Jesus Estrada Pelagio v. Modern Floor Specialists, et al.

I. BACKGROUND

On May 15, 2025, Plaintiff filed a Complaint against corporate Defendants Modern Floor Specialists. Inc., Clean Solution Experts. Inc., and individual defendants Martha Arciniega, Joseph Branch, Alicio Mendoza Galeno, and Erica Perez (collectively “Defendants”), in the Superior Court of California, County of Los Angeles. [Dkt. 1, Ex. A]. The Complaint alleges sixteen causes of action that Plaintiff asserts all arise solely under California law. Id.

1 The Complaint, as originally filed, contained the following claims: (1) discrimination on the basis of disability in violation of the Fair Employment and Housing Act (FEHA); (2) retaliation in violation of FEHA; (3) failure to accommodate in violation of FEHA; (4) failure to engage in the interactive process in violation of FEHA; (5) failure to prevent discrimination and retaliation in violation of FEHA; (6) interference with California Family Rights Act (CFRA) rights; (7) retaliation under CFRA; (8) wrongful termination in violation of public policy; (9) intentional Plaintiff has worked as a janitor for corporate Defendants on a full-time, hourly basis since November 2, 2018. Complaint ¶¶ 2, 6, 26. During…