Gunderson

I. BACKGROUND

22 Plaintiffs present the following facts in support of their Motion, which are undisputed 23 given Defendant’s failure to file an opposition. Defendant operated a facility at 545 Oakmead 24 Parkway in Sunnyvale, California until about October 21, 2019, when the facility was closed. See 25 ECF No. 48 (“Answer”) ¶ 5. Immediately prior to the closure, Defendant laid off nearly all of its 26 approximately 260 employees on October 15, 2019, without any prior written notice, stating to 27 them at an all-hands meeting that there was no more funding for payroll and that they should go home and not return to work until further notice. ECF No. 61-1 (“Olsen Decl.”) Ex. 2, ¶¶ 3-4, 8. Those employees were never recalled. Id. ¶ 3. At the time of the closure, Defendant still owed these employees unpaid wages, which remain unpaid to this day. Olsen Decl. Ex. 3, ¶ 3. Plaintiffs calculate the amount of unpaid wages to be $4,566,290.07, based on payroll information kept by Defendant prior to the closing. Olsen Decl. ¶ 4-18 & Exs. 2A, 5-7. Plaintiffs filed this case on December 6, 2019. See ECF No. 1. Plaintiffs filed a First Amended…