Zachary Gurzenski v. Delta Air Lines, Inc.

I. BACKGROUND

26 Plaintiff was employed by Defendant as a non-exempt Ramp Agent, and seeks 27 to represent a class of all current and former Ramp Agents at any of Defendant’s 28 locations at Los Angeles International Airport (“LAX”) during the class period. See Compl. ¶¶ 6, 14. According to Plaintiff, Defendant violated California labor law because it “routinely required [Class Members] to purchase and use their own mandatory personal protective equipment, mandatory safety equipment and tools, and personal cell phone data and minutes as a direct consequence of the discharge of their employment duties.” Id. ¶ 14. Defendant did not compensate Class Members for this equipment. The equipment Class Members purchased for themselves consisted of protective steel-toed boots, safety vests, earmuffs, marshaling wands, and knee pads. Id. ¶¶ 15, 19. Defendant also required Class Members to use their personal cell phones for work purposes and did not compensate them for this. Id. ¶¶ 22-23. Based on these allegations, the Complaint alleges the following three (3) causes of action: (1) Failure to Indemnify Employees for Necessary Expenditures…