Moniz

BACKGROUND

I. The Parties

Defendant Adecco is a staffing firm that supplies temporary labor to a variety of companies. Adecco hires temporary employees called “Associates” and full-time employees called “Colleagues.” Moniz was a Colleague who managed Adecco’s relationship with Google, and Correa was an Associate assigned to work at Google. Moniz worked for Adecco until spring of 2016, and Correa worked for Adecco until December 2016.

II. Doe and Moniz

In December 2016, John Doe filed a PAGA complaint against Google in San Francisco Superior Court (Doe, et al. v. Google, et al. (Super Ct. S.F. City & County, 2016, No. CGC-16- 556034) (Doe)). He alleged that Google’s non-disclosure agreements, policies, and practices violated numerous provisions of the California Labor and Business and Professions Codes. On February 1, 2017, Moniz filed a PAGA notice with the LWDA alleging that Adecco maintained and implemented unlawful limitations on the disclosure of information in violation of the Labor Code. For example, she stated that Adecco impermissibly required her to agree to several illegal terms in Adecco’s “Employment Agreement for Colleagues in California.” Moniz’s PAGA notice…