Gonzalez

FACTS AND PROCEDURAL HISTORY

Maldonado’s initial PAGA action in Orange County In July 2020, Maldonado submitted a PAGA notice to the Labor and Workforce Development Agency (LWDA) alleging violations of (1) the WARN Act,2 (2) failure to reimburse mileage, and (3) excessive heat and work conditions. He subsequently filed a PAGA lawsuit in Orange County Superior Court (Case No. 30-2020-01164707-CU-OE-CXC) based on the same three predicate violations. Gonzalez I In November 2020, Gonzalez submitted a PAGA notice to the LWDA, alleging APP failed to (1) pay minimum, straight time, and overtime wages, (2) provide meal periods, (3) authorize rest periods, (4) maintain accurate records of hours worked and meal periods taken, (5) reimburse and indemnify business expenses, (6) timely pay wages upon termination, and (7) provide accurate itemized wage statements. Gonzalez also filed a lawsuit in Ventura County Superior Court (Case No. 56-2020-00546795- CU-OE-VTA) (Gonzalez I), asserting individual and class causes

1 Further unspecified statutory references are to the Labor Code.

2 The California Worker Adjustment and Retraining Act (WARN Act). (Lab. Code, § 1400 et seq.)

2 of action based…