Ronald Sanders v. Exide Technologies
Opinion
Trial Court Opinion
I. Background
Plaintiff worked as a non-exempt truck driver at Exide from approximately October 2013 until March 2019. See Complaint, Dkt. # 1-2 (“Compl.”), ¶ 18; Declaration of Galit Knotz, Dkt. #14-1 (“Knotz Decl.”), ¶ 4. On June 24, 2019, Plaintiff filed this wage and hour putative class action in Riverside County Superior Court. See generally Compl. In the complaint, Plaintiff asserts causes of action against Defendant for (1) unpaid overtime wages, id. ¶¶ 43–51; (2) unpaid meal period premiums, id. ¶¶ 52–62; (3) unpaid rest period premiums and paid rest breaks, id. ¶¶ 63–73; (4) failure to pay minimum wages, id. ¶¶ 74–78; (5) failure to timely pay final wages, id. ¶¶ 79–84; (6) non-compliant wage statements, id. ¶¶ 85–91; (7) failure to reimburse business expenses, id. ¶¶ 92–95; and (8) unfair business practices, id. ¶¶ 96–102. On behalf of his proposed classes, Plaintiff seeks compensatory damages, liquidated damages for unpaid wages, restitution, penalties, injunctive relief, and attorneys’ fees and costs. Id. Prayer for Relief ¶¶ 1–49. 1 Plaintiff seeks to represent “all current and former California-based . . . individuals employed