Motion to Compel Arbitration

and DOES 1 through 10 (hereinafter collectively referred to as “Defendants”) for California

Labor Code Violations and unfair business practices stemming from Defendants’ failure to pay

for all hours worked (minimum, straight time, and overtime wages), failure to provide meal

periods, failure to authorize and permit rest periods, failure to timely pay final wages, failure t0

10 furnish accurate wage statements, and failure t0 indemnify employees for expenditures.

11 2. Plaintiff brings the First through Eighth Causes 0f Action individually and as a

12 class action on behalf of himself and certain current and former employees of Defendants

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13 (hereinafter collectively referred to as the “Class” or “Class Members,” and defined more fully

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14 below). The Class consists 0f Plaintiff and all other persons who have been employed by any

LAW

Causes of Action

COMPLAINT:

1. Pay Minimum and Straight Failure to Time Wages (Cal. Lab. Code §§ 204, 1194, 1194.2, and 1197);

2. Failure t0 Pay Overtime Wages (Cal. Lab. inclusive, Code §§ 1194 and 1198);

3. Failure t0 ProvideMeal Periods (Cal. Lab. Code §§ 226.7, 512);

4. Failure t0 Authorize and Permit Rest Periods (Cal. Lab. Code §§ 226.7);

5. Failure to Timely Pay Final Wages at Termination (Cal. Lab. Code §§ 201-203);

6. Failure to Provide Accurate Itemized Wage Statements (Cal. Lab. Code § 226);

7. Failure to Indemnify Employees for Expenditures (Cal. Lab. Code § 2802); and

8. Unfair Business Practices (Cal. Bus. &

Prof. Code §§ 17200, et seq.).

DEMAND FOR JURY TRIAL

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