Junkersfeld

I. BACKGROUND

24 A. Procedural History 25 Defendant Medical Staffing Solutions, Inc. (“Defendant”) is a staffing company that 26 employs hourly healthcare workers on short-term travel assignments at medical facilities 27 throughout California and elsewhere. (ECF No. 48-1 at 5.) Plaintiff was employed by Defendant in Oakdale, California between January 2016, and April 2016. (Id.) Plaintiff filed her complaint commencing this action on February 19, 2019. (ECF No. 1.) Plaintiff alleges that Defendant underpaid overtime by excluding the value of housing and meals payments and incidentals payments from workers’ regular rates of pay. (See id.) The complaint asserts claims for: 1) failure to pay overtime wages pursuant to California Labor Code §§ 510, 5 1194; 2) unfair business practices pursuant to California Business & Professions Code §§ 6 17200, et seq.; 3) waiting time penalties pursuant to California Labor Code § 203; and 4) 7 violation of the Fair Labor Standards Act pursuant to 29 US.C. §§ 201, et seq. (Id.) Defendant 8 filed an answer on May 3, 2019. (ECF No. 5.) 9 In December of 2019, following formal and informal discovery, the parties reached a 10…