Fictional matter — created for portfolio demonstration. No real parties, courts, or facts.

Caption

Santos v. Coastal Tech Solutions, Inc.

Court
Alameda County Superior Court
Case No.
RG25847201 (FICTIONAL)
Filed
2025-03-11
Plaintiff
Marco Santos
Defendant
Coastal Tech Solutions, Inc.

Fact pattern

Marco Santos was employed by Coastal Tech Solutions, Inc., a software development firm based in Oakland, California, from February 2022 through June 2024. He was classified as an exempt salaried employee under the title “Engineering Associate” and paid a fixed annual salary without overtime compensation. During his tenure, Mr. Santos routinely worked between 55 and 65 hours per week based on project deadlines communicated by management. The company’s timekeeping system did not track hours for salaried employees, and managers frequently scheduled working lunches and early-morning calls that precluded compliant meal and rest periods under California law.

Mr. Santos contends that the “Engineering Associate” classification was applied primarily based on his salary level rather than a genuine evaluation of whether his actual day-to-day duties met the requirements of the administrative or computer professional exemption under California wage and hour law. He describes his work as predominantly executing tasks under the direction of senior engineers and project managers, with limited discretionary authority over business operations or methodology. He also describes a company culture in which salaried employees were implicitly discouraged from leaving the office during core project sprints even for legally required breaks.

After separating from the company in June 2024, Mr. Santos provided the required PAGA notice to the California Labor and Workforce Development Agency and to his former employer. The LWDA declined to investigate the matter within the statutory period, clearing the way for a civil action. Coastal Tech Solutions disputes the misclassification allegation and maintains that Mr. Santos had the authority and knowledge required for exemption under the computer professional exemption, among other defenses.

Procedural posture

The complaint was filed in Alameda County Superior Court in March 2025, asserting claims for unpaid overtime, meal and rest period premium wages, waiting time penalties, and civil penalties under PAGA. Defendant answered in May 2025 and has raised the professional and administrative exemptions as affirmative defenses. Written discovery is substantially complete, including service of requests for admission and a trial subpoena to the company’s third-party payroll vendor. Trial is currently set for November 2026, with pretrial motions in limine due in the coming months.

Procedural timeline

  1. 2024-08-15

    Plaintiff provides written PAGA notice to California Labor and Workforce Development Agency and to Coastal Tech Solutions regarding overtime, meal break, and rest break violations

  2. 2024-10-22

    LWDA declines to investigate; plaintiff retains employment counsel and demand letter sent to employer

  3. 2025-03-11

    Complaint filed in Alameda County Superior Court asserting claims for unpaid overtime, meal and rest period premiums, waiting time penalties, and PAGA civil penalties

  4. 2025-05-02

    Defendant answers, denies misclassification, and asserts professional exemption defense under California Wage Order No. 4

  5. 2025-08-14

    Requests for admission served on defendant regarding classification criteria, job duty records, and timekeeping policies

  6. 2025-11-19

    Trial subpoena issued to third-party payroll vendor for plaintiff's time and compensation records

  7. 2026-05-08

    Written discovery substantially complete; pretrial motions in limine due; trial set for November 2026

Artifacts produced (2)