Travin Baker v. Propak Logistics, Inc.

I. BACKGROUND

On April 30, 2019, Plaintiff Travin Baker (“Plaintiff”) filed this putative class action complaint against Defendants Propak Logistics, Inc. (“Defendant”) and Does 1 through 100 (collectively, “Defendants”) in the Superior Court for the County of San Bernardino. (“Complaint,” Dkt. No. 1–4.) Plaintiff brings this action on behalf of himself and “[a]ll current and former hourly-paid employees who worked for any of the Defendants within the State of California at any time during the period from four years preceding the filing of this Complaint to final judgment.” (Complaint ¶ 13.) The Complaint advances multiple claims under California law: (1) unpaid overtime; (2) unpaid meal period premiums; (3) unpaid rest period premiums; (4) unpaid minimum wages; (5) final wages not timely paid; (6) wages not timely paid during employment; (7) non-compliant wage statements; (8) failure to keep requisite payroll records; (9) unreimbursed business expenses; and (10) violation of the California Business and Professions Code, §§ 17200, et seq. (Complaint ¶¶ 47–117.) Plaintiff asserts Defendant employed him as an hourly-paid, non-exempt employee from approximately December 2017…