Rebecca Arnett v. Traditions Health LLC

I. BACKGROUND

On October 2, 2023, Plaintiff, individually and on behalf of similarly situated individuals, filed a putative class action complaint in the Riverside County Superior Court against defendants Traditions Health LLC (“Defendant”), Mary Brackett, and Does 1 through 100. (“Complaint,” Dkt. No. 1-2, Ex. A.) On November 13, 2023, Defendant removed the action pursuant to the Class Action Fairness Act of 2005, (“CAFA”). (“NOR,” Dkt. No. 1.) In support of its NOR, Defendant filed the declarations of Crystal Mineo Diaz (“Diaz”) (“Diaz Declaration,” Dkt. No. 1-1), and the Romtin Parvaresh (“Parvaresh”) (“Parvaresh Decl.” Dkt. No. 1-2).

The Complaint alleges ten causes of action: (1) failure to pay overtime wages; (2) failure to pay minimum wages; (3) failure to provide meal periods; (4) failure to provide rest periods; (5) waiting time penalties; (6) wage statement violations; (7) failure to timely pay wages; (8) failure to indemnify; (9) violations of California Labor Code section 227.3; and (10) unfair competition. (See Complaint.) On December 14, 2023, Plaintiff filed this Motion. (Motion.) In support, Plaintiff filed: (1) evidentiary objections to evidence submitted…