For the purposes of the motion before the Court, the Court accepts as true the well-pled allegations in Plaintiff's Second Amended Complaint. The Court does "not accept as true, however, the plaintiff's legal conclusions or inferences that are unsupported by the facts alleged." Ralls Corp. v. Comm. on Foreign Inv. In the U.S., 758 F.3d 296, 315 (D.C. Cir. 2014).
Plaintiff Linda Sims is an African American black female veteran who was at least 40 years old during the times relevant to her complaint. Sec. Am. Compl., ECF No 21-2, ¶ 1. From May 2006 to October, 1 2016, Plaintiff worked as a specialty markets salesperson and an institutional salesperson for Defendant Sunovion Pharmaceuticals, Inc. Id. As a sales representative, Plaintiff was assigned responsibility for sales and promotions to medical professionals in designated territories including the District of Columbia and Maryland. Id. at ¶ 7.
From May 2006 to 2009, Plaintiff alleges that she reached her employment goals and quotas and regularly received ratings of "At Expectations" and "Exceeds Expectations." Id. at ¶ 8. However, in 2009, Livia Warden, a white female, became Plaintiff's supervisor. Id. at ¶ 9. Plaintiff alleges that Ms. Warden singled out Plaintiff and subjected her to discriminatory and harassing behavior on the basis of her age, sex, race, and veteran status.