Samanatha Shaunee Brown v. Western First Aid & Safety

I. INTRODUCTION

On June 20, 2024, plaintiff Samantha Shaunee Brown (“plaintiff”) filed suit in Los Angeles Superior Court against defendants Western First Aid & Safety, Vestis Corporation, Vestis Group, Inc., Katie Hall, and Does 1 through 50 (collectively “defendants”).! Dkt. 1-1. On July 24, 2024, defendants removed the case to federal court on the basis of Class Action Fairness Act (“CAFA”) jurisdiction. Dkt. 1 (“Notice of Removal’). On August 12, 2024, plaintiff filed her first amended complaint naming the same defendants and asserting nine claims for relief: (1) Failure to Pay Minimum Wages (Cal. Lab. Code §§ 204, 1185, 1194, 1194(a), 1194.2, 1197, 1197.1, 558); (2) Failure to Pay Wages and Overtime (Cal. Lab. Code §§ 204, 510, 558, 1194); (3) Meal Period Liability (Cal. Lab. Code § 226.7; IWC Wage Order §] 11); (4) Rest-Break Liability (Cal. Lab. Code § 226.7; IWC Wage Order 12): (5) Failure to Pay Vacation Wages (Cal. Lab.

Defendants request judicial notice of its Foreign Limited Liability (LLC) Name Change Amendment filed with the California Secretary of State on December 27, 2023, attaching its Certificate of Amendment changing the name of Aramark…