Luis Maria Heredia v. Target Corporation et al.

I. FACTUAL AND LEGAL BACKGROUND

Plaintiff Luisa Maria Heredia worked as a Fulfillment Worker for Defendant Target Corporation (“Target”) beginning on April 24, 2024. [Dkt. No. 1-2 at 4, “Complaint”]. In her position as a Fulfillment Worker, Plaintiff was responsible for “organizing and preparing batches of products throughout the Defendant’s store in San Bernardino County, California.” [Id.]. Around July 2024, Anthony Aranda began serving as team lead in supervising Plaintiff’s employment. [Id.]. The Complaint alleges that around August of 2024, Aranda became critical of Plaintiff’s work and “would constantly call Plaintiff . . . more than other employees” and spoke to Plaintiff “in a disrespectful tone and patronized her work Page 1 of CIVIL MINUTES—GENERAL Initials of Deputy Clerk iv throughout the store.” [Complaint at 4]. At times, when Plaintiff would seek Aranda’s assistance to fulfill her job duties, Aranda “would refuse to assist [Plaintiff]” and would “[become] upset at Plaintiff for asking a coworker for help.” [Id.]. Aranda ultimately reported Plaintiff to Casper Graviac, a Human Resources Representative. [Id.]. Plaintiff spoke with Graviac and told him…