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.”

CDW Q&A: CDW-G Asked 7 Questions; Long Answered Them All Under Oath

Case No. 2025L007458·Filed July 16, 2026·Cook County Circuit Court, Law Division

In discovery, each side puts written questions to the other and must answer under oath. These are CDW Government LLC's interrogatories and Plaintiff's sworn answers in Long v. CDW Government LLC, Cook County No. 2025L007458, served across two supplemental filings under Illinois Supreme Court Rule 213(i) and presented here as a question-and-answer record.

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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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