Frederick-Osborn

BACKGROUND

20 A. Complaint Allegations 21 Plaintiff worked as a staff software engineer at Twitter from June 2022 until November 22 2022. (Dkt. No. 1 ¶ 9.) She is a resident of San Francisco, California and in her late 50s. (Id. ¶¶ 23 9, 34.) Plaintiff’s performance “met the Company’s expectations” throughout her employment 24 with Twitter. (Id. ¶ 9.) 25 26 27 In late October 2022, Elon Musk purchased Twitter. (Dkt. No. 1 ¶ 20.) Following the purchase in early November 2022, Musk immediately began a mass layoff through a Reduction in Force (“RIF”) that affected more than half of Twitter’s workforce “under extremely hurried circumstances.” (Id. ¶¶ 20-22.) Data show the RIF disproportionately affected women and employees aged 50 and over. (Id. ¶¶ 24-25.) After the initial layoffs in November 2022, Musk implemented several policies (the “Post- RIF Policies”), including expecting employees to “work an unreasonable number of hours” and requiring employees to immediately return to work in physical offices, even though Twitter had allowed remote work throughout the pandemic and even before that. (Dkt. No. 1 ¶ 27.) Since …