Steven Tapia v. Paragon Systems, Inc.

I. BACKGROUND

Plaintiff was employed as a non-exempt employee by Defendant, a company that provides security services, from approximately December 2023 to November 2024. Compl., Dkt. No. 1-1, Ex. A, 9-10. On February 20, 2025, Plaintiff filed the Complaint against Defendant in the Los Angeles County Superior Court. See generally id. Plaintiff alleges a single cause of action against Defendant for violation of the Private Attorneys General Act (“PAGA”). See generally id. The Complaint seeks civil penalties under PAGA based on the following violations of the California Labor Code:

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1. Underpayment and late payment of minimum wages and hourly wages in violation of California Labor Code §§ 204, 1194, 1194.2, 1197, IWC Wage Order, and California Minimum Wage Order. 2. Underpayment of overtime wages in violation of California Labor Code §§ 510, 1194, 1198, and IWC Wage Order. 3. Failure to provide compliant meal periods in violation of California Labor Code §§ 226.7, 512, 558, and IWC Wage Order. 4. Failure to provide compliant rest periods in violation of California Labor Code §§…