Patricia Saavedra v. LA-Z-Boy, Inc.

I. Background

A. Factual Background The following facts are taken from Plaintiff’s complaint. On or about December 1, 2015, La-Z-Boy employed Plaintiff as a Human Resources Manager at its manufacturing plant in Redlands, California. See Complaint, Dkt. # 1-1 (“Compl.”) ¶ 10. Plaintiff was fifty-eight when she was hired. Id. ¶ 11. Pineda was the General Manager of the Redlands plant. Id. ¶ 12. Pineda made comments to Plaintiff about her age and about the inability of older employees to keep up with workload demands. Id. ¶ 13. From 2016 through 2019, Plaintiff worked with Pineda to hire new employees to fill open positions at the Redlands plant, and Pineda continually stressed the need for a “younger bench,” “younger talent,” and “fresh talent.” Id. ¶ 14. Pineda routinely asked Plaintiff to estimate applicants’ ages before offering them interviews. Id. Pineda explicitly instructed Plaintiff against hiring older employees. Id. Plaintiff routinely presented Pineda with older well-qualified applicants, only to have Pineda hire younger, less- qualified candidates instead. Id. Throughout 2018, Pineda actively replaced numerous Redlands plant management staff members…