Jennifer Favela v. Lowe's Home Centers, Inc.

I. INTRODUCTION AND BACKGROUND

On December 4, 2024, Plaintiff Jennifer Favela (“Plaintiff”) filed a Complaint in Los Angeles County Superior Court, raising disability discrimination and employment retaliation claims under state law (“Complaint”). (Compl., ECF No. 4, at 10–231.) On January 6, 2025, Defendant Lowes Home Centers, Inc. (“Defendant”) filed its Answer in the Superior Court (ECF No. 4, at 41–46) and a Notice of Removal in this Court (“Removal Notice”), the latter supported by Declarations of Grace Ridley (“Ridely Declaration”) and Nichole Browning (Removal Not., ECF No. 1; Ridley Decl, ECF No. 3; ECF No. 4). On January 27, 2025, Plaintiff filed the instant Motion to Remand (“Motion”), which included a Declaration of Alixandra M. Powers and Request for Judicial Notice. (Mot., ECF No. 17; ECF No. 18.) On February 19, 2025, Defendant filed an Opposition to the Motion (“Opposition”), which included a Declaration of Nichole T. Browning and a Request for Judicial Notice. (Opp’n, ECF No. 20-1–20-2.) On February 26, 2025, Plaintiff filed a Reply to the Opposition (“Reply”). (Reply, ECF No. 21.) The Motion is fully briefed. The Court deems the Motion appropriate for…