Maria Guijarro v. Healthcare Services Group, Inc.

I. BACKGROUND

24 On December 10, 2019, Plaintiff Guijarro (“Plaintiff”) filed her initial 25 complaint against Defendants Healthcare Services Group, Inc., HCSG West 26 1 LLC, and Yolocare Inc., dba Terracina Post Acute (together, “Defendants”) in San Bernardino Superior Court, alleging violations of various California Labor Codes. (See generally “Compl.,” Dkt. 1-1, Ex. B). 4 In the Complaint, Plaintiff identifies as the putative class “[a]ll current and former non-exempt employees of Defendants who worked at any of Defendants’ locations in the State of California at any time within the period beginning four (4) years prior to the filing of the this [sic] action, and ending at the time this action settles or proceeds to final judgment.” (Compl. ¶ 5). Plaintiff alleges in the Complaint that Defendants engaged in various unlawful practices, including (1) failure to provide meal periods, (2) failure to provide rest periods, (3) failure to pay overtime wages, (4) failure to pay minimum wages, (5) failure to timely pay wages during employment, (6) failure to pay all wages due at termination, (7) failure to maintain payroll records,…