Joseph Smith, on behalf of himself and all other current and former nonexempt employees, and the general public v. MV Transportation, Inc., a California Corporation; MV Public Transportation, Inc., a California Corporation; and DOES 1 through 50, inclusive

I. Background

Smith was employed as a bus driver by MV Transportation, Inc. from approximately April 1, 2023 through August 1, 2024. Dkt. 1-2 (Compl.) ¶ 8-9. Smith was an hourly employee. Id. ¶ 8. He was a member of the Amalgamated Transit Union, Local 1575, AFL-CIO (the Union) and the terms and conditions of his employment were covered by a collective bargaining agreement (CBA) between MV Transportation, Inc. and the Union. Dkt. 1-1, Ex. A. Smith alleges he performed off-the-clock work, before and after his shift, for which he was not paid. Compl. ¶¶ 9-13. He states he was required to report to the facility, retrieve schedules, and complete pre-trip inspections before his shift. Id. ¶ 9-10. He estimates unpaid, pre-trip duties could take 15 to 30 minutes each day. Id. at 10. Smith also estimates he performed five to ten minutes of unpaid work after clocking out, including uploading bus schedules and timesheets. Id. ¶¶ 11-13. He alleges he was not provided with uninterrupted meal periods of at least 30 minutes for each five hours worked, nor was he provided with rest periods of 10 minutes for each four-hour work period. Id. ¶¶ 14-17. Smith also alleges he was not…