Kee

BACKGROUND

22 On May 3, 2019, Plaintiff initiated this action by filing a Complaint in the Superior 23 Court of California for the County of San Diego, assigned case number 37-2019-00023035- 24 CU-OE-CTL, against Defendant Hiossen, Inc. (Ex. A, ECF No. 1 at 10). 25 On July 18, 2019, Plaintiff filed a First Amended Complaint (“FAC”) in the Superior 26 Court for the County of San Diego. (Ex. B, ECF No. 1). Plaintiff alleges that he was 27 employed by Defendant as a sales representative from July 2017 to November 2018. (Ex. 28 B, ECF No. 1 at 38). Plaintiff alleges that Defendant (1) subjected Plaintiff and the Class to unlawful non-compete agreements; (2) failed to pay accrued and unused paid time off; (3) failed to provide accurate itemized wage statements; (4) failed to pay earned wages and overtime compensation; (5) failed to provide 30-minute employee meal periods; (6) failed to authorize and permit 10-minute employee rest periods; (7) failed to reimburse business expenses; (8) failed to pay compensation when due at employment separation; (9) engaged in unlawful and unfair business practices; and (10) violated the Labor Code Private 8 …