response. The Court will therefore consider the reply in conjunction with this motion. 15 . In so holding, the Tenth Circuit aligned with the First Circuit and the Ninth Circuit, which have held that First Amendment retaliation adverse employment actions are subject to a lower standard than Title VII claims. See Rivera-Jimenez v. Pierluisi, 362 F.3d 87, 94 (1st Cir.2004)("[T]he standard for showing an adverse employment action is lower in the First Amendment retaliation context than it is in other contexts (such as Title VII).”); Coszalter v. City of Salem, 320 F.3d 968, 975 (9th Cir.2003)("To constitute an adverse employment action, a government act of retaliation need not be severe and it need not be of a certain kind.”). See also Morris v. Lindau, 196 F.3d 102, 110 (2d Cir.1999)(<HOLDING>) The Eleventh Circuit, on the other hand,
holding that adverse employment effects include but are not limited to such discrete actions as discharge demotion or reduction in pay holding that lesser actions than discharge refusal to hire refusal to promote demotion reduction in pay and reprimand may also be considered adverse employment actions in the first amendment retaliation context recognizing retaliation involving promotion as adverse employment actions under the first amendment recognizing that a set of actions may constitute an adverse employment action when considered collectively even though some actions do not rise to the level of an adverse employment action individually holding in the context of a first amendment retaliation claim that adverse employment actions may include negative evaluation letters