Eliud Ramirez v. Quad Graphics, Inc.

I. BACKGROUND

On November 17, 2022, Plaintiff filed a complaint against Defendants Quad Graphics, Inc. (“Quad”), QG Printing II, LLC (“QG”) (collectively, “Corporate Defendants”), Rafael Alvarez (“Mr. Alvarez”), Angelo Ortiz (“Mr. Ortiz”) (collectively, “Individual Defendants”), and Does 1-100 in the Superior Court of the State of California, County of Riverside. (“Notice of Removal,” Dkt. No. 1, Ex. A, “Complaint”). The Complaint asserts 18 causes of action under California law: (1) Wrongful Termination in Violation of Public Policy; (2) Retaliation; (3) Employment Discrimination Based on Disability/Medical Condition; (4) Employment Discrimination Based Upon Age; (5) Hostile Work Environment and Harassment in the Work Place; (6) Intentional Infliction of Emotional Distress (“IIED”); (7) Failure to Accommodate Disability; (8) Failure to Engage in the Interactive Process; (9) Negligent Supervision and Retention; (10) Failure to Pay Overtime; (11) Failure to Pay Meal Period Compensation; (12) Failure to Pay Rest Period Compensation; (13) Failure to Pay Wages in a Timely Manner; (14) Failure to Pay Earned Wages; (15) Failure to Pay Wages Due; (16) Waiting Time Penalties; (17)…