Massey

I. BACKGROUND

25 Plaintiff filed the putative class action complaint on March 2, 2021 against Star Nursing, a 26 staffing company that employs hourly healthcare workers (“Travelers”) on short-term travel 27 Case No.: 5:21-cv-01482-EJD assignments at healthcare facilities throughout California. Plaintiff alleges that Travelers were underpaid overtime because Star Nursing excluded the value of hourly stipends from the regular rate when calculating overtime rates of pay. Plaintiff’s Second Amended Complaint (“SAC”) asserts claims for (1) unpaid overtime wages under California Labor Code §§ 510 and 1194; (2) unfair business practices under California Business & Professions Code § 17200 et seq.; (3) waiting time penalties under California Labor Code § 203; (4) civil penalties under the California Labor Code Private Attorney General Act (“PAGA”), Labor Code § 2698, et seq.; and (4) violation of the federal Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201, et. seq. See SAC, Dkt. No. 24. The parties reached a settlement prior to class certification with the assistance of the Honorable Suzanne Segal. B. Terms of the…