Pedro Murillo v. Target Corporation

I. BACKGROUND

On January 31, 2023, Plaintiffs filed a putative class action complaint against Target and Does 1-10 in the Superior Court of the State of California for the County of Los Angeles. (“Notice of Removal,” Dkt. No. 1.) On April 21, 2023, Target removed the action pursuant to the Class Action Fairness Act (“CAFA”). (Id.) In support of the Notice of Removal, Defendants filed declarations of Michael Brewer (“Brewer Declaration,” Dkt. No. 3), Paul F. White (“White Declaration,” Dkt. No. 4) and Anna M. Skaggs (“Skaggs Declaration,” Dkt. No. 5.) Plaintiffs’ complaint alleges six causes of action: (1) failure to pay minimum and straight time wages in violation of Cal. Lab. Code §§ 204, 1194, 1194.2 and 1197; (2) failure to pay overtime wages in violation of Cal. Lab. Code §§ 1194 and 1198; (3) failure to timely pay final wages at termination in violation of Cal. Lab. Code §§ 201-203; (4) failure to provide accurate itemized wage statements in violation of Cal. Lab. Code § 226; (5) failure to indemnify employees for expenditures in violation of Cal. Lab. Code § 2802; and (6) unfair business practices in violation of Cal. Bus. & Prof. Code §§ 17200 et seq. (“Complaint,”…