This is a class action complaint alleging that Defendants engaged in the following illegal activities: (1) failed to pay employees all wages due, including at the time of termination, in violation of California Labor Code sections 201-203; (2) failed to pay for all hours worked, and overtime and double-time owed, in violation of California Labor Code sections 510 and 1194; (3) failed to provide and/or make available rest and meal breaks in violation of California Labor Code sections 226.7 and 512; (4) failed to provide accurate, itemized, wage statements to employees as required by California Labor Code section 226; and, (5) failed to reimburse employees for the costs incurred to use their personal cell phones for work, and other work-related expenses, in violation of California Labor Code section 2802. Said conduct, in addition to the forgoing, violated each Labor Code section as set forth in California Labor Code section 2699.5. Ms. Rodriquez seeks to represent all similar aggrieved employees, who worked for the employer from November 17, 2021, to the present.
Plaintiff is a former non-exempt Provisioner Engineer (hereinafter “provisioner”) who worked for Defendants and seeks to represent all other similarly situated non-exempt employees of Defendants including but not limited to provisioners who worked for Defendant within four years of the date of the filing of this class action. Plaintiff alleges that Defendants 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.