Fuapau

I. BACKGROUND

1 Plaintiffs, who are all residents of Monterey County, California, are present and former 2 non-exempt employees of defendant Lhoist. Dkt. No. 43 ¶¶ 1–9. Lhoist is an Arizona corporation 3 that operates a mineral products business with its headquarters in Fort Worth, Texas. Dkt. No. 1 ¶ 4 18; Dkt. No. 1-2 ¶¶ 4–5; Dkt. No. 43 ¶ 18; Dkt. No. 45 ¶ 18. Lhoist employs or employed 5 plaintiffs at Lhoist’s “Natividad Plant” in Salinas, California. Dkt. No. 43 ¶ 22; Dkt. No. 45 ¶ 22. 6 The Natividad Plant is a mineral mining and quarrying operation that runs continuous machinery 7 24 hours a day, six to seven days a week. Dkt. No. 43 ¶ 22. 8 Plaintiffs allege that during their employment, Lhoist intentionally failed to pay its 9 employees the full wages owed for overtime hours worked, nondiscretionary safety bonuses 10 earned, and contractually promised shift premiums. Id. ¶ 32. They say that Lhoist regularly 11 required employees to work, without overtime pay, more than eight hours in a single workday and 12 more than 40 hours in a workweek. Id. ¶ 36. Plaintiffs further allege that employees never 13 received off-duty meal periods, even though Lhoist…