Henry Corlew v. Superior Duct Fabrication, Inc.

I. BACKGROUND

On April 18, 2022, Plaintiff filed this action in the Los Angeles County Superior Court on his own behalf and on behalf of “[a]ll current and former hourly-paid or non- exempt 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 and who reside in California.” (Compl. ¶ 13, Doc. 1-1.) Plaintiff’s Complaint alleges ten causes of action against Defendant: (1) California Labor Code §§ 510 and 1198 violations (unpaid overtime); (2) California Labor Code §§ 226.7 and 512(a) violations (unpaid meal period premiums); (3) California Labor Code § 226.7 violations (unpaid rest period premiums); (4) California Labor Code §§ 1194, 1197, and 1197.1 violations (unpaid minimum wages); (5) California Labor Code §§ 201 and 202 violations (final wages not timely paid); (6) California Labor Code § 204 violations (wages not timely paid during employment); (7) California Labor Code § 226(a) violations (non-compliant wage statements); (8) California Labor Code § 1174(d) violations (failure to keep requisite payroll records); (9) California Labor Code §§ 2800…