them to see." Id. In response, Walsh allegedly stated that withholding information from KPMG would constitute fraud and he would not be a party to it. Id. That same month, plaintiff's allege that Walsh informed Chiasson that he believed Levi's reported net income was overstated as a result of Levi's improper release of excess reserves and improper recognition of unrealizable foreign tax credits as deferred tax assets. Id. ¶ 188. As a result, Walsh was "effectively frozen" out of his role on the leadership team and management of the global tax department. On December 10, 2002 Walsh's employment was terminated "for cause." Id. ¶ 189.
2. Robert Schmidt
Schmidt worked in Levi's global tax department from June 18, 2001 to December 10, 2002 as senior manager for international tax untilthese transactions resulted in improper tax deductions between 1986 and *973 1994.[9] According to plaintiff's' allegations, after informing Liang and Fong that he believed these documents should be produced to the IRS, Schmidt was directed by Liang and Fong to withhold them, and that same day he was replaced as the primary IRS contact by Jim Fuller of the Fenwick & West law firm ("Fenwick"). CAC ¶ 195. Plaintiff's allege that boxes of materials brought back from Brazil were withheld from the IRS. Id. ¶ 196. On December 10, 2002 Schmidt's employment with Levi was terminated "for cause." Id. ¶ 197.
3. Confidential Witnesses
CW1 worked for Levi from the summer of 2002 to early 2003 as a manager of internal reporting. Id. ¶ 199. CW1 reported directly to Caroline