John Doe v. Wells Fargo Bank, N.A.

I. Background

A. Introduction Plaintiff John Doe (“Plaintiff”) asserts state-law violations of the California Fair Employment and Housing Act (“FEHA”), California Government Code §§ 12900 et seq., against Defendants Wells Fargo Bank, N.A. (“Wells Fargo”), Joe Fillippelli (“Fillippelli”), and Does 1- 10 (collectively, “Defendants”) for: (1) sexual harassment; (2) retaliation for Plaintiff’s opposition to Defendants’ alleged FEHA violations; and (3) failure to prevent sexual harassment and retaliation. See generally Plaintiff’s Complaint (“Complaint”), Docket No. 1, Ex. A. Plaintiff also asserts a common-law claim for intentional infliction of emotional distress (“IIED”). See id. B. Factual Background Plaintiff alleges the following relevant facts: In approximately 2007, Plaintiff – a citizen of California – began working as a loan officer for Wells Fargo – a citizen of South Dakota. See id. ¶ 8; see also Defendants’ Notice of Removal of Action to United States District Court Pursuant to 28 U.S.C. §§ 1332(a) and 1441 (Diversity) (“Notice of Removal”), Docket No. 1, at 7-8. In 2010, Wells Fargo – recognizing Plaintiff as a strong performer – promoted…