REQUESTS FOR ADMISSION — SET ONE
SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA
MARCO SANTOS, Plaintiff,
v.
COASTAL TECH SOLUTIONS, INC., Defendant.
Case No.: RG25847201 (FICTIONAL) Dept.: [TBD]
PLAINTIFF MARCO SANTOS’S REQUESTS FOR ADMISSION TO DEFENDANT COASTAL TECH SOLUTIONS, INC. — SET ONE
Pursuant to California Code of Civil Procedure § 2033.010 et seq., Plaintiff Marco Santos (“Plaintiff”) hereby requests that Defendant Coastal Tech Solutions, Inc. (“Defendant” or “Coastal Tech”) admit the truth of each of the following facts within thirty (30) days of service.
INSTRUCTIONS: These Requests for Admission are directed to Defendant Coastal Tech Solutions, Inc. and to each of its agents, employees, officers, directors, predecessors, successors, subsidiaries, and affiliated entities. Your responses must be made under oath by a person with authority to respond on behalf of the corporation. Each admission that you make will be deemed conclusive on that fact in this proceeding. Each denial must specifically address why the matter is not true or cannot be admitted. Qualified admissions should state the portion that is admitted and specifically deny the remainder.
CLASSIFICATION AND EMPLOYMENT STATUS
REQUEST FOR ADMISSION NO. 1:
Admit that Plaintiff Marco Santos was employed by Defendant Coastal Tech Solutions, Inc. from approximately February 2022 through June 2024.
REQUEST FOR ADMISSION NO. 2:
Admit that at all times during his employment, Plaintiff was classified by Defendant as an exempt salaried employee not entitled to overtime compensation.
REQUEST FOR ADMISSION NO. 3:
Admit that Plaintiff’s classification as exempt was based, at least in part, on his annual salary exceeding the minimum salary threshold applicable to salaried exempt employees under California Wage Order No. 4.
REQUEST FOR ADMISSION NO. 4:
Admit that at no time during Plaintiff’s employment did Defendant conduct a written individualized analysis of whether Plaintiff’s actual job duties met the criteria for the administrative exemption under California Labor Code § 515 and Wage Order No. 4.
REQUEST FOR ADMISSION NO. 5:
Admit that at no time during Plaintiff’s employment did Defendant conduct a written individualized analysis of whether Plaintiff’s actual job duties met the criteria for the computer professional exemption under California Labor Code § 515.5.
REQUEST FOR ADMISSION NO. 6:
Admit that Plaintiff’s title during his employment was “Engineering Associate.”
HOURS WORKED
REQUEST FOR ADMISSION NO. 7:
Admit that Defendant did not maintain any timekeeping records for Plaintiff during his employment because Plaintiff was classified as a salaried exempt employee.
REQUEST FOR ADMISSION NO. 8:
Admit that Defendant’s timekeeping system was configured to exclude salaried employees from automatic time-punch requirements during the period February 2022 through June 2024.
REQUEST FOR ADMISSION NO. 9:
Admit that during at least one workweek in the period from February 2022 through June 2024, Plaintiff worked in excess of forty (40) hours in a single workweek.
REQUEST FOR ADMISSION NO. 10:
Admit that during at least one workweek in the period from February 2022 through June 2024, Plaintiff worked in excess of eight (8) hours in a single workday.
REQUEST FOR ADMISSION NO. 11:
Admit that Defendant did not pay Plaintiff any overtime compensation for hours worked in excess of eight (8) hours in a day or forty (40) hours in a week during his employment.
MEAL AND REST PERIODS
REQUEST FOR ADMISSION NO. 12:
Admit that Defendant did not maintain any records of meal periods taken or missed by Plaintiff during his employment.
REQUEST FOR ADMISSION NO. 13:
Admit that Defendant did not maintain any records of rest periods taken or missed by Plaintiff during his employment.
REQUEST FOR ADMISSION NO. 14:
Admit that Defendant did not provide Plaintiff with any written meal period or rest period policy specific to salaried exempt employees during the period February 2022 through June 2024.
REQUEST FOR ADMISSION NO. 15:
Admit that during at least one day in the period from February 2022 through June 2024, Plaintiff did not receive a compliant thirty (30)-minute uninterrupted meal period.
REQUEST FOR ADMISSION NO. 16:
Admit that Defendant did not pay Plaintiff any meal period premium wages during his employment with Defendant.
SEPARATION AND WAITING TIME PENALTIES
REQUEST FOR ADMISSION NO. 17:
Admit that Plaintiff’s employment with Defendant ended in June 2024.
REQUEST FOR ADMISSION NO. 18:
Admit that at the time of Plaintiff’s separation, Defendant did not include any overtime compensation or meal period premium wages in Plaintiff’s final paycheck.
DOCUMENT AUTHENTICITY
REQUEST FOR ADMISSION NO. 19:
Admit that the document attached hereto as Exhibit A — a payroll summary report produced by Defendant in discovery in this action reflecting compensation paid to Plaintiff for the period February 2022 through June 2024 — is a true and accurate record maintained in the ordinary course of Defendant’s business.
REQUEST FOR ADMISSION NO. 20:
Admit that the document attached hereto as Exhibit B — a copy of Defendant’s Employee Classification Policy dated January 2022 produced in discovery — is a true and accurate record maintained in the ordinary course of Defendant’s business.
Dated: August 14, 2025
Respectfully submitted,
[LAW FIRM NAME]
By: ________________________ [ATTORNEY NAME — STATE BAR NO. ######] Attorneys for Plaintiff Marco Santos
Exhibit A: Payroll Summary — Marco Santos (Feb. 2022–Jun. 2024) [attached] Exhibit B: Employee Classification Policy (Jan. 2022) [attached]
This document is a fictional representation created for portfolio purposes only. All names, case numbers, and factual details are invented.