Contract analysis

I. Deficiency Category 1: Specific Instances of Alleged Missed Meal Periods (Interrogatory Nos. 5–8) Interrogatories at Issue. Interrogatory Nos. 5 through 8, propounded to each of the three named plaintiffs, asked each plaintiff to identify the specific dates, shifts, time periods, or approximate frequency during which she or he alleges she or he was denied a compliant 30-minute meal period, as required under Labor

II. Deficiency Category 2: Identity of Supervisors Who Allegedly Required or Permitted Work Through Breaks (Interrogatory Nos. 12–15) Interrogatories at Issue. Interrogatory Nos. 12 through 15 asked each named plaintiff to identify, by name and title, the specific supervisors who allegedly directed, required, or permitted each plaintiff to work through meal or rest periods during her or his employment at AMA. These i

III. Deficiency Category 3: Use of the TimeTrack Pro Missed Meal Attestation Feature (Interrogatory Nos. 22–25) Interrogatories at Issue. Interrogatory Nos. 22 through 25 asked each named plaintiff whether she or he was aware of the NovaPay Solutions "TimeTrack Pro" Missed Meal Attestation feature — a function within AMA's timekeeping system that allowed employees to override the automatic 30-minute meal period deduc

IV. Deficiency Category 4: Individual Damages (Interrogatory Nos. 30–35) Interrogatories at Issue. Interrogatory Nos. 30 through 35 asked each named plaintiff to state her or his individual damages claim, including the amount of unpaid meal period premiums, rest period premiums, overtime wages, and other compensation she or he contends is owed, together with the factual basis for each calculation. These are standard

V. Summary and Request for Supplemental Responses In summary, AMA has identified significant deficiencies in the responses served by each of the three named plaintiffs — Marisol Fuentes, Derek Halloran, and Yesenia Padilla — to AMA's First Set of Special Interrogatories. As detailed above, the deficient responses fall into four categories:

1. Interrogatory Nos. 5–8 (specific instances of alleged missed meal periods) — responses consisting of vague, generalized assertions without any specificity as to dates, shifts, facilities, show units, or supervisors;

2. Interrogatory Nos. 12–15 (identity of supervisors who allegedly required or permitted work through breaks) — responses identifying "all supervisors" without naming a single individual;

3. Interrogatory Nos. 22–25 (awareness and use of the TimeTrack Pro Missed Meal Attestation feature) — responses that are ambiguous, incomplete, or fail to address the follow-up components of the interrogatories; and

4. Interrogatory Nos. 30–35 (individual damages) — responses consisting entirely of a deferral to a future expert report, without any individual contention as to the nature or amount of each plaintiff's damages. We respectfully request that Plaintiffs serve supplemental responses to the deficient interrogatories identified in this letter within fifteen (15) days of the date of this correspondence — that is, by no lat