Jaiyeola

I. BACKGROUND

1 A. Factual Background 2 Jaiyeola worked for Apple as a Senior Subject Matter Expert from February 21, 2022, until 3 his termination on August 8, 2023. FAC ¶¶ 2, 5–6. Jaiyeola’s claims arise out of his interactions 4 with the following Apple employees. 5 Shiva Mandepudi 6 Shiva Mandepudi was a senior Apple manager during Jaiyeola’s employment. Id. ¶ 11. In 7 Jaiyeola’s initial video meeting with Mandepudi, Mandepudi allegedly told Jaiyeola that Jaiyeola 8 “couldn’t do the job,” that Mandepudi “didn’t want a lazy person,” and that Jaiyeola should 9 decline the offer. Id. Jaiyeola also alleges that at some point in 2022, Mandepudi “scolded” 10 Jaiyeola in a one-on-one meeting and during a presentation. Id. ¶ 32. Jaiyeola further alleges that 11 Mandepudi told Rolling1 that Rolling “was hired because he is White,” and willfully delayed the 12 permanent resident application for Afolabi,2 who Jaiyeola alleges is Black and Nigerian. Id. 13 Jaiyeola filed a “discrimination complaint” against Mandepudi “based on what he did and 14 said on January 2022 and after January 2022.” Id. ¶ 11. The results of the investigation are 15 currently unknown to Jaiyeola. …