Extract to table

Plaintiffs' Reply directly confronts this argument and reframes it in a manner that we must candidly acknowledge is effective

Makhija's analysis demonstrates that the actual experience of receiving (or not receiving) a compliant meal period varies significantly by show unit, facility type, and production schedule, but Plaintiffs' argument is that the policy itself — not the experience under the policy — is what must be evaluated at the class-wide level

Makhija's analysis will likely remain relevant and persuasive with respect to the non-certified claims (rest period, off-the-clock), where Plaintiffs have not identified any analogous systemic mechanism and must rely on individualized evidence

Under Sargon, the trial court serves as a gatekeeper and must exclude expert opinion that is based on speculative or conjectural assumptions that have no reasonable basis in the evidence

Rest period and off-the-clock claims must be denied