“The only two documented complaints against De La Cruz are dated February 8, the day she was demoted.  Although not incriminating evidence, the suspicious timing of these documents, taken with reasonable inferences in favor of De La Cruz’s claim that they were fabricated, could support a finding of discriminatory motive.”

De La Cruz v. Coastal Bend Reg’l Court Residential Treatment Ctr., 2:12-CV-355, 2013 WL 5744796 at *5 (S.D. Tex. Oct. 21, 2013) (Hinojosa, J.).