Mark Clemons v. Element Materials Technology Huntington Beach LLC
Opinion
Trial Court Opinion
I.
FACTUAL AND PROCEDURAL BACKGROUND
On September 13, 2021, Plaintiff filed a class action complaint in Los Angeles County Superior Court against Element HB. Notice of Removal (“NOR”), Ex. B [Doc. # 1-2]. On September 15, 2021, Plaintiff filed the operative First Amended Complaint (“FAC”), asserting various wage-and-hour violations on behalf of the following proposed class:
All California citizens currently or formerly employed as non-exempt employees by Defendants in the State of California within four years prior to the filing of this action to the date of class certification.
And the following proposed subclass:
All members of the Class who separated their employment from Defendants in the State of California within four years prior to the filing of this action to the date of class certification.
NOR, Ex. A ¶¶ 19-20 [Doc. # 1-1]. CV- CIVIL MINUTES—GENERAL Initials of Deputy Clerk KTI Case 2:21-cv-08581-DMG-E Document Filed 04/22/ Page 2 of Page ID #:435
UNITED STATES DISTRICT COURT JS-6 / REMAND
CENTRAL DISTRICT OF CALIFORNIA
CIVIL MINUTES—GENERAL
Case No. CV 21-8581-DMG (Ex) Date April 22, 2022