Contract analysis

1. In response to the allegations of Paragraph 1 of the Complaint, concerning Plaintiff Gloria Reyes, Vantage admits that Gloria Reyes was employed by Vantage as a Production Associate assigned to Trim Line B at Vantage's manufacturing facility located at 11780 Cherry Avenue, Fontana, California 92337 (the "Fontana Plant"), from approximately March 12, 2021 through January 19, 2025. Vantage admits that Plaintiff was

2. In response to the allegations of Paragraph 2 of the Complaint, Vantage admits that it is a corporation organized and existing under the laws of the State of Delaware, duly registered and authorized to transact business in the States of California and Michigan. Vantage admits that its corporate headquarters are located at 4200 Industrial Parkway, Auburn Hills, Michigan 48326. Vantage admits that it operates the Fo

3. In response to the allegations of Paragraph 3 of the Complaint, Vantage admits that it was at all relevant times an employer within the meaning of the California Labor Code. Vantage admits that it employed Plaintiff during the period alleged. Vantage denies any remaining allegations in Paragraph 3 to the extent they purport to describe the nature or characteristics of the employment relationship in a manner that s

4. In response to the allegations of Paragraphs 4 through 8 of the Complaint, to the extent such paragraphs contain further allegations regarding the parties, Vantage responds to each specific allegation therein by admitting only those facts expressly admitted above, and denies each and every remaining allegation not specifically admitted.

5. In response to the allegations of Paragraph 9 of the Complaint, concerning jurisdiction, Vantage admits that the Superior Court of the State of California, County of San Bernardino, has subject matter jurisdiction over this action pursuant to the California Constitution, Article VI, Section 10, and that personal jurisdiction over Vantage is proper in this Court given Vantage's operations at the Fontana Plant withi

6. In response to the allegations of Paragraph 10 of the Complaint, concerning venue, Vantage admits that venue is proper in the County of San Bernardino pursuant to California Code of Civil Procedure sections 395 and 395.5, based on the location of the Fontana Plant at 11780 Cherry Avenue, Fontana, California 92337, which is situated within San Bernardino County. B. Response to Allegations Regarding the Proposed Cla

7. In response to the allegations of Paragraph 11 of the Complaint, which sets forth the proposed class definition, Vantage denies that class treatment is appropriate under California Code of Civil Procedure section 382 or any other provision of law. Vantage notes that the Complaint defines the proposed class as "[a]ll current and former non-exempt hourly employees of Vantage Mobility Systems Corp. who worked at the

8. In response to the allegations of Paragraph 12 of the Complaint, concerning numerosity, Vantage admits that the number of individuals falling within the proposed class definition is sufficiently numerous that joinder of all members would be impracticable. Vantage reserves all objections and defenses to class certification, including but not limited to objections to the other prerequisites for class certification.

9. In response to the allegations of Paragraphs 13 and 14 of the Complaint, concerning commonality and typicality, Vantage denies that common questions of law or fact predominate over individualized questions, and denies that Plaintiff's claims are typical of the claims of the putative class. Vantage affirmatively states that individual variations in shift assignments across six distinct production lines at the Fonta

10. In response to the allegations of Paragraph 15 of the Complaint, concerning adequacy of representation, Vantage denies that Plaintiff Gloria Reyes is an adequate representative of the putative class. Plaintiff's individual circumstances — her assignment to Trim Line B on the second shift, her specific hourly wage rate, her specific job duties, and her individual interactions with supervisors — are not representat

11. In response to the allegations of Paragraphs 16 through 18 of the Complaint, concerning superiority and other class certification requirements, Vantage denies that a class action is the superior method for the fair and efficient adjudication of the claims alleged in the Complaint. Vantage affirmatively states that the highly individualized nature of the alleged meal period, rest period, and wage violations — whic

12. In response to the allegations of Paragraph 19 of the Complaint, regarding the operations of the Fontana Plant, Vantage admits that the Fontana Plant operates two production shifts: a First Shift with scheduled hours of 5:00 AM to 1:30 PM, and a Second Shift with scheduled hours of 2:00 PM to 10:30 PM. Vantage admits that during surge production periods, overtime shifts may be scheduled that extend a given employ

13. In response to the allegations of Paragraphs 20 through 23 of the Complaint, concerning Vantage's meal period policy, Vantage admits that it maintained a written meal and rest break policy set forth in Section 4.3 of the Employee Handbook (Fontana Plant), which was most recently revised in June 2022. Vantage admits that the written policy scheduled a 30-minute unpaid meal period at approximately 9:00 AM for First

14. In response to the allegations of Paragraphs 24 and 25 of the Complaint, concerning Vantage's rest break policy, Vantage admits that its written policy, as set forth in Employee Handbook Section 4.3, provides for two paid 10-minute rest breaks per 8-hour shift and three paid 10-minute rest breaks per 12-hour shift, in compliance with the applicable Industrial Welfare Commission Wage Order and California Labor Cod

15. In response to the allegations of Paragraphs 26 through 29 of the Complaint, concerning the automatic meal period deduction feature in the ApexTime 6.2 timekeeping system, Vantage admits the following: From approximately January 2020 through March 15, 2024, the Fontana Plant utilized an automatic 30-minute meal period deduction feature in the ApexTime 6.2 timekeeping system, which was provided and maintained by A

16. In response to the allegations of Paragraph 30 of the Complaint, to the extent such paragraph references the internal Human Resources audit, Vantage notes, without waiving any applicable attorney-client privilege, work-product protection, or other privilege, that Vantage proactively conducted an internal review of its timekeeping practices at the Fontana Plant. The internal HR audit memorandum, dated February 8,

17. In response to the allegations of Paragraphs 31 and 32 of the Complaint, concerning the time-rounding policy, Vantage admits that the ApexTime 6.2 timekeeping system rounds clock-in and clock-out punches to the nearest 6-minute (one-tenth of an hour) increment. Vantage denies that the rounding policy systematically favors Vantage or results in net underpayment to employees, whether individually or on a class-wide

18. In response to the allegations of Paragraphs 33 through 36 of the Complaint, concerning production quotas and supervisor conduct, Vantage denies that production quotas at the Fontana Plant prevented or impeded employees from taking compliant meal periods or rest breaks. Vantage denies that supervisors routinely required, directed, or encouraged employees to remain at their workstations during scheduled meal perio

19. In response to the allegations of Paragraphs 37 through 40 of the Complaint, concerning Plaintiff Gloria Reyes's individual employment experience, Vantage denies Plaintiff's allegation that she was routinely required to remain at her workstation during scheduled meal periods due to production quotas or for any other reason attributable to Vantage. Vantage denies that Plaintiff's rest breaks were shortened or deni

20. In response to the allegations of Paragraphs 41 through 48 of the Complaint, concerning alleged damages, Vantage denies each and every allegation regarding the nature, scope, and amount of damages allegedly sustained by Plaintiff and the putative class. Vantage specifically denies that Plaintiff's aggregate damages estimate of approximately $65 million, or any other aggregate figure stated in the Complaint, is ac

21. In response to the allegations set forth in the First Cause of Action, Vantage denies each and every material allegation. Vantage admits that California Labor Code sections 226.7 and 512 impose certain obligations on employers with respect to meal periods for non-exempt employees. Vantage denies that it failed to provide, authorize, or permit compliant off-duty, uninterrupted 30-minute meal periods to Plaintiff o

22. In response to the allegations set forth in the Second Cause of Action, Vantage denies each and every material allegation. Vantage admits that California Labor Code section 226.7 requires employers to authorize and permit paid rest breaks of not less than 10 minutes per four hours of work, or major fraction thereof. Vantage denies that it failed to authorize and permit rest breaks to Plaintiff or to any putative

23. In response to the allegations set forth in the Third Cause of Action, Vantage denies each and every material allegation. Vantage denies that the automatic deduction of 30 minutes for meal periods resulted in the systematic nonpayment of wages for time actually worked by Plaintiff or any putative class member. Vantage further denies that the time-rounding policy utilized in the ApexTime 6.2 timekeeping system res

24. In response to the allegations set forth in the Fourth Cause of Action, Vantage denies each and every material allegation. Vantage denies that it issued wage statements that failed to accurately report hours worked and wages earned by Plaintiff or by any putative class member. Vantage affirmatively states that wage statements issued by Vantage, which were generated and processed through Apex Workforce Solutions,

25. In response to the allegations set forth in the Fifth Cause of Action, Vantage denies each and every material allegation. Vantage denies that it failed to pay all wages due at the time of separation to any former employee, including Plaintiff Gloria Reyes, who separated from employment on January 19, 2025. Vantage denies that approximately 2,100 former employees during the proposed class period, or any other numb

26. In response to the allegations set forth in the Sixth Cause of Action, Vantage denies each and every material allegation. Vantage denies that it engaged in any unlawful, unfair, or fraudulent business act or practice within the meaning of California Business and Professions Code section 17200 et seq. (the "UCL"). Vantage denies that the predicate violations of the California Labor Code alleged in the Complaint ha

27. In response to the allegations set forth in the Seventh Cause of Action, Vantage denies each and every material allegation. Vantage admits that Plaintiff served a notice pursuant to the Private Attorneys General Act of 2004 ("PAGA"), California Labor Code section 2699.3, on the California Labor and Workforce Development Agency ("LWDA") and on Vantage on or about May 22, 2025. Vantage admits that the PAGA notice w

1. That Plaintiff Gloria Reyes take nothing by this action;

2. That the Complaint be dismissed in its entirety, with prejudice, and that judgment be entered in favor of Vantage and against Plaintiff and the putative class on each and every cause of action alleged in the Complaint;

3. That the Court deny class certification in its entirety;

4. That Vantage be awarded its costs of suit incurred herein, including but not limited to filing fees, deposition costs, and other recoverable costs, pursuant to California Code of Civil Procedure section 1032;

5. That the Court deny any and all requests for injunctive relief, restitution, penalties, and other equitable or legal remedies sought by Plaintiff; and

6. That the Court grant such other and further relief as it deems just and proper. PART IV AFFIRMATIVE DEFENSES Without assuming any burden of proof that would otherwise rest with Plaintiff, and without admitting the sufficiency, merit, or viability of any cause of action alleged in the Complaint, Defendant Vantage Mobility Systems Corp. hereby asserts the following affirmative defenses. Vantage expressly reserves th