Shahid Rahmatullah v. Charter Communications, LLC

I. Background

On December 18, 2019 Plaintiff filed a putative class action complaint against Defendant in San Bernardino County Superior Court, bringing the following claims: (1) violation of the California Labor Code §§ 201 and 202 (waiting time penalties); (2) violation of California Labor Code § 2802 (unreimbursed business expenses); and (3) violation of the California Business and Professions Code. See Complaint, Dkt. # 1-1 (“Compl.”). Plaintiff seeks to represent a class of “all current and former employees who worked for any of the Defendants within the state of California at any time during the period from four years preceding the filing of this Compliant [sic] until final judgment.” See id. ¶ 7. Plaintiff alleges that Defendant failed to provide putative class members with their final wages immediately upon termination or within seventy-two hours of voluntarily leaving employment, and members of the class were required to use their home internet access and personal automobile, and Defendant did not fully reimburse class members for these expenses. See id. ¶¶ 16 17. Plaintiff seeks the wages of each class member no longer employed by Defendant at their regular rate…