Saad Badrh v. Amazon.com, Inc.

I. BACKGROUND

Badrh is a resident of California and was employed by Defendants in California until August 2021. Dkt. 13 (FAC) ¶¶ 1, 42. Badrh is Muslim of Arab descent. Id. ¶ 21. Defendant Amazon.com, Inc. is a Delaware corporation with its principal place of business in Washington. Dkt. 3 (Stephens Decl.), Ex. B. The sole member of Defendant Amazon.com Services LLC is Amazon.com Sales, Inc., a Delaware corporation with its principal place of business in Washington. Dkt. 1 (Removal); Stephens Dec., Ex. C. Badrh alleges that during his employment, Defendants failed to provide him with state required breaks at the times required by law. FAC ¶ 43. Additionally, on or around March 16, 2021, Defendants’ Operations Manager, Rachel (now identified as Rachel Cerda), terminated Badrh’s employment without providing a reason and within eight days of his return from sick time and the Fair Employment and Housing Act (FEHA) accommodation of a medical leave. Id. ¶¶ 8-9; MTA at 4. Despite Badrh’s several attempts to lodge complaints with Defendants, Badrh alleges there was no adequate investigation or remediation. FAC ¶¶ 11-15. After several weeks, Badrh emailed Defendants’ Chief…