Martray Reese v. Daikin Comfort Technologies Distribution, Inc.

I. BACKGROUND

Plaintiff is a citizen of California and Defendant is a citizen of Texas. See Compl. (Dkt. No. 1-1) 1-2. Defendant engages in the HVAC distribution business. Jd. § 3. Plaintiff began working as a warehouse associate for Defendant in approximately April 2023. Jd. 4 11. Plaintiff earned $19.00 per hour and worked approximately 40 hours per week. See id. § 11; Mot. at 13. On July 5, 2023, Plaintiff was using a box cutter when the box cutter fell and pierced his knee. Id. {

CV-90 (12/02) CIVIL MINUTES — GENERAL Initials of Deputy Clerk CB

12. Plaintiff informed his manager, who sent him to urgent care, and Plaintiff returned to work that same day. Id. After the incident, Plaintiff began receiving regular disciplinary write-ups, including formal write-ups related to his knee injury and using an unapproved box cutter, tardiness, and forklift operation. See id. ¶¶ 13- 16. On July 21, 2023, Plaintiff was terminated for too many write-ups. See id. ¶ 17. Plaintiff alleges that he “was left embarrassed, ashamed, emotionally hurt, and in financial desperation for having been directly discriminated and retaliated against for having a…