Mondragon

FACTS AND PROCEDURAL BACKGROUND

I. Facts

Let’s Do Lunch, Inc. (defendant) provides “perishable prepared food for schools’ distributors, private-label, and retail customers in California and throughout the United States.” Raphael Mondragon (Mondragon) was hired as a forklift operator at defendant’s Los Angeles-based warehouse in November 2018. He was terminated less than six months later, in April 2019, for initiating an aggressive verbal confrontation with a co-worker.

All further statutory references are to the Code of Civil Procedure unless otherwise indicated.

II. Procedural Background

A. Complaint In September 2020, Mondragon sued defendant. In this lawsuit, Mondragon alleged that he was terminated in a “retaliatory fashion” for complaining about (1) defendant’s “safety practices” (namely, that his co-workers “improperly stacked pallets” in his loading area and “enter[ed] into the path of his forklift”) and (2) his “missing compensation” (namely, that defendant reduced his hours and did not pay him for the time he spent discussing his reduced hours at a human resources office). Based on these allegations, Mondragon asserted causes of action for (1)…