Moises Ross v. Tata Consultancy Services Ltd

BACKGROUND

On December 28, 2023, plaintiff filed a putative class action in state court against Tata Consultancy Services Limited (“defendant”), asserting claims for violations of the California Labor Code and California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200, et seq. (See Dkt. 1, Notice of Removal (“NOR”) at ¶ 1); (Dkt. 1-3, Complaint). Plaintiff alleges, among other things, that defendant “at times, failed to play Plaintiff and the Class, or some of them, for all hours worked, including minimum, straight time, and overtime wages[,]” and that defendant “would, at times, manufacture time keeping records to falsely show that plaintiff and the Class took meal periods when in fact they worked ‘off-the-clock’, uncompensated.” (Dkt. 1-3, Complaint at ¶ 15); (id. at ¶¶ 34). Plaintiff also alleges that defendant failed to provide legally compliant meal and rest breaks to plaintiff and the Class “or some of them” (id. at ¶¶ 16-17), and willfully failed to “timely pay Plaintiff and the Class, or some of them, all final wages due at their termination of employment.” (Id. at ¶ 18). Plaintiff seeks to represent a class comprised of “[a]ll persons who worked…