Mark Richard Keck v. Unifirst Corporation

I. BACKGROUND

On March 26, 2025, plaintiff Mark Richard Keck (“Plaintiff”) filed a complaint against defendants Unifirst Corporation (“Unifirst”), Daniel Como (“Como”), and Does 1-20 (Collectively, “Defendants”) in the Superior Court of the State of California, County of San Bernadino. (“Complaint,” Dkt. No. 1-2.) The Complaint alleges six causes of action: (1) failure to pay wages, (2) waiting time penalties, (3) failure to provide accurate itemized wage statements, (4) retaliation, (5) unfair and unlawful business practices, (6) and wrongful termination. (Id.) (Id.) Defendants filed an answer on May 15, 2025. (Dkt. No. 1-5.)

On May 16, 2025, Defendants filed a notice of removal pursuant to diversity jurisdiction. (“Notice of Removal,” Dkt. No. 1.) On June 19, 2025, Plaintiff filed the Motion. (See Motion.) In support of the Motion, Plaintiff filed the declaration of attorney Gavril T. Gabriel. (“Gabriel Decl.,” Dkt. No. 13-1.) Defendants opposed the Motion on July 21, 2025. (“Opposition,” Dkt. No. 15.) In support of the Opposition, Defendants filed the declaration of attorney Sue J. Noh (“Noh Decl.,” Dkt. No. 15-1) and Defendant Como. (“Como Decl.,” Dkt. No.…