Browden

FACTS AND PROCEDURAL BACKGROUND

I. Browden’s Complaint

On May 14, 2024, Browden, on behalf of himself, all others similarly situated, and the general public, filed a complaint alleging various individual and nonindividual PAGA claims against CJ Berry and Does 1 through 50, for Labor Code violations (PAGA action). Browden alleges he was a nonexempt employee of CJ Berry from approximately August 19, 2022, to June 8, 2023. He alleges CJ Berry violated his and other employees’ rights under the Labor Code by (1) failing to compensate them for (a) time spent donning uniforms and required safety equipment, (b) time spent waiting in line to clock in for work, (c) work performed at CJ Berry’s insistence after they had clocked out from work, and (d) overtime work at the proper overtime hourly rate; (2) failing to provide them with required meal and rest breaks; (3) maintaining policies that resulted in an unlawful forfeiture of their vested vacation pay; (4) failing to reimburse them for work-related expenses; and (5) failing to provide them with wage statements that accurately reflect all hours worked, gross and net wages earned, and applicable hourly rates for work performed.…