Yvonne Hernandez v. The Elevance Health Companies, Inc.

I. BACKGROUND

On January 11, 2023, Hernandez commenced this action against Defendants The Elevance Health Companies, Inc. (“Elevance”) and Leslie Soloki, in the Ventura County Superior Court. (See Notice of Removal at 2, Ex. 3 (“Complaint”) (Docket No. 1-1)). The Complaint includes the following allegations: Hernandez is a resident of Ventura County, California. (Complaint ¶ 1). Defendant Elevance is a corporation organized under the laws of, and with its principal place of business in, Indiana. (Id. ¶ 2). On information and belief, Defendant Soloki is a resident of Ventura County. (Id. ¶ 3). Hernandez worked for Elevance as a services specialist for about 25 years (from December 1997 until her termination in August 2022). (Id. ¶ 8). In 2019, Hernandez’s daughter suffered a major stroke soon after giving birth. (Id. ¶ 11). Hernandez lives in the same house as her daughter and granddaughter. (Id.) Consequently, Hernandez needed time off to care for her daughter. (Id. ¶¶ 13-16). Soloki, Hernandez’s direct supervisor at Elevance, almost always “negatively responded” to Hernandez’s requests for time off and did not express any compassion for the situations with her…