14.  Plaintiff is employed by Essex as a Community Manager in charge of one of  Essex’s multifamily properties called Highlands at Wynhaven located in Issaquah, Washington.   She is certified as an Accredited Residential Manager.     15.  As a condition of her offer of employment from Essex, Plaintiff, along with every  other Essex employee, was required to provide personal identifying information including her  52.  Plaintiff brings this action on her own behalf, as well as on behalf of all other  similarly situated individuals.  PORTLAND, OR 97204  b. That Plaintiff be appointed as representative of the Class members;  c. That counsel for Plaintiff be appointed as Class Counsel;  d. A finding that Essex breached its duty to safeguard and protect the PII of Plaintiff and  Class members that was compromised in the Data Breach;  e. For damages, and all other appropriate legal and equitable relief;  f. For appropriate injunctive and declaratory relief;  g. For an award of pre-judgment and post-judgment interest;  h. For reasonable attorneys’ fees and costs; and  i. For such further relief as this Court may deem just and proper.   