Alina Manukyan v. KinderCare Education at Work LLC

I. BACKGROUND

19 On July 7, 2020, Plaintiff filed her Complaint in the California Superior 20 Court, Los Angeles County, asserting employment discrimination claims 21 related to her alleged wrongful termination. (See Dkt. 3-1, ¶ 5 “Complaint”). 22 Plaintiff brings claims for: (1) Discrimination (Gov’t Code §§12940); (2) 23 Failure to Prevent Discrimination (Gov’t Code §§ 12940(k)); (3) Failure to 24 Provide Reasonable Accommodation (Gov’t Code §§ 12940); (4) Failure to 25 Engage in a Good Faith Interactive Process (Gov’t Code §§ 12940); (5) 26 1 Declaratory Judgment; (6) Failure to Pay Wages (Labor Code §§ 201, 226.7, 512); (7) Failure to Provide Meal and Rest Periods (Labor Code §§ 201, 512); and (8) Unfair Competition (Business and Professions Code § 17200). (Id.). 5 On July 9, 2020, Defendant KinderCare Education at Work, LLC (“Defendant” or “KinderCare”) removed the case to this Court. (Dkt. 1). According to Defendant, the amount in controversy is satisfied because “[w]hile working at KinderCare in 2018, Plaintiff’s gross pay was approximately $29,421 … [and] Plaintiff also seeks $1,050.00 in Labor Code §558 penalties and $15,855.84 to…