Chasmine Shaw v. Kaiser Foundation Health Plan, Inc.

I. BACKGROUND

On May 12, 2021, Ms. Shaw filed a class action complaint in the Superior Court of the State of California for the County of Riverside against Defendant Kaiser Foundation Health Plan (“Defendant” or “Kaiser”). (Dkt. No. 1-1, ¶ 2.) She did not serve the first complaint on Kaiser. (Id.) On August 8, 2021, Ms. Shaw filed an amended complaint. (“FAC,” Dkt. 1-1, Ex. 1.) The FAC alleges ten causes of action: (1) failure to pay overtime in violation of Cal. Labor Code §§ 510, 1194, and 1198; (2) failure to pay wages for all hours worked in violation of Cal. Labor Code §§ 1194, 1197, 1197.1, and 558; (3) failure to provide meal periods or proper premiums in violation of Cal. Labor Code §§ 226.7 and 512; (4) failure to provide rest periods in violation of Cal. Labor Code §§ 226.7 and 512; (5) failure to provide accurate itemized wage statements; (6) failure to pay wages due; (7) failure to reimburse business expenses; (8) failure to pay wages upon termination of employment; (9) unlawful competition and unlawful business practices under California’s Unfair Competition Law Bus. & Prof. Code § 17200 et seq.; and (10) violation of Page 1 of CIVIL MINUTES—GENERAL…