Stephen Cartwright v. Envoy Air Inc.

I. INTRODUCTION

On April 1, 2021, Plaintiff Stephen Cartwright (“Plaintiff”), on behalf of all other similarly situated employees in the State of California, filed a Complaint in state court against Defendant Envoy Air, Inc. (“Envoy”). Plaintiff’s claims arise from alleged wage and hour violations committed by Envoy during Plaintiff’s employment with Envoy. Plaintiff asserts the following claims under the California Labor Code, the Los Angeles Living Wage Ordinance (“LWO”), and the Industrial Welfare Commission (“IWC”) Wage Orders: (1) failure to provide meal periods; (2) failure to provide rest periods; (3) failure to pay minimum and regular wages; (4) failure to indemnify all necessary expenditures; (5) unlawful deductions from wages; (6) failure to provide accurate itemized wage statements; (7) failure to timely pay all wages due upon separation of employment; and (8) violation of Business & Professions Code § 17200, et seq. On June 14, 2021, Plaintiff filed a First Amended Complaint. On June 21, 2021, Envoy removed this action to federal court based on diversity jurisdiction under the Class Action Fairness Act (“CAFA”). On July 23, 2021, Plaintiff filed the current Motion…