D’Este v. Bayer Corp., 565 F.3d 1119 (9th Cir. 2009) The Ninth Circuit has certified two questions of law to be answered by the California Supreme Court pursuant to Cal. Rule of Court 8.548: (1) Does a pharmaceutical sales representative (“PSR”) qualify as an “outside salesperson” under Industrial Welfare Commission Wage Orders 1-2001 and 4-2001 … Continue Reading