Lupe Rodriguez v. Caliber Holdings Corporation

I. INTRODUCTION

On March 15, 2021 Plaintiffs Lupe Rodriguez and Arthur Bebekyan (“Plaintiffs”) filed a class action Complaint in state court against Defendants Caliber Holdings Corporation (“Caliber”) and Caliber Bodyworks, Inc. (“CB”) (collectively, “Defendants’’). Plaintiffs’ claims arise from alleged wage and hour violations committed by Defendants during the course of their employment. Plaintiffs seek to represent themselves and all others similarly situated through this class action. Plaintiffs assert the following claims under the California Labor Code: (1) Failure to Authorize or Permit Meal Periods, (2) Failure to Authorize or Permit Rest Periods, (3) Failure to Timely Pay Earned Wages During Employment, (4) Failure to Provide Complete and Accurate Wage Statements, (5) Failure to Timely Pay All Earned Wages and Final Paychecks Due at Time of Separation of Employment. Plaintiffs also assert a sixth claim for Unfair Business Practices in Violation of Business and Professions Code § 17200 et seq. On April 19, 2021, Defendants removed this action to federal court on the basis of subject matter jurisdiction under the Class Action Fairness Act (“CAFA”). On May 7, 2021…