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Kenneth R. Freeman
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October 22, 2019
Los Angeles County, CA
Other Employment Complaint Case (General Jurisdiction)
BYERS TONI - Plaintiff
HABIB HILARY ANN - Attorney for Defendant
HAYES MATTHEW BRYAN - Attorney for Plaintiff
MUSSIG ROBERT EUGENE - Attorney for Defendant
PAWLENKO KYE DOUGLAS - Attorney for Plaintiff
SIMMONS RICHARD JAY - Attorney for Defendant
UNITED STAFFING SOLUTIONS INC. - Defendant
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TONI BYERS V. UNITED STAFFING SOLUTIONS, INC. MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION TENTATIVE RULING Grant motion for summary judgment; motion for summary adjudication is moot DISCUSSION I. Background This is a putative wage-and-hour class action. Plaintiff Toni Byers alleges that she worked for Defendant United Staffing Solutions, Inc. (“USSI”) as a travel nurse from October 2015 until April 2016. [First Amended Class Action Complaint (“FAC”), ¶2.] USSI is a healthcare staffing company that employs hourly health care professionals for short-term travel assignments at health care providers throughout California and elsewhere. [FAC, ¶7.] Plaintiff alleges that in addition to an hourly wage rate, for each hour that Travelers work, Defendant pay Travelers an hourly rate for housing and meals and incidentals expenses for the duration of the assignment as par........
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