In 2011 and 2012, plaintiffs Tayler Kirner, Brian Richard and Damien Stickler, worked as emergency medical technician ambulance drivers for Explorer 1 Ambulance & Medical Services. However, they claimed that during that time, they were not paid for overtime hours worked. Kirner, Richard and Stickler sued Explorer 1 Ambulance & Medical Services and its owner, Sultan Mohamed (also known as Timothy Lee II). The ambulance drivers alleged that defendants’ failure to pay overtime constituted violations of the Labor Code. Specifically, they contended that although they were generally working shifts of 24 hours, or 12-16 hours, they were not paid for all the hours worked or paid at the overtime rate. Defense counsel contended Kirner, Richard and Stickler were exempt from receiving overtime pay as EMT ambulance drivers, per the Industrial Welfare Commission’s California Code of Regulations, Title 8, § 11090 — Order Regulating Wages, Hours, and Working Conditions in the Transportation Industry – specifically section 3(K). Plaintiffs’ counsel contended that CCR, Title 8, §11090, 3(K), stated that an EMT worker does not have to be paid overtime even if under a 24-hour shift, as long as it is agreed to do so in writing and as long as there are adequate facilities provided to sleep. Additionally, the employer has to keep track of all records, including sleep hours and working hours. Thus, plaintiffs’ counsel responded that the defendants failed to prove the existence of any such agreements with Kirner, Richard and/or Stickler., Kirner, Richard and Stickler each sought recovery of unpaid overtime wages, and penalties under the Industrial Welfare Commission’s California Code of Regulations and the Labor Code.