Caya Rodriguez v. Raising Cane's USA, L.L.C.

I. FACTUAL AND PROCEDURAL BACKGROUND

According to the Complaint, Plaintiff was a non-exempt employee of Defendants in the State of California from approximately December of 2021 to May of 2022. Complaint ¶ 2. On August 26, 2022, Plaintiff, on behalf of herself and all persons similarly situated, filed a Complaint against Defendants in Los Angeles Superior Court, alleging the following claims for relief: (1) failure to pay overtime wages (Labor Code § 510); (2) failure to pay minimum wages (Labor Code § 1197); (3) failure to provide meal periods (Labor Code § 512); (4) failure to provide rest periods (Labor Code § 226.7); (5) waiting time penalties for failure to timely pay wages upon termination (Labor Code §§ 201-203; (6) failure to provide accurate wage statements (Labor Code § 226(a)); (7) failure to timely pay wages during employment (Labor Code § 204); (8) failure to reimburse necessary business expenses (Labor Code § 2802); and (9) unfair competition in violation of California’s Unfair Competition Law (“UCL”) (Business & Professions Code § 17200 et seq.). On November 14, 2022, Defendants removed this action, alleging that this Court has jurisdiction pursuant to 28…