Dominique Daniels v. G4S Secure Solutions USA, Inc.

I. BACKGROUND

On July 21, 2021, Plaintiff filed a complaint against Defendant G4S Secure Solutions USA, Inc., in the Superior Court of California for the County of Orange. (“Complaint,” Dkt. No. 1-3.) The Complaint alleges five causes of actions: (1) discrimination on the basis of disability in violation of the California Fair Employment and Housing Act (“FEHA”), Cal. Gov’t Code § 12940, et seq.; (2) failure to provide reasonable accommodation in violation of FEHA; (3) failure to engage in a good faith interactive process in violation of FEHA; (4) retaliation in request to a request for accommodation in violation of FEHA; and (5) wrongful termination and constructive discharge in violation of public policy. The matter was referred to the Honorable John D. Early and the Honorable Josephine L. Stanton. (Dkt. No. 6.) On September 1, 2021, the matter was transferred to Judge Early and the Honorable Jesus G. Bernal. (Dkt. No. 15.)

On August 19, 2021 Defendant filed its notice of removal. (“Notice of Removal,” Dkt. No. 1.) Plaintiff filed the Motion on September 2, 2021. Defendant filed a late opposition on September 15, 2021. (“Opposition,” Dkt. No. 19.) Plaintiff replied…