Katrina Wright v. Q Squared Solutions LLC

I. Background

Plaintiff initiated this action in Orange County Superior Court on February 7, 2023. (Dkt. 1-2 (“Compl.”).) Plaintiff alleges she was employed by Defendant IQVIA and Defendant Q Squared in April 2021 and worked in that role until her wrongful termination in December 2021. (Id. ¶ 14.) Plaintiff alleges she was an employee with a disability under the Fair Employment and Housing Act (“FEHA”), Cal. Gov. Code §§ 12900 et seq. during this time. (Id. ¶ 15.) Plaintiff’s disabilities included anxiety and an injured right hand, right wrist, shoulder, and bicep. (Id. ¶¶ 15, 17.) Plaintiff asserts Defendants harassed Plaintiff in a severe and pervasive basis because of her disabilities. (Id. ¶ 18.)

In summary, Plaintiff alleges the following incidents occurred during her employment:

• On or around September 29, 2021, a forklift was placed in an unsafe area with no warning cones around to prevent an accident. (Id.) Plaintiff was working a midnight shift when she attempted to open a container of dry ice. (Id.) Plaintiff’s foot got stuck underneath the forklift and she had no way of getting out. (Id.) She fell forward and sustained serious injuries. (Id.) The…