Motion to Vacate Order Compelling Arbitration

defendant Riverside Sanitarium, LLC and DOES 1 through 20, inclusive (“Defendant”), on

Plaintiff’s own behalf and on behalf of a putative class 0f California citizens who are and were

employed by Defendant as non-exempt employees throughout California.

OOOONQ 2. Defendant is in the healthcare industry.

Through this action, Plaintiff alleges that Defendant engaged in a systematic

pattern of wage and hour violations under the California Labor Code and Industrial Welfare

11 Commission (“IWC”) Wage Orders, all 0f which contribute to Defendant’s deliberate unfair

12 competition.

13 4. Plaintiff is informed and believe, and thereon alleges, that Defendant has

14 increased their profits by violating state wage and hour laws by, among other things:

15 (a) failing to pay all wages (including minimum wages and overtime wages);

16 (b) failing to provide lawful meal periods or compensation in lieu thereof;

17 (c) failing t0 authorize or permit lawful rest breaks 0r provide compensation

18 in lieu thereof;

19 (d) failing t0 reimburse necessary business-related costs;

20 (e) failing to provide accurate itemized wage statements; and

21 (f) failing to pay all wages due upon separation of employment.

22 5. Plaintiff seeks monetary relief against Defendant on behalf 0f herself and all

23 others similarly situated in California to recover, among other things, unpaid wages, un-

24 reimbursed business expenses, benefits, interest, attorneys’ fees, costs and expenses, and

25 penalties pursuant to Labor Code §§ 201, 202, 203, 204, 210, 226, 226.7, 510, 512, 1182.12,

26 1194, 1194.2, 1197, 1198, 2800, and 2802, and Code of California Civil Procedure § 1021.5.

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Causes of Action

COMPLAINT FOR:

1. Failure to Pay Minimum Wages;

2. Failure to Pay Overtime Wages;

3. Failure to Provide Meal Periods;

4. Failure to Permit Rest Breaks;

5. Failure to Reimburse Business Expenses;

6. Failure t0 Provide Accurate Itemized Wage Statements;

7. Failure to Pay All Wages Due Upon Separation 0f Employment;

8. Violation of Business and Professions

Code §§ 17200, et seq.; and