Analysis of Survey Methodology Related to Alleged Meal & Rest Break Violations In the Logistics Industry

Cirque Analytics was retained by the Defendants to evaluate Plaintiff’s proposed trial plan to survey a sample of the potential aggrieved employees in connection with a PAGA claim. The dispute was over alleged meal and rest break violations and expenses incurred by the former and current employees.

Cirque Analytics Senior Vice President Dr. Chen Song was retained by Dependable Highway Express, Inc. (DHE) and CitiStaff Solutions, Inc. (CitiStaff), to offer rebuttal analyses to the survey conducted by Plaintiff’s survey expert. In her rebuttal analyses, Dr. Song assessed whether Plaintiff’s expert’s survey can be used as representative evidence to determine any liability and PAGA exposure. She studied issues of potential biases with the methodology used by Plaintiff’s survey expert including the potential nonresponse bias and self-interest bias. Additionally, Dr. Song evaluated the reliability of Plaintiff’s expert’s survey results by studying survey outcomes from Plaintiff’s expert’s survey.