Quinonez

FACTS

A. The Alleged PAGA Violations 1 According to Quinonez, Payless 4 Plumbing, Inc. and Alex Beltran (together

“Payless”) employed him as a plumber in San Bernardino County from July 3, 2015 to

November 20, 2018.

Quinonez alleged Payless committed a string of Labor Code violations during the

term of his employment, which affected himself and other employees. On December 21,

2018, he sent a notice of these violations and his intent to file a PAGA claim to his

employers and the Labor Workforce and Development Agency (LWDA), as required by

statute, and mailed out a check of $75 to the LWDA as a fee for filing the notice.

What follows is a list of the violations and the Labor Code provisions Quinonez

alleges his employers transgressed.

• Failure to relieve employees of all duties during meal breaks, pay them for the

break time during which they worked, or pay the statutory penalty for missed

breaks. (Lab. Code, §§ 226, 226.7, 512, 558, & 1198.)

• Failure to pay employees for all hours worked. (Lab. Code, §§ 200, 203, 218.5,

226, 558, 1194, & 1198; Industrial Welfare Commission Order 9.)

• Failure to pay overtime. (Lab. Code, §§ 500, 510, & 1194.)

1 Quinonez …