Bannon

I. BACKGROUND

25 On May 24, 2024, Plaintiff on behalf of himself individually and others similarly 26 situated, initiated a wage and hour class action lawsuit against Defendant in the Superior 27 Court of California, San Diego County. ECF No. 1-4. The complaint alleged that Plaintiff 28 worked for Defendant in California as a station operator, a non-exempt employee, from about August 2018 to July 2023. Id. at ¶ 11. Defendant is a Delaware limited liability company that maintains operations and conducts business throughout the state of California. Id. at ¶ 12. The complaint alleged that Defendant paid employees on an hourly basis and repeatedly underpaid Plaintiff and class members and failed to keep accurate records. Id. at ¶¶ 21-22. Based on this course of conduct, Plaintiff alleges causes of action for: (1) minimum wage violations; (2) failure to pay all overtime wages; (3) meal period violations; (4) rest period violations; (5) paid sick leave violations; (6) untimely payment of wages; (7) wage statement violations; (8) waiting time penalties; (9) failure to reimburse business expenses; (10) violation of California Business and…