Linda Davis v. Bright Horizons Children's Centers LLC

I. Factual and Procedural Background

On December 16, 2020, Plaintiff filed a Complaint against Defendants in Los Angeles Superior Court, alleging causes of action for: (1) violation of California Labor Code §§ 510 and 1198 (unpaid overtime); (2) violation of California Labor Code §§ 226.7 and 512(a) (unpaid meal period premiums); (3) violation of California Labor Code § 226.7 (unpaid rest period premiums); (4) violation of California Labor Code §§ 1194, 1197, and 1197.1 (unpaid minimum wages); (5) violation of California Labor Code §§ 201 and 202 (final wages not timely paid); (6) violation of California Labor Code § 204 (wages not timely paid during employment); (7) violation of California Labor Code § 226(a) (non-compliant wage statements); (8) violation of California Labor Code § 1174(d) (failure to keep requisite payroll records); (9) violation of California Labor Code §§ 2800 and 2802 (unreimbursed business expenses); and (10) violation of California Business & Professions Code §§ 17200, et seq. Plaintiff was an hourly, non-exempt employee of Defendants from approximately May 2015 to May 2020. Declaration of Elisa Nadeau, Ex. A (Complaint ¶ 18), (Docket No. 1-1), 12:4-6.…