Smith v. Advanced Clinical Employment Staffing, LLC

I. BACKGROUND

22 On August 12, 2021, Plaintiffs filed an unverified complaint in the Santa Clara County 23 Superior Court against Defendant, alleging: (1) failure to pay for all hours worked; (2) failure to 24 pay minimum wage; (3) failure to pay overtime; (4) failure to authorize and/or permit meal breaks; 25 (5) failure to authorize and/or permit rest breaks; (6) failure to reimburse business-related

1 On May 13, 2022, the Court found this motion appropriate for decision without oral argument pursuant to Civil Local Rule 7-1(b). See Dkt. No. 19. expenses; (7) failure to furnish accurate wage statements; (8) waiting time penalties; and (9) unfair business practices. See Compl. Defendant, an Alabama limited liability company, is a temporary staffing agency for healthcare facilities throughout California. Compl. ¶ 7. Specifically, Defendant contracts with healthcare facility clients to provide travel and/or strike nurses, and separately enters contracts with individual nurses to satisfy its facility contracts. Compl. ¶ 7; see also Declaration of Regina Allcorn in Support of Defendant’s Opposition to Plaintiff’s Motion to Remand…