Gammon

BACKGROUND

20 Plaintiff Stuart Gammon (“Gammon”) is a mixed race male, over 40 years old, who suffers 21 from Attention Deficit Disorder. (Compl. ¶ 12.) He has worked as an SES.2 Chemist at LLNS 22 since July 14, 1998 and alleges that he performed well and received positive performance reviews. 23 (Id. ¶¶ 13, 15.) Gammon alleges that as a federal contractor LLNS “receives directions through 24 NNSA and DOE.” (Id. ¶ 14.) Some of Gammon’s work involves national security related 25 activities, and he alleges that has a security clearance approved by DOE. (Id. ¶¶ 14, 16.)

Secretary Wright is automatically substituted in pursuant to Federal Rule of Civil Procedure 25(d). On March 13, 2024, Gammon filed a complaint with the California Civil Rights Department (“CCRD”) alleging harassment based on sex/gender, age, disability, and race, discrimination based on sex/gender, age, and disability, and retaliation. (Id. ¶ 11; LLNS Req. for Judicial Notice, Ex. A.) Gammon received a right to sue letter that same day. (Compl. ¶ 11.) Based on allegations discussed in more detail below, Gammon asserts claims against the Federal Defendants…