Lauren Millstein v. County of Los Angeles

I. Background

A. Factual Background1 3 This case involves alleged violations of the Fair Labor Standards Act (“FLSA”). For two 4 years, Plaintiff Lauren Millstein (“Millstein”) was employed by the Defendant County of Los 5 Angeles (the “County”) as a non-exempt, hourly employee at the North County Correctional Facility 6 (“NCCF”). First Amended Complaint (“FAC”), ECF No. 24, ¶ 12. NCCF is a jail facility owned 7 and operated by the County. Id. ¶ 6. 8 Millstein was formally required to work eight-hour days, six days a week,2 with shifts 9 starting at 6:00 a.m. and ending at 2:00 p.m. Id. ¶¶ 12–13. However, in practice, Millstein was 10 required to work more than ten hours a day and did not receive pay for all hours worked. Id. ¶ 13. 11 She was required to perform work-related tasks such as retrieving security keys and conducting 12 security checks one hour before her 6:00 a.m. start time. Id. ¶ 13. The County also did not pay 13 Millstein for work performed during allotted rest breaks and meal breaks. Id. ¶¶ 13–15. Millstein’s 14 last day of work was on May 27, 2019. Id. ¶ 12. 15 Millstein asserts a claim for failure to pay straight time and overtime…