Jessica Montoya v. Sights on Service, Inc.

I. FACTUAL ALLEGATIONS AND NOTICE OF REMOVAL

A. Montoya’s Complaint

Plaintiff Jessica Montoya is a California citizen who previously worked for Defendant Sights on Service, Inc. d/b/a Secret Shopper (“Sights”). (FAC ¶¶ 5, 6, 13.) According to the FAC, “SECRET SHOPPER is an app-based secret shopper company. Workers use the app to accept secret shopping tasks for set rates. The worker then performs the task, writes a report, and submits it via the app.” (Id. ¶ 10.) The crux of the FAC are the allegations that: ____________________________________________________________________________

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 8:19-cv-02334-JLS-SHK Date: February 04, 2020 Title: Jessica Montoya et al v. Sights on Service, Inc. et al. i) SECRET SHOPPER willfully misclassifies its secret shoppers as independent contractors to deprive them of fundamental employment rights, such as the right to minimum wages, the right to overtime, the right to mandated meal breaks, the right to mandated rest breaks, the right to premium wages for missed meal and rest breaks, the right to accurate itemized wage statements,…