Juan C. Gamarra v. ADT, LLC

I. Background

On July 2, 2020, Plaintiff filed a Complaint in the Superior Court for the County of Los Angeles against Defendants ADT LLC and Does 1 through 100 (“Defendants”). (Dkt. 3.) In the Complaint, Plaintiff alleges that he was hired as a technician for ADT. (Id. ¶ 11.) During his time of employment, Plaintiff was denied rest and meal periods required by California law. (Id. ¶¶ 13–16.) Plaintiff also alleges that he sustained a work-related injury in 2019 and was thereafter terminated from his employment. (Id. ¶¶ 18, 21.) Plaintiff contends that his termination was improperly based on his disability and age. (Id. ¶¶ 22–23.) ADT removed the action to this Court on November 13, 2020 on the basis of diversity jurisdiction, 28 U.S.C. § 1332. (Dkt. 1.) In its Notice of Removal, ADT states that Plaintiff is a California resident, ADT is a limited liability company with a sole member that is a Delaware corporation with a principal place of business in Florida, and Plaintiff alleges damages likely to exceed $75,000. (See id. ¶¶ 1, 2, 11.) Plaintiff now brings the instant Motion. Plaintiff contends that ADT has not met its burden of demonstrating complete diversity…