Mark Henry Shanks v. Vertex Aerospace LLC

I. Factual Background

Plaintiff is an aircraft mechanic who worked for Defendant Vertex between June 2013 and May 2017. During his employment, Plaintiff was subjected to unlawful labor practices and racial harassment, which he reported to Defendants. Dkt. 1-1 (Compl.) ¶¶ 11-13. In July 2015,

1 Plaintiff has identified the Defendant as “L-3 Communications Vertex Aerospace LLC.” Vertex clarifies in its Notice of Removal that its correct corporate identity is “Vertex Aerospace LLC.” 2 Sichenzia and Bantilan are collectively referred to as Individual Defendants. after complaining that he had been racially harassed by a coworker, Plaintiff received a written warning from Defendants “for not having his Air Frame & Power Plant (A&P) license.” Id. ¶¶ 13-15. Plaintiff complained to the Individual Defendants that that he “was previously instructed that he did not need an A&P license” and had worked for Vertex for “almost a decade without the license.” Id. ¶¶ 17-18. Defendants subsequently “told [Plaintiff] that the A&P license was not required and the issue was dropped.” Id. ¶ 18. In January 2016, Plaintiff was diagnosed with bladder cancer. Id. ¶ 19. He underwent a biopsy for…