Sengrath

FACTS

Employer is a California corporation once named “Kertel Communications, Inc.” Pursuant to an agreement, Kertel Communications, Inc. merged with and into Audeamus, which was the surviving corporation. The merger was effective on June 30, 2019. Employer is a subsidiary of Sebastian Enterprises, Inc., a California corporation (Parent Company). The declaration of defendant Rita Garcia, Employer’s human resources manager since 2019, states that Employer and Parent Company (1) share the same facilities, website, e-mail address, phone number, and employees; (2) use the same vehicles, tools, and equipment; (3) operate as one under the name Sebastian, a registered fictitious business name; and (4) are managed and controlled by the same persons. The statements of information filed with the California Secretary of State by Employer and Parent Company in 2020 show that both corporations have the same chief executive officer (William Barcus), the same secretary (Susan Moran), and the same chief financial officer (Stephanie Hannah). In addition, Ruth Barcus, Brian Barcus, Susan Moran, and Chris Moran are listed as directors of both corporations. Two of Employer’s directors—Dave Archer…