Alberto Vasquez v. Impact Fulfillment Services, LLC

I. BACKGROUND

On February 28, 2024, Plaintiff, individually and on behalf of similarly situated individuals, filed a putative class action complaint in the Superior Court of the County of Riverside against Defendant Impact Fulfillment Services, LLC (“IFS” or “Defendant”) and Does 1 through 10. (“Complaint,” Dkt. No. 1-2, Ex. A.) On May 9, 2024, Defendant answered the Complaint. (“Answer to Complaint,” Dkt. No. 1-2, Ex. E.) On August 13, 2024, Plaintiff filed a first amended complaint. (“FAC,” Dkt. No. 1-2, Ex. H.) On September 12, 2024, Defendant answered the FAC. (“Answer to FAC,” Dkt. No. 1-2, Ex. I.)

On October 8, 2024, Defendant removed the action pursuant to the Class Action Fairness Act of 2005 (“CAFA”), 28 U.S.C. § 1332(d), and 28 U.S.C. §§ 1441, 1446, and 1453. (“NOR,” Dkt. No. 1.) In support of its NOR, Defendant filed the declarations of Vice President of IFS’ Human Resources Department Angela Mendes (“Mendes Decl.,” Dkt. No. 1-1) and attorney Matthew Scholl (“Scholl Decl.,” Dkt. No. 1-2). The FAC alleges nine causes of action under the California Labor Code and California Business and Professions Code: (1) failure to pay minimum and straight time wages, Cal.…