Geoffrey Kinzel v. RLS-CMC, Inc.

I. BACKGROUND

On April 13, 2021, Mr. Kinzel filed a putative class action in the Superior Court of California for the County of Riverside against Defendants RLS-CMC, Inc. (“RLS-CMC”) and Does 1 through 20, asserting wage and hour claims under California law. (“Complaint,” Dkt. No. 1-1.) On August 19, 2021, Mr. Kinzel filed a first amended complaint against RLS-CMC to assert claims under the Private Attorneys General Act (“PAGA”). (“FAC,” Dkt. No. 1-3.) On March 18, 2022, Mr. Kinzel filed amendments to the FAC, naming Roger Lee Sanchez and Jasmine Bormann as Does 11 and 12, respectively. (“Amendments to FAC,” Dkt. Nos. 1-4, 1-5.) On April 8, 2022, Defendants RLS-CMC, Mr. Sanchez, and Ms. Bormann (collectively, “Defendants”) removed the action. (“Notice of Removal,” Dkt. No. 1.) On May 9, 2022, Mr. Kinzel filed the instant Motion. (See Mot.) In support, he filed the declaration of Peter Carlson. (“Carlson Declaration,” Dkt. No. 7-1.) Page 1 of CIVIL MINUTES—GENERAL Initials of Deputy Clerk MG Case 5:22-cv-00602-JGB-SP Document Filed 06/07/ Page 2 of Page ID #:222

Defendants opposed on May 16, 2022. (Dkt. No. 9.) In support, they filed the…