in the protected activity; (3) the defendant took adverse action against the plaintiff; and (4) a causal connection existed between the plaintiffs protected activity and the adverse action taken by the defendant. Gordon v. N.Y.C. Bd. of Educ., 232 F.3d 111, 116 (2d Cir.2000) (citing Cosgrove v. Sears, Roebuck & Co. 9 F.3d 1033, 1039 (2d Cir.1993)). As in the case of a discrimination claim under Title VII or the ADA, once the plaintiff establishes a prima facie case, the defendant must provide a legitimate, non-retaliatory reason for the adverse action. After that, the plaintiff must show that the reason is pretextual. Zann Kwan v. Andalex Grp. LLC, 737 F.3d 834, 844-846 (2d Cir.2013); Univ. of Tex. Sw. Med. Ctr. v. Nassar, — U.S. —, 133 S.Ct. 2517, 2534, 186 L.Ed.2d 503 (2013) (<HOLDING>). The Court analyzes ADA retaliation claims
holding that the mixedmotive framework does not apply to retaliation cases under title vii holding that a plaintiff can prove illegal retaliation under   1981 in the same manner as he establishes retaliation under title vii holding the title vii mixedmotive theory does not apply to adea claims holding that in title vii cases the mixedmotive theory of discrimination is available in cases with circumstantial evidence of discrimination holding that title vii does not mention much less require that a plaintiff make a heightened showing through direct evidence in mixedmotive cases