Sotoodeh

I. BACKGROUND AND PROCEDURAL HISTORY1

1 The following facts are undisputed.2 Sotoodeh started working for Wells Fargo in 1990 as 2 a bank teller. He worked his way up and received multiple promotions, including a promotion in 3 2006 to Regional President for Southern California, in which he was responsible for oversight of 4 approximately 120 bank branches. Sotoodeh Decl. ¶ 2-4. In 2009, he made a lateral move to 5 manage the Greater Los Angeles markets. His region expanded over time and he was promoted to 6 Regional Bank Executive in 2014, “responsible for branch banking and business banking for the 7 Southwest region.” Id. at ¶ 4. He held that position until early 2017. Id. at ¶ 5. 8 Mary Mack became the head of Wells Fargo’s Community Bank in fall 2016. Mack Dep. 9 70. Mack subsequently reorganized the Community Bank, reducing the number of her direct 10 reports from three to two. One of Mack’s two direct reports was Lisa Stevens. Id. at 63, 74. In 11 April 2017, Stevens appointed Sotoodeh as Lead Regional President of the Mountain Midwest 12 Region. Sotoodeh Decl. ¶ 5; Mack Dep. 62-63, 73-76. 13 The Los Angeles Times published an article in 2013 regarding…