Sanguinetti

I. BACKGROUND

Sanguinetti was hired as a territory sales representative for Forest in 1998. Her duties included calling upon hospitals and pharmacies within her territory to promote Forest’s products. Generating sales was the most important goal in Sanguinetti’s position with Forest. Toups became her division manager and direct supervisor in 2004 and was responsible for periodically riding with Sanguinetti and preparing evaluations of her performance in the field. These evaluations were quantified on a scale of 1 to 5, with 3.0 considered to be the minimum standard performance. Sales representatives also received midyear and annual reviews. From 1998 to mid-2008, Sanguinetti consistently received performance evaluations above 3.0. Sanguinetti had her first child in 2003, and took maternity leave in 2005 to have twins. In fiscal year 2006 (covering April 1, 2005 to March 30, 2006), she ranked 82d in sales among Forest’s 104 hospital sales representatives, and in fiscal year 2007, she ranked 24th. Sanguinetti’s May 2008 performance review (fiscal year 2008 annual review) gave her a 3.43 rating. However, for the nine months ending in December 2007 of that fiscal year, she ranked No.…