Navarro

I. BACKGROUND

25 Plaintiff is a Hispanic American female of Mexican descent, and a citizen of the 26 United States of America. (Complaint ¶ 2). She is a resident of Imperial County, in the 27 State of California. (Id.) At the time she filed her complaint, Plaintiff was employed as a 28 Group Supervisor, GS-1811-14, with Immigration and Customs Enforcement (ICE), Department of Homeland Security (DHS). (Comp. ¶ 3). DHS is a cabinet department of the U.S. federal government, tasked with anti-terrorism, border security, immigration and customs, cyber security, and disaster prevention and management. (Comp. ¶4). Plaintiff has been employed with ICE for more than 20 years. (Comp. ¶8). During her employment, Plaintiff has received commendations and distinctions including fourteen (14) special act awards for merit and job performance between 1999 through 2016, which included an award for outstanding performance as a Special Agent within ICE, and the JTF-1 Directors Award for Distinguished Service in July 2016. (Comp. ¶11 ((i),(k),(m)). Plaintiff created and supervised multiple programs including the first child Exploitation 11 …