Karina Nunez v. Keurig Dr Pepper Inc.

I.

BACKGROUND

On November 29, 2018, Plaintiff initiated this lawsuit in San Bernardino County Superior Court against Defendant KDP alleging causes of action for (1) Retaliation (Labor Code § 1102.5); (2) Wrongful Termination in Violation of Public Policy; (3) Sexual Harassment (Gov. Code § 12940(j)); and (4) Failure to Prevent Sexual Harassment (Gov. Code §12940(k)). ECF Docket No. (“Dkt.”) 4-1. On January 2, 2019, defendant KDP removed the action to this Court. Dkt. 1.

On January 22, 2019, defendant KDP propounded initial written discovery on Plaintiff. Dkt. 31-1 at 3-5, Declaration of Amber L. Roller (“Roller Decl.”), ¶ 2. On February 20, 2019, Plaintiff served verified responses to Defendant KDP. Id. In her responses to Interrogatories Nos. 16 and 17, Plaintiff states she is seeking approximately $61,022.00 in past and future lost wages and $200,000.00 in emotional distress damages. Id., Ex. 1. On March 15, 2019, Plaintiff filed a First Amended Complaint (“FAC”) against both Defendants alleging the same causes of action. Dkt. 16. Plaintiff alleges she was unlawfully terminated by Defendants from her employment for reporting sexual harassment. Id., ¶¶ 10-25.…