In Mauze v. CBS Corporation, 15-CV-4905, 2018 WL 5115564 (E.D.N.Y., 2018), the court, inter alia, denied defendant’s motion for summary judgment as to her retaliation claims.
In reaching this conclusion, the court explained:
[Plaintiff] has … established a sufficient causal connection between her engagement in protected activity and her termination. See Gordon v. NYC Bd. of Educ., 232 F.3d 111, 117 (2d Cir. 2000) (causation can be shown by either: “1) indirectly[ ] showing that the protected activity was followed closely by discriminatory treatment, or through other circumstantial evidence such as disparate treatment of fellow employees who engaged in similar conduct; or 2) directly[ ] [presenting] evidence of retaliatory animus against plaintiff by defendant.”) (citations omitted); see also Hicks v. Baines, 593 F.3d 159, 164, 170 (2d Cir. 2010). In this case, the time between the “events that precipitated the adverse action[ ]”—Mauze’s complaints to her supervisors in the summer and fall of 2013, and her EEOC complaint submitted in December 2013—and “the adverse action[ ] itself”—Mauze’s termination in early April 2014—is sufficient to make out a prima facie showing of causation through temporal proximity.