Iloff

I. BACKGROUND

Iloff lived and worked on property owned by BPI. LaPaille served as chief executive officer and chief financial officer of BPI, and managed that property during the relevant period. Iloff requested free rent if he kept the water system running, and provided maintenance and handyman services. Iloff performed various tasks for BPI between 2009 and 2016, and LaPaille provided him instructions, directions, and approvals related to this

2 Further undesignated statutory references are to the Labor Code.

2 work. BPI subsequently terminated this arrangement, and conceded Iloff had not been paid for his work apart from receiving free rent. Iloff filed DLSE form 1, entitled “Initial Report or Claim,” with the Labor Commissioner (Initial Report or Claim) on January 31, 2017. The form identified the employer, set forth wage information, and identified hours worked. Iloff named LaPaille and BPI as his employer, and alleged he was owed $132,880 in unpaid wages. He also checked the box claiming waiting time penalties under section 203. Iloff executed a form entitled “Complaint” a few months later. It sought $132,880 in unpaid wages and $4,200 in waiting time penalties, but also…