Identify and describe in specific detail each and every act of retaliatory conduct you allege was committed by Defendant as set forth in Paragraph 9 of your complaint, including but not limited to: hostility, animosity, and other treatment adverse to your employment and professional standing and identify the date, time, location and persons involved in such acts and what was done or said by each person present.

On January 18, 2024, Plaintiff filed a formal internal complaint that both complained of the goal-modifier wage reductions and formally requested, as its second enumerated request for relief: “Transfer to a new sales team that does not employ the goal modifier in the compensation plan.” Defendant thereafter admitted, in its position statement submitted to the Illinois Department of Labor, both that Plaintiff made this request and that Defendant denied it: “CDWG also admits that Claimant requested that he be moved to a new sales team that does not have a goal modifier as part of the compensation plan and that CDWG declined the request since there had been no violation of policy or inappropriate treatment by Claimant’s leadership team.”

Plaintiff's Second Supplemental Answers to Interrogatories

Case No. 2025L007458·Filed September 23, 2026·Cook County Circuit Court, Law Division

Exhibit A to Plaintiff's Response in Opposition to Defendant's Motion for Extension of Time to Answer Plaintiff's Fifth Amended Complaint, Long v. CDW Government LLC, Cook County No. 2025L007458. Plaintiff's Second Supplemental Answers to Interrogatories, served under Illinois Supreme Court Rule 213(i) and verified under 735 ILCS 5/1-109, reproduced in its as-filed form bearing the Clerk's file stamp; previously of record as Exhibit 3 to Plaintiff's Third Amended Motion to Compel Responses to Requests to Admit.

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Part of the public record in Long v. CDW Government LLC, Case No. 2025L007458. Released to the public domain under CC0 1.0 Universal.

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