This is a class action complaint against Defendant to challenge the following of Defendant’s policies and practices of: (1) failing to pay employees all compensation owed; (2) failing to timely pay all wages after employees voluntarily or involuntarily terminated their employment with Defendant; (3) failing to provide employees with accurate, itemized, wage statements; (4) failing to provide signed commission plans; (5) taking unlawful deductions from wages; (6) failing to reimburse for work-related expenses; and, (7) failing to provide paid sick leave and written notice of available sick leave.
Plaintiff is a former sales person (also referred to as an account manager) who worked for Defendant between June 1, 2020, and August 1, 2022, who seeks to represent all other similarly situated employees of Defendant including, but not limited to, sales persons who worked for Defendant within four years of the date of the filing of this class action and employees who did not receive notice of available sick leave. Plaintiff alleges that Defendant engaged in unlawful patterns and practices of failing to comply with the requirements of the California Labor Code and California Business and Professions Code and applicable Industrial Commission Wage Orders.