Christopher Haro v. Target Corporation

I. BACKGROUND

On February 3, 2025, Plaintiff Haro, individually and on behalf of similarly situated individuals, filed a putative class action complaint in the Superior Court of the County of Riverside against defendants Target Corporation (“Target” or “Defendant”), Eato Tanaka, and Does 1 through 100 (collectively, “Defendants”). (“Complaint,” Dkt. No. 1-1.) On March 3, 2025, Plaintiffs filed a first amended complaint against Defendants. (“FAC,” Dkt. No. 1-4.)

On April 3, 2025, Target 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 and 1446. (“NOR,” Dkt. No. 1.) In support of its NOR, Target filed the declarations of attorney Alberto Corona (“Corona NOR Decl.,” Dkt. No. 1-7) and Defendant’s expert Holly Brackin, a principal in the Labor & Employment practice of Charles River Associates (“Brackin Decl.,” Dkt. No. 1-8).

The FAC alleges nine causes of action under the California Labor Code and California Business and Professions Code: (1) failure to pay overtime fees, Cal. Lab. Code §§ 1194 and 1199; (2) failure to pay minimum wages, Cal. Lab. Code §§ 218.6 and 1194; (3) failure to provide meal…