Lewings

FACTS

The TAC asserted allegations on behalf of all nonexempt or hourly employees who worked for Chipotle in California in the four years preceding October 22, 2013. According to those allegations: A company named Shoes For Crews markets its nonslip shoes (SFC shoes) to employers by offering to reimburse them for thousands of dollars in workers’ compensation related medical expenses if an employee is injured in a slip and fall while on the job.2 Chipotle implemented a Shoes For Crews program in which

1 All further statutory references are to the Labor Code unless otherwise indicated. 2 The TAC incorporates four exhibits by reference. Those exhibits, as alleged, are Shoes For Crews marketing materials. Lewings did not include those exhibits in the appellant’s appendix. We note, however, that in connection with an opposition to a demurrer to the second amended complaint, Lewings submitted four exhibits regarding Shoes For Crews marketing materials, and those exhibits are part of the appellant’s appendix. Presumably, they are the same exhibits that were attached to the TAC. For context, we elucidate the following. Exhibit 1 set forth the Shoes For Crews $5,000 slip and fall…