phil Giambone, the Dean of Admissions for DeVry’s Chicago office. Castro was an Assistant Dean, directly supervising Brooks and Florez who worked as “Advisors” in recruiting students. During the meeting with HR, Plaintiffs said Giambone created a “hostile environment” because of his derogatory ethnic and racial comments and his “management by threats” style. They gave ex-ampies of the derogatory comments that he frequently made. As for the threats, Brooks described how she questioned Giambone at a meeting about the very old recruiting leads they were receiving and he later warned that she would not be around long if she was disloyal to him. Plaintiffs also complained to HR that Giambone made Advisors feel guilty for taking a vacation or personal day. They said his lack of management skills had led to extremely low morale and was the reason so many Advisors had left, predicting more would do so if his behavior continued. A few months later, in July 2007, DeVry made a number of personnel changes. Giambone was moved out of the Chicago office and into the field, so his interactions with Plaintiffs ceased (in August 2008 he stopped working for DeVry entirely). A handful of others were also moved, including Castro. Though her salary did not change, Castro was stripped of her supervisory duties and transferred to another office where she worked as a Senior Advis- or. Florez and Brooks remained in the Chicago office but reported to new supervisors. Each Plaintiff remained at DeVry for an extended period after this but ultimately was terminated: Florez in February 2008, Brooks in July 2008, and Castro in November 2009. In September 2010, Plaintiffs filed this joint lawsuit, alleging that each was fired in retaliation for complaining to HR about Giambone in April 2007. DeVry acknowledges that Plaintiffs engaged in “protected conduct” when they informed HR about Giambone’s derogatory racial and ethnic comments. All parties agree that the key issue now is whether Plaintiffs can establish a causal nexus between that protected conduct and their eventual terminations under different supervisors several months later: 10 months later for Florez; 15 months later for Brooks; and 26 months later for Castro. In opposing summary judgment, Plaintiffs argue that they have established that nexus using the direct method of proof and based on circumstantial evidence. To overcome the lack of temporal proximity between the protected conduct and the terminations, Plaintiffs focus heavily on Giambone’s “retaliatory” conduct shortly after the meeting with HR even though he admittedly was gone three months later and played no role in their terminations. Plaintiffs also attempt (without success) to show that their new supervisors learned and cared that they told HR about Giambone’s offensive statements and thus were motivated to retaliate and eventually terminate them. Unfortunately for Plaintiffs, even when the factual disputes are resolved (and inferences drawn) in their favor, they are unable to muster sufficient evidence of a causal connection between the protected conduct and the terminations. Given all the circumstances here, including the change in supervisors, the long passage of time between the protected conduct and the terminations, and the many intervening events that bear on what happened, no reasonable inference can be drawn that the terminations were in retaliation for the protected conduct. FACTUAL BACKGROUND A. The Parties DeVry is a for-profit organization that grants higher education degrees in Illinois and elsewhere. See DeVry website, http:// www.devry.edu (last .visited Apr. 16, 2013). During the relevant time period, Christine Hierl served as Dean of Enrollment Management for the Chicago Metro area (hereinafter “Dean Hierl”). (Hierl Decl., Doc. 49-3 at ¶2). Reporting to Dean Hierl were two Directors of Admissions (“DA”): Phil Giambone was responsible for the Chicago office, and Kathaleen Berry was responsible for the other two Chicagoland DeVry locations in Addison and Tinley Park. (Id. at ¶ 3). Plaintiffs Elizabeth Castro, Michael Florez, and LaTonya Brooks are former DeVry employees. (PI. Castro’s 56.1 Resp. (“Castro Resp.”), Doc. 70 at ¶ 1; PL Florez’s 56.1 Resp. (“Florez Resp.”), Doc. 71 at ¶ 1; Pl. Brooks’s 56.1 Resp. (“Brooks Resp.”), Doc. 72 at ¶ 1). Castro and Florez both consider themselves to be of Mexican national origin. (Castro Resp., Doc. 70 at ¶ 1; Florez Resp., Doc. 71 at ¶ 1). Brooks considers her national origin to be African-American and her race to be Black/Non-Hispanic. (Brooks Resp., Doc. 72 at ¶ 1). Castro began forking for DeVry in 1997 as a secretary, and by January 2006 was an Assistant Director of Admissions (“ADA”) in the Chicago office. (Castro Resp., Doc. 70 at ¶ 5; Pis’ Add’l Facts, Doc. 69 at ¶¶ 1-2). Until July 2007, Castro supervised co-plaintiffs Florez and Brooks. (Florez Resp., Doc. 71 at ¶ 6; Brooks Resp., Doc. 72 at ¶ 5). Castro in turn reported to DA Giambone who reported to Dean Hierl. (Castro Resp., Doc. 70 at ¶¶ 5-6; Florez Resp., Doc. 71 at ¶ 6). Florez and Brooks both worked as Advisors. Giambone interviewed and hired Florez in October 2005; Florez was based out of his home at that time. Giambone twice promoted Florez — to Advisor I and then to Advisor II. (Florez Resp., Doc. 71 at ¶ 7). Brooks began working as an Advisor in the Chicago office in October 2006. (Brooks Resp., Doc. 72 at ¶ 5). As Advisors, Florez and Brooks were responsible for “doing phone work, interviewing prospective students, performing follow-up with prospective students, and otherwise assisting prospective students with the enrollment process, all with the ultimate goal of securing students to commence school at DeVry.” (Castro Resp., Doc. 70 at ¶ 8). Castro’s responsibilities as an ADA consisted of recruiting students to enroll at DeVry, as well as hiring, training, overseeing, and coaching Advisors and ensuring budgets were met. (Id. at ¶¶ 7, 9). The primary performance measure for ADAs and Advisors “was the number of students secured to commence school at DeVry,” or “starts,” with Advisors evaluated on their own numbers and ADAs evaluated on both their own numbers and their team’s overall numbers. (Id. at ¶ 9). Ad-visors were also evaluated on the process they used to secure starts, such as the number of interviews conducted and applications received. (Brooks Resp., Doc. 72 at ¶ 8). DeVry sat new classes every two months in odd months. (Castro Resp., Doc. 70 at ¶ 10). B. The 2006 Departmental Reorganization In the summer of 2006, DeVry reorganized the Enrollment Management Department to categorize ADAs and Advisors either as presenters, who visited high schools to generate leads, or as recruiters, who worked in DeVry offices to convert leads into student enrollments. (Castro Resp., Doc. 70 at ¶ 11). As a result of the reorganization, Castro was assigned to be one of two ADAs in the Chicago office where she continued to report to Giambone and had more interaction with him than she did previously. (Castro Dep., Doc. 49-9 at 49:14-50:9, 76:4-8). There, she served as ADA for a team of two Advisors, Florez and Brooks, who were newly designated as “recruiters” at the Chicago office. (Castro Resp., Doc. 70 at ¶ 11; Hierl Deck, Doc. 49-3 at ¶¶ 7-8). In this revised role, all Advisors were now expected to work from DeVry offices rather than from their homes, which meant that instead of going to the homes of prospective students as they previously did, the Advisors scheduled appointments with students and their parents in the DeVry offices. (Castro Deck, Doc. 74-1, Tab B at ¶ 3). As a result, “the number of ‘no-shows’ increased dramatically, thus making recruiting more difficult.” (Id.) C. Castro’s Transfer Request In October 2006, several months after the reorganization, Castro complained to Giambone that she and her team members were receiving “really bad” leads. She complained again in January 2007 after finding undistributed leads in a drawer. (Castro Resp., Doc. 70 at ¶ 13). During this same time period, Castro talked to Dean Hierl and DA Berry (Giambone’s counterpart in the Tinley Park and Addison offices) about possibly transferring to Berry’s region. (Castro Dep., Doc. 74-4 at 78:16-79:21). Castro testified that she asked Berry about transferring to her office, but Berry said Hierl would never approve it. Hierl said she needed Castro to help in Chicago because Castro was a great ADA. (Id. at 78:16-79:1). On January 22, 2007, Castro contacted Deb Maher, DeVry’s Director of Human Resources and Ethics Officer, to request a transfer to another department. (Castro Dep., Doc. 74 — 4 at 82:1-19). Maher emailed her the transfer request form, which Castro submitted a couple months later. (Id. at 83:5-14). However, Dean Hierl told Castro she would not allow a transfer until after the July class. (Id. at 156:12-19). In March 2007, Hierl told Castro that she believed Castro’s production levels did not justify her compensation. Castro responded by complaining about the quality of the leads she was being given. (Castro Resp., Doc. 70 at ¶¶ 15-17). D. Giambone’s Derogatory Racial and Ethnic Comments When she began working more closely with Giambone after the reorganization, Castro found him to be “a micromanager who unnecessarily and constantly harangued all his subordinates to ‘get on the phone.’ ” (Castro Resp., Doc. 70 at ¶ 12). Moreover, he made frequent racial and ethnic comments within the office. Plaintiffs and at least two other employees found the comments offensive. (Brooks Dep., Doc. 74-2 at 46:11-47:24; Castro Dep., Doc. 74-4 at 98:14-24; Florez Dep., Doc. 74-3 at 167:7-169:10; Leal Dep., Doc. 74-8 at 26:1-27:14; Lucio Dep., Doc. 74-12 at 41:5-42:8). For example, Giambone regularly asked about the ethnicity of potential students they were attempting to recruit by linking the potential students’ ethnicity to their ability to pay the $100 deposit. Former Advisor Mara Leal testified that Giambone “would say that a Hispanic person, more like a Mexican, always had $100; Puerto Rican, a black person were always broke.” (Leal Dep., Doc. 74-8 at 26:6-9). Leal also said Giambone would make such statements “[a]s often as I didn’t close somebody, because I was supposed to be able to close my own kind. I’m Mexican.” (Id. at 26:12-14). Brooks testified that Giambone said to her, “‘Well, Puerto Ricans never have any money and Mexicans always have their Catholic money.’ ” (Brooks Dep., Doc. 74-2 at 47:1-3). Likewise, Castro testified, “Every time we had an interview [Giambone] said, ‘So, were they Mexican? Did they have $100? Oh, they didn’t have $100? They were probably Puerto Rican, or they were black.’ ” (Castro Dep., Doc. 74-4 at 98:16-19). Advisor Leo Lucio observed Giambone making similar comments “[w]henever we had interviews” and more frequently “when numbers were down.” (Lucio Dep., Doc. 74-12 at 42:2-5). Florez testified that Giambone told him, “ ‘Mexicans always have $100 in their mattress because it’s communion money.’ ” (Florez Dep., Doc. 74-3 at 168:5-6). All five employees testified that they found Giambone’s comments to be offensive and unprofessional, and that they repeatedly asked him to stop making them, to no avail. (Castro Dep., Doc. 74-4 at 106:19-107:10; Lucio Dep., Doc. 74-12 at 42:12-24; Brooks Dep., Doc. 74-2 at 48:17-50:5; Florez Dep., Doc. 49-11 at 167:7-23; Leal Dep., Doc. 74-8 at 27:5-20). As further evidence of Giambone’s offensive comments, Florez testified that in reference to a young Hispanic couple he interviewed, Giambone stated, “ ‘How old are they? You know, 18, 19 years old and they’re married already? Oh, she must be pregnant,’ ” which Florez construed to suggest “that Mexicans are underage, they get pregnant, and underneath the Catholic religion their parents make them get married ...” (Florez Dep., Doc. 74-3 at 168:22-169:5). Also, on April 14, 2007, Florez asked Giambone for permission to take May 5th off from work to attend a wedding, to which Giambone responded by asking if Florez was going to “get drunk with your people, the Mexicans, on Cinco de Mayo for La Raza?” (Id. at 198:14-24; 200:1-6). Florez was offended by the remark and reported it to his supervisor, Castro, who also found it upsetting. (Id. at 199:20-24; 200:21-23; Castro. Dep., Doc. 74-4 at 110:3-11). Finally, Giambone assigned neighborhoods and leads based on race or national origin. For example, Brooks testified that Giambone assigned her leads “from schools that were primarily on the south side, which are predominantly black schools.” (Brooks Dep., Doc. 74-2 at 50:6-51:2). Similarly, Advisor Lucio testified that Giambone “always put the Black ad-visors in the Black neighborhoods, Latinos with Latinos[,] and Whites with 'Whites,” and that he knew this to be true “[b]eeause [Giambone] told us.” (Lucio Dep., Doc. 74-12 at 39:10-17). Leal, who is of Mexican heritage, testified that Giambone gave her “Spanish leads.” (Leal Dep., Doc. 74-8 at 30:15-23). E. Plaintiffs Complain to HR on April 16, 2007 (“Protected Conduct”) On April 16, 2007, Castro, Florez, and Brooks met with Alana Hurt from the Human Resources Department (“HR Officer Hurt”) to complain about Giambone’s deficiencies as a supervisor, including the offensive racial and ethnic remarks. (Castro Resp., Doc. 70 at ¶ 19; Florez Resp., Doc. 71 at ¶ 18; Brooks Resp., Doc. 72 at ¶ 16.). Since Plaintiffs do not challenge the accuracy of Hurt’s typewritten summary of what occurred (this was confirmed during oral argument on the motions), the summary is included in its entirety: The above advisors [Brooks, Castro, and Florez] came to meet with me to voice their concerns regarding Phil Giambone. According to the advisors, Phil creates a “hostile environment” with derogatory comments and his “management by threats” attitude. There is an incentive program within the group whereby any advisor that has four applications by Thursday can take Saturday off. Mike Florez had four applications last week, but had to come into work, because he had scheduled appointments. He asked Phil if he could take another Saturday off instead. Phil asked which Saturday he wanted off. Mike asked for May 5 off. Phil laughed. He said, “Oh, yeah. I get it. You want to go celebrate with your people. La Raza ... because it is Cinco de Mayo.” [Mike is Mexican.] Mike replied, “Actually, I have a wedding to go to, and it’s my wife’s birthday.” According to Mike, Phil constantly asks the ethnicity of applicants when he knows they have had interviews with students. He’ll secondly ask, “Did you get the $100?” On more than one occasion if the student was of Mexican descent, Phil has remarked, “Well make sure you press them, because you know Mexicans always have $100 on them, guaranteed.” This was corroborated by Liz [Castro] and Mara Leal. On another occasion Mike had a young couple come to see him. The girl was interested in attending DeVry. After they left, Phil asked if Mike had signed them both. Mike told Phil that they were a young couple (the girl was 18; her husband was 19) and had limited resources. They could not afford to both go to school. He told Phil the couple was just married and starting out. Phil remarked, “She’s 18, and he’s 19 ... and they are married? She must be pregnant, because you know Mexicans are really religious, and they will marry at an early age if the girl is pregnant.” Mike said, “Why can’t they just be married, because they are in love?” LaTonya Brooks questioned Phil in a meeting, because there was a problem with them getting leads. The group was getting very old leads. After the meeting Phil approached LaTonya and told her that he needed to speak with her. He went on to say, “This business is all about loyalty. Your questioning me in the meeting embarrassed me in front of the team. If you want to get anywhere in this company, you need to show some loyalty, because I have Christine Hierl, Virginia Mechnig and Dave Pauldine in my back pocket. If you are not loyal to me, you will not be around very long.” LaTonya felt like her job was threatened and vowed never to speak up in a meeting again. Phil makes the advisors feel guilty for taking a vacation or personal day. He has asked advisors to come in on their vacation to work. He told them that he didn’t understand why he had to give them Saturday, April 7 off. The Spring Holiday was on Friday. It is their regular day off. I told Phil to give them an alternative day off for the holiday. He told the advisors that “in his day they worked seven days a week.” They believe that Phil’s lack of management skills has been the reason so many people have left. Furthermore, they believe people will continue to leave, as long as Phil is allowed to continue to behave the way he does. The morale of the team is extremely low. (Def.’s Appx., Doc. 49-54). As Castro recalled at her deposition, Plaintiffs told Hurt about how Giambone made racial comments “every day” and about his “demotivating” and “demeaning” remarks towards people, his “unprofessional and rude” behavior, the fact that he didn’t know how to distribute leads, and that he was hurting production. (Castro Dep., Doc. 49-9 at 102:22-105:15,134:10-14). Shortly after meeting with Plaintiffs, HR Officer Hurt called Maher, the director of HR, to tell her about the complaint. (Def.’s Reply to Pis’ Rule 56.1 Statement (“Def.’s 56.1 Reply”), Doc. 84 at ¶ 23; Hurt Dep., Doc. 74-14 at 22:14-15). Hurt then investigated the complaint by composing 16 questions and posing these to three other advisors from Giambone’s team, including Mara Leal. (Hurt Dep., Doc. 74-14 at 24:9-17, 30:6-20, 31:21-32:22, Exh. 1; Leal Dep., Doc 74-8 at 63:7-65:16). These questions inquired as to the “greatest challenge” faced by the group and how they could be “more successful,” and asked for an assessment of how the team was managed and the “climate of the work environment.” Still other questions focused on whether the advis- or had ever witnessed “any unprofessional conduct or inappropriate language.” (Hurt Dep., Doc. 74-14 at Exh. 2). Upon the HR Director’s suggestion, HR Officer Hurt informed Dean Hierl of Plaintiffs’ complaint by providing her with the results of the investigation about a week after the complaint was made. (Hurt Dep., Doc. 74-14 at 44:4-45:3). After learning of the complaint, Dean Hierl informed Giambone about it, characterizing this as an example of Castro’s negativity. (Pis’ Add’l Facts, Doc. 69 at ¶ 35; Giambone Dep., Doc. 74-9 at 52:12-20). Hierl did not share the details concerning whom or what was said to HR. (Giambone Dep., Doc. 74-9 at 47:9-49:15). Giambone assumed the topic was something to do with production. (Id. at 48:11-16). F. Giambone’s Post-Complaint Conduct Minutes after the April 16th meeting with HR ended, Giambone went to Castro’s office looking “mad, like he was going to hit me,” demanding to observe her do phone work, telling her she was “never going to go to PRIDE and [she was] not going to make [her] budget,” and “furiously]” asking, “ ‘Do you have anything to tell me? Do you want — anything you want to talk about?’ ” (Castro Dep., Doc. 74-4 at 142:9-143:14). Castro and Florez perceived that Giambone then began restricting their leads. (Id. at 138:20-24; Florez Dep., Doc. 74-3 at 100:4-7). They began receiving “do not call” leads. (Florez Deck, Doc. 74-1, Tab C at ¶ 2.) They also ceased receiving ESM (electronic) leads, though there is no evidence as to whether they were unique in this respect. Brooks testified generally that her “lead flow diminished” after the April 16th meeting, but also conceded that leads typically diminish “around June” when high school students are out of school. (Brooks Dep., Doc. 74-2 at 69:23-70:7, 71:22-72:19). G. Chicago Team Meeting on April 28, 2007 On April 28, 2007, Dean Hierl convened a team sales meeting attended by the Chicago team, including Plaintiffs. The meeting was motivated at least in part by Hierl’s concerns “that we were not going to make budget.” (Castro Dep., Doc. 74-4 at 151:15-22). Hierl wanted to “reiterate that we needed to stay on task and that we needed to ... focus on our class.” (Id.). This was a concern because, as Castro put it, “[t]he July class was our biggest class. It was our ultimate class. It was what we worked all year for.” (Id. at 151:23-152:1). During the meeting Castro said that “ ‘[o]ne of the main reasons why we’re here today is because Joe [Mucinski] or Phil [Giambone] passed out sophomore leads. We need to be careful. We are recruiting seniors, not sophomores.’ ” (Id. at 150:1-23). After Castro made these remarks, Dean Hierl verbally attacked her for the comments to the point of reducing Castro to tears. (Pis’ Add’l Facts, Doc. 69 at ¶¶ 32-33; Giambone Dep., Doc. 74-9 at 36:8-23). Castro attributes this reprimand to Hierl’s racism since immediately after the meeting, Castro overheard Hierl say to Giambone in a stairwell, “ ‘There’s no way we’re going to let a bunch of wetbacks run this office.’ ” (Castro Dep., Doc. 74-4 at 176: 6-14). Several days after the April 28th meeting, Dean Hierl sent Castro a memo, with copies to Giambone and HR Officer Hurt. The memo noted that Hierl had convened the meeting due to “low” performance and “dismal” morale. The memo then criticized Castro for her conduct during the meeting in repeatedly ignoring Hierl’s request to keep comments positive and for engaging in an “unprofessional and disrespectful rant” against Giambone and colleague Joe Mucinski. (Def.’s Appx., Doc. 49-27). In particular, she identified Castro’s statement that she “ ‘had to get something off [her] chest,’ ” which Hierl said was followed by criticism of Giambone and Mucinski, including the statement that “ ‘we are in the position we are in because Joe and Phil weren’t paying attention and dropped the ball.’ ” (Id.). After receiving the memo, Castro sent a note to Hierl in response stating that she did not feel she had acted inappropriately. (Castro Dep., Doc. 74-4 at 153:3-7). Castro was very upset by the “wetback” comment and decided that she needed a transfer. (Castro Dep., Doc. 74-4 at 178:14-20). Two days later, on April 30, 2007, Castro submitted another transfer request for any opening for an ADA or DA position, and indicated that she “would like to work closer to home.” (Def.’s Appx., Doc. 49-28). Giambone signed off on the transfer request the same day. (Id.; Castro Dep., Doc. 74-4 at 154:1-156:10). Dean Hierl agreed to work with Castro to facilitate a transfer after the July class was seated (Castro Dep., Doc. 74-4 at 156:5-19), but later said she was not going to approve the transfer. (Castro Decl., Doc 74-1, Tab B at ¶ 8). The record does not indicate what reason, if any, Hierl gave Castro for her decision to deny the transfer request. H. Changes in Leadership/Offices in July 2007 In July 2007, Dean Hierl made a number of organizational changes. First, she replaced Giambone with Kathaleen Berry as the DA in the Chicago office. Berry already served in this position for the two suburban offices in Addison and Tinley Park but she now assumed responsibility for the Chicago office as well. (Hierl Deck, Doc. 49-3 at ¶ 11). Giambone was transferred out of the Chicago office and into the field where he resumed a prior position as High School Manager. (Id. at ¶ 10). At this point he ceased having supervisory authority over Plaintiffs or day-to-day contact with them. (Castro Resp., Doc. 70 at ¶ 32; Florez Resp., Doc. 71 at ¶ 29; Brooks Resp., Doc. 72 at ¶ 20). By August 2008, Giambone stopped working for DeVry entirely. (Offutt Deck, Doc. 49-5 at ¶ 4). Also as part of Dean Hierl’s organizational changes, Joe Mucinski, who had been a High School Manager, was demoted to an Advisor, reporting to Giambone. (Hierl Decl., Doc. 49-3 at ¶ 10). Hierl retained Lourdes “Lou” Ramos as an ADA in the Chicago office but ADA Julie Strauss, from the Tinley Park office, began spending more time at the Chicago office to assist Ramos. (Florez Resp., Doc. 71 at ¶ 31; Brooks Resp., Doc. 72 at ¶ 23). Hierl eliminated the second ADA position in Chicago (the one that Castro had held), and transferred Castro to the Addison office where she was demoted to Senior Ad-visor. There Castro reported to ADA Karen “Casey” Tobin, who in turn reported to DA Berry. (Hierl Decl., Doe. 49-3 at ¶ 9; Castro Dep., Doc. 49-9 at 183:19— 184:22, 199:9-17). Hierl maintained the pay of Castro, Giambone, and Mucinski at the same levels as before. (Hierl Decl., Doe. 49-3 at ¶ 12). On July 11, 2007, after Castro’s transfer, Giambone said to Florez: “ You see what happens to traitors like Liz [Castro], ... I told you if you want to be someone in this company, you need to be loyal.’ ” (Florez Dep., Doc. 74-3 at 216:10-14). Castro believed she was demoted because “I went to HR, and they were going to use me as an example.” (Castro Dep., Doc. 74-4 at 198:2-8). Dean Hierl testified that she wanted Castro out of the Chicago office because she was the “primary negative person” there. (Hierl Deck, Doc. 49-3 at ¶ 12). She largely blamed Castro for the office’s performance problems as reflected by her comments in Giambone’s performance review for the first half of 2007 (rated not meeting expectations), where Hierl wrote: “Although Phil made his March and May classes, July was a disaster. He was plagued with morale and personnel issues and this directly affected performance. Phil gave it his best shot to minimize the loss from July, unfortunately, with unmotivated advisors and manipulating Assistant Directors the class was too far gone.” (Pis’ Add’l Facts, Doc. 69 at ¶ 58; Giambone Dep., Doc. 74-9 at 118:1— 6). Giambone testified that he understood Castro to be the “manipulating” Assistant Director referenced in the review. (Pis’ Add’l Facts, Doc. 69 at ¶ 58; Giambone Dep., Doc. 74-9 at 119:16-120:3). After the staff changes in July 2007, Florez and Brooks remained in DeVry’s Chicago office under the supervision of ADAs Strauss and Ramos and DA Berry. Castro worked out of the Addison office where she was supervised by ADA Tobin and DA Berry. Since the facts as to each Plaintiff diverge considerably after July 2007, this Opinion discusses these facts later as part of the analysis of each Plaintiffs retaliatory discharge claim. DISCUSSION On September 15, 2010 (approximately one year after Castro’s termination), Plaintiffs filed their joint two-count lawsuit. Count I sought damages for a “hostile work environment as a result of derogatory racial and ethnic statements being made by their supervisor.” (Compl., Doc. 1 at ¶ 10). Plaintiffs now acknowledge that this claim must be dismissed. (Pis’ Br., Doc. 73 at 13). Brooks and Florez waited too long to assert such a claim so it is time barred. See Nagle v. Vill. of Calumet Park, 554 F.3d 1106, 1121 n. 4 (7th Cir.2009). Castro is estopped from recovering for such a claim due to omissions from a bankruptcy filing. See Johnson v. ExxonMobil Corp., 426 F.3d 887, 891 (7th Cir.2005) (Judicial estoppel is an equitable doctrine that “prevents a party from adopting a position in a legal proceeding contrary to a position successfully argued in an earlier legal proceeding.”). Plaintiffs’ lawsuit also alleged that they complained to DeVry’s human resources department about the behavior of their supervisor in April 2007. (Compl., Doc. 1 at ¶ 11). “Following their complaint, each of the plaintiffs was subjected to retaliation, harassment and different terms and conditions of employment, including threats made by their supervisor specifically as a result of plaintiffs’ having reported his conduct.” (Id., ¶ 12). But they seek to recover damages only for their terminations, alleging in Count II that they were fired in retaliation for their “protected conduct” and because of their national origin (Castro and Florez) and race (Brooks). (Id., ¶¶ 14-16). A. Summary Judgment Legal Standard Summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A genuine issue of material fact exists when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986); Pugh v. City of Attica, Ind., 259 F.3d 619, 625 (7th Cir.2001). The moving party bears the initial burden of identifying evidence demonstrating the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323-24, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). To survive a defendant’s motion for summary judgment, a plaintiff “must present sufficient evidence to show the existence of each element of its case on which it will bear the burden at trial.” Serfecz v. Jewel Food Stores, 67 F.3d 591, 596 (7th Cir.1995) (citing Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 585-86, 106 S.Ct. 1348, 1355, 89 L.Ed.2d 538 (1986)). In ruling on a motion for summary judgment, “[a] court’s role is not to evaluate the weight of the evidence, to judge the credibility of witnesses, or to determine the truth of the matter, but instead to determine whether there is a genuine issue of triable fact.” Nat’l Athletic Sportswear, Inc. v. Westfield Ins. Co., 528 F.3d 508, 512 (7th Cir.2008) (citing Anderson, 477 U.S. at 249-50, 106 S.Ct. 2505). The court must construe all facts in the light most favorable to the non-moving party and draw all reasonable inferences in favor of that party. Anderson, 477 U.S. at 255, 106 S.Ct. 2505; Arizanovska, 682 F.3d at 702. B. Title VII Retaliation Legal Standard Since the hostile work environment claim is out of the case, this Opinion focuses solely on the retaliatory discharge claim. An employer is prohibited from discriminating against an employee “because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under [Title VII]” 42 U.S.C. § 2000e-3(a); see Milligan v. Bd. of Trustees of S. Ill. Univ., 686 F.3d 378, 388 (7th Cir.2012). “The antiretaliation provision seeks to prevent employer interference with ‘unfettered access’ to Title VH’s remedial mechanisms ... by prohibiting employer actions that are likely ‘to deter victims of discrimination from complaining to the EEOC,’ the courts, and their employers.” Milligan, 686 F.3d at 388 (quoting Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53, 68, 126 S.Ct. 2405, 165 L.Ed.2d 345 (2006)). A plaintiff may defeat a motion for summary judgment by establishing retaliation using either the direct or indirect method of proof. Hoppe v. Lewis Univ., 692 F.3d 833, 841 (7th Cir.2012). Here Plaintiffs’ counsel clarified during the oral argument that they are relying only on the direct method. Under this method, a plaintiff must present evidence from which a jury could conclude that (1) he engaged in a statutorily protected activity; (2) he suffered a materially adverse employment action; and (3) a causal connection exists between the two. Id. (citing Benuzzi v. Bd. of Educ. of City of Chicago, 647 F.3d 652, 664 (7th Cir.2011); Harper v. C.R. England, Inc., 687 F.3d 297, 306 (7th Cir.2012)). DeVry does not contest that the first two elements are satisfied here: Plaintiffs engaged in protected activity when they complained of Giambone’s derogatory racial and ethnic comments (Hoppe, 692 F.3d at 842); and termination of employment constitutes an adverse employment action (Harper, 687 F.3d at 306). Thus, to defeat summary judgment, Plaintiffs need only show a causal link between the two. “[T]o put it another way, the plaintiffs must produce evidence that a ‘retaliatory animus’ motivated the defendants’ adverse actions against them.” Brown v. Advocate S. Suburban Hosp. et al., 700 F.3d 1101, 1106 (7th Cir.2012) (quoting Smith v. Bray, 681 F.3d 888, 901 (7th Cir.2012)). Plaintiffs may make this showing using either direct or circumstantial evidence. Evidence is direct when, “if believed by the trier of fact, [it] will prove the particular fact in question without reliance on inference or presumption.” Harper, 687 F.3d at 307 (quoting Pitasi v. Gartner Grp., Inc., 184 F.3d 709, 714 (7th Cir.1999)). “ ‘Because direct evidence ... essentially requires an admission by the employer,’ such evidence ‘is rare.’ ” Harper, 687 F.3d at 307 (quoting Benders v. Bellows & Bellows, 515 F.3d 757, 764 (7th Cir.2008)). Plaintiffs in this case do not offer any such admissions. Instead, they endeavor to present a “ ‘convincing mosaic of circumstantial evidence’ that would permit the same inference without the employer’s admission.” Coleman v. Donahoe, 667 F.3d 835, 860 (7th Cir.2012) (citing Rhodes v. Illinois Dep’t of Transp., 359 F.3d 498, 504 (7th Cir.2004), quoting Troupe v. May Dep’t Stores Co., 20 F.3d 734, 737 (7th Cir.1994)) (internal quotations omitted). Three categories of such circumstantial evidence have been recognized by the Seventh Circuit: (1) “ ‘suspicious timing, ambiguous statements, behavior toward or comments directed at other employees in the protected group, and other bits and pieces from which an inference of discriminatory intent might be drawn.’ ” Harper, 687 F.3d at 307 (quoting Boumehdi v. Plastag Holdings, LLC, 489 F.3d 781, 792 (7th Cir.2007)); (2) evidence showing that similarly situated employees who did not engage in protected activity were treated better; and (3) evidence showing that a defendant’s stated reason for taking action against the employee (here, terminating him or her) is not believable and is a pretext for the real and discriminatory reason. Harper, 687 F.3d at 307; Coleman, 667 F.3d at 860. Plaintiffs argue that there is substantial evidence in each of these categories but examination of the record shows otherwise. Plaintiffs lack evidence of suspicious timing given the many months between the protected conduct and the terminations. They also are unable to identify any similarly situated employees who were treated better than they were. Plaintiffs focus most heavily on attempting to show that their new supervisors’ stated reasons for terminating them were pretextual. This Opinion analyzes the pretext and other arguments specific to each Plaintiff below after summarizing the post-July 2007 evidence for each. But first it examines the suspicious timing argument that is common to all Plaintiffs. C. Suspicious Timing Argument Advanced by All Plaintiffs Plaintiffs argue that a jury could infer a causal nexus between the protected conduct and the terminations because of suspicious timing. Yet it is undisputed that Florez remained a DeVry employee for ten months after complaining to HR, Brooks remained fifteen months, and Castro remained twenty-six months. This forecloses them from relying on suspicious timing or temporal proximity to make the required showing under the direct method. See Kidwell v. Eisenhauer, 679 F.3d 957, 967 (7th Cir.2012) (finding that “extended time gaps” of five weeks and two months between protected activities and alleged retaliation “militate against” inferring causation); Harper, 687 F.3d at 308-09 (finding gap of three and a half to five months between complaints and termination too lengthy to support inference of retaliation); O’Leary v. Accretive Health, Inc., 657 F.3d 625, 634-35 (7th Cir.2011) (two-month gap between plaintiffs complaint and his termination was too lengthy to show causal nexus between the two); Healy v. City of Chicago, 450 F.3d 732, 741 n. 11 (7th Cir.2006) (finding no suspicious timing where adverse action took place more than a year after protected conduct). In any event, suspicious timing alone is rarely sufficient to create a triable issue in the absence of any corroborating evidence of retaliatory motive, and Plaintiffs lack such corroborating evidence here. Smith, 681 F.3d at 907 (finding that “short gap” of “a few months” between discrimination complaints and termination, absent any other evidence of retaliatory intent, does not support inference of retaliation) (citing Coleman, 667 F.3d at 860); Harper, 687 F.3d at 308-09. In an effort to overcome the long gap in time between the protected conduct and their terminations, Plaintiffs focus great attention on alleged retaliatory acts of Giambone that occurred suspiciously soon after the complaint to HR in April 2007. Specifically, Plaintiffs stress testimony from Florez and Castro that they began receiving “do not call” leads and attributed this to Giambone; however, there is no admissible evidence that they were unique in this respect and, of course, Giambone’s inability to effectively distribute leads was a concern before and during the meeting with HR in April 2007. (Castro Dep., Doc. 49-9 at 13:5-15). Regardless, even assuming Giambone retaliated against Plaintiffs by restricting leads or in other ways, it is undisputed that Giambone was entirely out of the picture within three months of the protected conduct and had nothing more to do with them. After this, their interactions were with entirely new supervisors: ADA Strauss and DA Berry (for Florez and Brooks) and ADA Tobin and DA Berry (for Castro). Had Giambone instead remained their manager and continued engaging in retaliatory acts until he eventually sought their terminations, the suspicious timing argument would perhaps have some force, but this is not what happened here. Plaintiffs next try to equate this case with Hasan v. Foley & Lardner, LLP, 552 F.3d 520 (7th Cir.2008), a discrimination case in which the Seventh Circuit reversed the district court’s ruling that a gap of one year between a law firm partner’s anti-Muslim remarks and the firing of a Muslim associate was insufficient evidence of discriminatory intent under the direct method. Significantly, the partner who made the discriminatory remarks remained at the firm during this time, and “[t]he record shows that [the partner] attended the meeting at which the partners decided to fire Mr. Hasan and that he participated in that decision.” Hasan, 552 F.3d at 528. The Seventh Circuit further noted that “[t]here is also evidence in the record that [the partner’s] criticisms at that meeting incited anti-Muslim and racially charged commentary from other partners” who then “piled on” their own criticisms. Id. As a result, there was evidence directly linking the anti-Muslim comments to the termination decision. Here, in contrast, there is no such direct link between the protected conduct and the termination decisions many months later. To the contrary, the supervisor who made the offensive ethnic and racial remarks was transferred to a different position and location where he ceased all involvement with Plaintiffs long before the terminations. And as discussed later, there is no evidence that the new supervisors who eventually sought to terminate Plaintiffs (ADA Strauss and DA Berry) were even aware of the protected conduct. Plaintiffs also make a cursory argument that “[t]he law is very clear that, ‘If the plaintiff has evidence from which one may reasonably infer that her former employer waited in the weeds for five or ten years and then retaliated against her for filing an EEOC charge, we see no difficulty with allowing the case to go forward.’” (Pls’ Br., Doc. 73, at 17, citing Veprinsky v. Fluor Daniel, Inc., 87 F.3d 881, 891 (7th Cir.1996)). Of course, Plaintiffs offer no such evidence here — only speculation. Further, the statement quoted from Veprinsky is dicta from a footnote in which the court discussed a potential outcome to a hypothetical factual scenario. Veprinsky, 87 F.3d at 891 n. 6. Plaintiffs cite no case in which a court has actually ruled in favor of a plaintiff in such a “waiting in the weeds” scenario, and this Court declines to do so here given the absence of evidence to support such a conclusion. D. Supplemental Facts and Analysis for Plaintiff Florez 1. Supplemental Facts During the six months following the complaint to HR in April 2007, Florez received another excellent performance review, another pay raise, and another PRIDE nomination. (Florez Resp., Doc. 71 at ¶¶ 37-39). After Giambone and Castro left the Chicago office in July 2007, Florez spoke with Dean Hierl about transferring out of the enrollment department to pursue an opportunity as an academic advisor outside the Chicago region. (Florez Dep., Doc. 74-3 at 84:6-21). Florez may have told Dean Hierl that he wanted to leave because Castro was not going to be there anymore. (Id. at 84:22-85:2). Hierl asked him to stay several times and was very positive about Florez. She said they needed him due to his numbers and could not make their starts without him. If he stayed, Hierl said she would make him a mentor and get him a manager position when he was ready. (Id. at 83:11— 20, 85:5-15). Florez decided to stay. At his mid-year 2007 review, Florez received an overall rating of “significantly exceeds standards.” (Def.’s Appx., Doc. 49-49). The review was approved by Dean Hierl and either Giambone or his successor, DA Berry. On the negative side, the review noted that Florez’s average applications per week still needed to improve, as did his volume of quality phone work. (Id.; Florez Resp., Doc. 71 at ¶ 37). In October 2007, Florez was nominated by one of his new supervisors, ADA Strauss, for a PRIDE award. (Florez Dep., Doc. 74-3 at 95:8-13; Florez Resp., Doc. 71 at ¶ 39). Not long after this, Florez and ADA Strauss had a “kind of a blowup with each other” (Florez’s words) which resulted in Strauss giving Florez some very low ratings on the subjective (or “TEACH”) assessment that month. (Florez Resp., Doc. 71 at ¶¶ 40-45, 52). Strauss reported what had happened to DA Berry, who called Florez a half-hour later and told him that his behavior was unacceptable and not to be repeated. She asked if she was clear and he said she was. (Florez Resp., Doc. 71 at ¶¶ 47-48 & Florez Dep., Doe. 74-3 at Exh. 15). While he did not say this to DA Berry during the call, Florez felt that Strauss was the one at fault. That night he prepared a lengthy written complaint about Strauss’s unprofessional behavior and gave it to HR Officer Hurt when he met with her the next day. (Florez Dep., Doc. 74-3 at 98:17-21; 99:11-19; Exh. 15). According to Florez’s complaint to HR, he left his office in the afternoon to escort a student to the financial aid office. ADA Strauss questioned why he needed to do this. Florez said he believed in customer service and could not afford to lose a student, to which Strauss responded: “Things are going to change around here, next time you point your student in the right direction, especially when you need to be on the phone during prime phone hours.” (Florez Dep., Doc. 74-3 at Exh. 15). Florez’s complaint then described how later that day ADA Strauss asked him to call her on a “three-way” in the other office so she could observe him conducting phone work. There was static on the line that interfered with the calls so he asked Strauss to come to his office and listen to his calls. She declined and told him to keep calling. (Id.). The static continued so Florez again politely asked if she would be willing to listen in Florez’s office. Strauss responded: “No you need to get another phone ... you don’t want me to go get it for you, do you?” (Id.). Florez then said he would get another phone and set it up. He did so but the static continued. At this point, Strauss said she would listen to him through the hallway with her door open. When Florez then left his office to get some water, the situation became more heated. He summarized what happened as follows: When I stepped out of my office Julie [Strauss] stated, “Where do you think your [sic] going?” I told her, “I am going to the refrigerator to get my water.” She stated, “You better make it quick.” So, I went back to my office and switched the cables to my original phone and continued to conduct phone work. Julie then comes in my office with her face as red as a cherry and says, “I think we have a fucking problem ... Do we have a problem, you slammed the door on me twice. As of today your TEACH values are zero,” while signaling with her hands a zero and leaves my office. When she was yelling at me franticly I was calm and stated, “I think there is a misunderstanding ...and continued to get cut off. I waited about 10 minutes [then] went to her office and knocked on her door. I went in and told her, “Julie, I really think there is a misunderstanding ...” She would not let me say a word, she then said, “Just get out of my office now, get out, get out. If you don’t get out right now, I’m going to hit you so hard you won’t even know what hit you.” I was calm and collective [sic] and then said, “Excuse me? Are you threatening me?” She then said, “Just get out of my office now!” (Florez Dep., Doc. 74-3 at Exh. 15). In his complaint to HR, Florez also described the reprimand that he received from DA Berry afterwards: Within a half hour Kathy Berry gave me a call with Julie on three-way, she said, “Don’t you ever disrespect one of my managers again and if I ever hear that you do there will be problems. If there is ever a problem again you take it and later you can discuss it with me. You are a PRIDE member and you are slamming doors and having temper tantrums. Never ever again, do I want to hear something like this again. Do you understand? Am I clear?” I just said, “Yes.” (Id.). Florez acknowledges that Berry’s reaction was appropriate based on Strauss’s report to her about what had happened. (Florez Resp., Doc. 71 at ¶ 48.) ADA Strauss later prepared her own (and different) written summary of what happened, stating that Florez had slammed doors, thrown phones and addressed her in a disrespectful and inappropriate manner. (Florez Dep., Doc. 74-3 at Exh. 16; Def.’s 56.1 Reply, Doc. 84 at ¶ 93). As it must at this juncture, the Court credits Florez’s version (although as discussed later, this has no bearing on the outcome of this motion). HR Officer Hurt investigated the incident but concluded that she could not corroborate the assertions of either Florez or Strauss. (Florez Resp., Doc. 71 at ¶ 51). As Florez remembered it, he and Strauss were told by HR to ignore what had happened and move on. (Florez Dep., Doc. 74-3 at 101:11-17). Former Advisor Mara Leal testified in her deposition that DA Berry asked her about the incident and Leal said Strauss was the one who had slammed the door, yelled, and created a disturbance. (Def.’s 56.1 Reply, Doc. 84 at ¶ 101; Leal Dep., Doc. 74-8 at 71:1-23). DA Berry told Leal that she could have her old office back if, in the event HR contacted her about the incident, Leal said she had not seen anything. Leal agreed, told HR she knew nothing, and got her old office back. (Def.’s 56.1 Reply, Doc. 84 at ¶ 101). As she had threatened during the blowup, Strauss gave Florez multiple ratings of zero on his subjective “TEACH” performance assessment in October 2007. (Florez Resp., Doc. 71 at ¶¶ 45-46, 52; Def.’s Appx., Doc. 49-51; Florez Dep., Doc. 74-3 at 120:6-13). She noted in the commentary, for example, that Florez “helps current applicants get into class but does not focus on helping prospective applicants and therefore many leads are less than worked because he does not put appropriate time into phone prospecting.” (Def.’s Appx., Doc. 49-51). In subsequent months, Florez’s TEACH scores improved but “they weren’t great like [he] had them before.” (Florez Dep., Doc. 49-11 at 133:1-7). On November 14, 2007, DA Berry sent Florez a memo stating that he missed his November 2007 start goal (achieving 5 starts on a target of 9), and that further unsatisfactory performance may result in disciplinary action, including termination. (Def.’s Appx., Doc. 49-52). When asked whether the memo about his failure to make his November starts was fair, Florez testified, “I guess you could say that.” (Florez Dep., Doc. 49-11 at 229:12 — 15). For the January 2008 class, Florez achieved his goal of 5 starts, though DA Berry and ADAs Strauss and Ramos initially tried to thwart him by saying that one of the students had to wait for the next class since the student had enrolled on the first day of the class. After Florez refused to back down and said he would go to DeVry’s president if necessary, his supervisors told him to go ahead with enrolling the student if he felt he could make it happen, and he thus met his goal. (Florez Dep., Doc. 74-3 at 127:1-17,128:9-18; Florez Resp., Doc. 71 at ¶¶ 55-56). On January 31, 2008, DA Berry scheduled a phone observation of Florez. During this session, Florez began to challenge the zeros that Strauss had given him on his TEACH assessment a few months earlier. (Florez Resp., Doc. 71 at ¶ 59). Afterwards, Berry sent a memo to HR Officer Hurt (copying Dean Hierl) that summarized what she described as Florez’s “45 minute diatribe”: During the time when we were supposed to be accomplishing a phone observation, Mike insisted on talking about his TEACH values from October, he was strident and yelling, there were threats about lawyers and complaints to the EEOC. He insisted that he could not focus and do his job because of the ratings he received on his TEACH. He successfully made his class goals for January and his behavior and TEACH ratings had improved in both November and December. He wanted a mediation or a transfer. I advised him that a transfer was not possible and that I didn’t know what he wanted me to mediate as the TEACH review had been done at the end of October and it was now the end of January. He continually rehashed an incident that had happened in October and that had been investigated by Human Resources at the time. I told him the incident was in the past and to focus on the present and future. I asked him what he was trying to accomplish or what he wanted, by having this conversation now. He had no answer. He brought up that he was put on probation, even though no “Caucasians” in the region had been. I asked how he knew that. He had no real answer. There were strong undertones of racism and lawsuits, and he even asked if I would like to talk to his lawyer and that he was recording all conversations in his office. His attitudes and behaviors are disruptive to the entire office. These events take up both my time, without accomplishing anything, and his time when he should be accomplishing his job. This was a 45 minute diatribe. He then did not want to do the phone session as he was upset. I told him that it needed to be accomplished because I had carved time out of my schedule to do this. I talked to him about moving forward and being successful in his position. We proceeded with the phone session. (Berry Dep., Doc. 74-10 at Exh. 4). Florez testified at his deposition that Berry’s summary of the discussion was “inaccurate” in certain ways but acknowledged that he complained to her about his TEACH values from October. He testified: “[M]y conversations with her were, basically, I had these zero TEACH values, they need to be changed.” (Florez Dep., Doc. 49-11 at 134:1-14). Florez denied yelling at Berry, noting: “Kathy Berry is a lady to be feared, seriously. So I never raised my voice at Kathy once.” (Id. at 133:14-20). Florez also denied making threats about lawyers or complaints or the EEOC. (Id. at 133:21-24). In the declaration that Florez submitted in opposition to summary judgment, he noted that the discussion with DA Berry lasted 5 to 10 minutes, not 45 minutes, before they returned to the phone session. (Florez Deck, Doc. 74-1, Tab C at ¶ 7). Shortly after this, Florez requested a transfer. (Florez Dep., Doc. 74-3 at 141:24-142:3). Again, this Court assumes for purposes of this motion that Florez’s version is accurate. After receiving the report from DA Berry about the “diatribe,” HR Officer Hurt sent an email on February 4, 2008 to HR Director Maher indicating that Florez’s supervisors wanted to discharge him and that she agreed with the decision. (Castro Deck, Doc. 74-1, Tab B at Exh. N). The email enumerated two specific problems: his inconsistent performance and his “volatile” behavior. The email then described the most recent “blow up” and his constant insubordination: His last “blow up” was with Kathy Berry last week. To refresh your memory, he is the employee who was going to Daniel Hamburger [President and CEO of DeVry Inc.] and Dave Pauldine [President of DeVry University and Executive VP of DeVry Inc.], because he did not feel he got resolution on the run-in he had with Julie Strauss a few months ago. He is also one of the people who complained about a previous supervisor (with Liz Castro). He is constantly insubordinate and challenging every decision his supervisor makes as racially motivated. Supervisors/managers feel that Mike’s negativity adversely impacts the team and would like to separate him at this time. His coming review will be “Meets Standards”. I agree with the supervisors. Let’s discuss when you have a moment. (Id.) On February 15, 2008, Hurt sent Maher a follow-up email, stating: I have reviewed his semi-annual performance review. Although he “Meets Standards”, I would like to move forward with separation. The totality of his review is that his performance is inconsistent, his inability to effectively follow the direction of his supervisors is a continuous problem and his refusal to accept management decisions will continue to impede his performance. While separating him is a risk, I feel comfortable that it is the right decision. (Castro Deck, Doc. 74-1, Tab B at Exh. O). DeVry terminated Florez about a week later, on February 21, 2008. (Florez Resp., Doc. 71 at ¶ 62). Although Maher believes she approved the termination decision, she has little recollection of it and, consistent with her general practice, did not generate any paperwork about her decision. (Def.’s 56.1 Reply, Doc. 84 at ¶ 109, citing Maher 20:18-21:19). On April 9, 2008, Florez filed a charge with the EEOC, alleging national origin discrimination .(arising out of Giambone’s offensive comments) and retaliatory discharge (for complaining about Giambone’s offensive comments)., (Florez Resp., Doc. 71 at ¶ 63; Def.’s Appx., Doc. 49-45). 2. Arguments Specific to the Termination of Florez a. Pretext: Florez argues that a jury could draw an inference of a causal nexus between the protected conduct and his termination because ADA Strauss and DA Berry twisted and exaggerated the facts related to their clashes with him. Thus he argues “[a] reasonable jury could conclude that given the level of dishonesty engaged in by Berry and Strauss, no defense based on an ‘honest belief will fly here.” (Pis’ Br., Doc. 73 at 26). There are several problems with this argument. First, Florez acknowledges that he and Strauss had a “kind of a blowup with each other” (Florez Resp., Doc. 71 at ¶¶ 40-45, 52), so is not claiming that Strauss feigned the altercation. Nor does he deny that he filed a written complaint against Strauss afterwards in which he accused her of unprofessional behavior. Further, Florez admits that, given how Strauss described the altercation to DA Berry (saying Florez was at fault), Berry acted appropriately in reprimanding him. Finally, Florez concedes that Berry was again unhappy with him three months later when, during a time set aside for her to observe Florez on the telephone, he rehashed the old TEACH ratings given by Strauss and insisted they be changed. In other words, Florez admits that he clashed with Strauss and Berry and that they were unhappy with him. What he quarrels with are the details concerning the clashes and, with respect to Strauss, who was at fault. Of course, the inquiry is not whether the employer’s reasons are accurate or fair but simply honestly believed. Coleman, 667 F.3d at 852. Given the undisputed facts here, Florez is unable to establish that Strauss and Berry did not honestly believe he deserved to be terminated based on his behavior towards them. Second, even if Florez were able to prove that DA Berry and ADA Strauss fabricated their reports concerning the altercations in order to create false reasons to terminate him, he still would need evidence linking their desire to terminate him to the protected conduct. In other words, he would need evidence that they fabricated their reports to cover up a retaliatory motive. See St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 516, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993) (to establish pretext, plaintiff must show both that the reason was false and that it was a pretext for an unlawful motive, not merely that it was false); King v. Preferred Tech. Grp., 166 F.3d 887, 893 (7th Cir.1999) (same); Hauge v. Equistar Chem. Co., No. 02 C 0878, 2002 WL 1968390, at *5 (N.D.Ill. Aug. 26, 2002) (even assuming the decision-maker “fabricated” the supposed reason for plaintiffs dismissal, “[t]o establish pretext, [the plaintiff] must attribute a retaliatory animus to ... the decision-maker”). Florez is unable to offer such evidence here. Instead, the evidence demonstrates that the decisionmakers neither knew nor cared about the protected conduct involving a prior supervisor almost a year earlier. In terms of their knowledge of the protected conduct, the only evidence that Florez is able to marshal are isolated statements Berry and Strauss made at one meeting with the Chicago staff in July 2007. Specifically, he notes Brooks’s testimony that DA Berry said to everyone: “[Djon’t go running off to HR, because I handle everything in-house. This is my team. Come see me.” (Brooks Dep., Doc. 49-8 at 107:16-108:1). Florez did not testify about such a statement though he too was at the meeting. He did, however, testify that Berry told the staff that she was “loyal” to Giambone, Dean Hierl, and another person. (Florez Dep., Doc 74-3 at 156:2-9). He also recalled Berry remarking that she was a tougher manager than Giambone and that things were going to change, and he felt she was tougher than Giambone. (Id. at 91:12-21). As for ADA Strauss, Florez testified that after the staff meeting, Strauss met with Florez and Brooks and told them: “‘Kathy Berry is different. Don’t go to HR. If you go to HR, the people that have went to HR no longer work here.’ ” (Id. at 148:19-149:5). Brooks did not testify about such a statement. At best such statements, if credited, would allow an inference that Berry and Strauss were generally aware that Florez and his co-plaintiffs complained in some manner about Giambone. There is no evidence, however, to suggest that Strauss or Berry became aware that they informed HR about offensive racial or ethnic remarks by Giambone. In fact, Plaintiffs never even inquired about this when deposing Strauss and Berry. Plaintiffs’ counsel merely asked whether and when they learned of the “complaint.” Strauss