Kincheloe

I. BACKGROUND

1 Defendant operates a commercial airline with ongoing business within this District and 2 Division. Am. Compl. ¶ 14. ECF 35. Defendant employs thousands of flight attendants who 3 perform “same primary job duties of providing information, guidance, and assistance for safety 4 and comfort to airline passengers and conducting safety checks.” Id. ¶¶ 15–16. In March 2020, 5 Defendant offered a Voluntary Early Out Program (“VEOP”) to its older flight attendants as 6 consideration in exchange for their agreement to early retirement “to motivate people who really 7 were close to retiring” to retire. Id. ¶ 17–19. The March 2020 offer required flight attendants 8 have at least 10 years of seniority, and only flight attendants older than 40 were eligible due to 9 Defendant’s prior hiring freeze and minimum hiring age requirement. Id. ¶ 20. Defendant was 10 allegedly aware of the resultant age delineation. Id. 11 Defendant allegedly provided no truly voluntary choice to its older flight attendants on 12 whether to accept the March 2020 offer. Id. ¶ 21–23. Defendant allegedly pressured its older 13 flight attendants to accept the March 2020 offer through various…