Ibarra

FACTS AND PROCEDURAL HISTORY

From January to July 2021, Ibarra was employed as a nonexempt employee by defendants Chuy & Sons Labor, Inc., Infinite Herbs, LLC, Baby Root Farms, and G.J. Farms, Inc. (collectively Defendants). Chuy is a farm labor contractor that provides labor to various client growers. The remaining three defendants are client growers. In September 2021, Ibarra sent a prelitigation notice to Defendants and the LWDA alleging Defendants violated several provisions of the Labor Code. She specifically identified each defendant and alleged they “failed to maintain adequate staffing levels” and gave Ibarra and other nonemployees “too much work to perform,” resulting in missed, short, late, and interrupted meal and rest periods without premium pay. Defendants also allegedly failed to reimburse these employees for safety gloves and protective masks and required them to “work off-the clock,” “work during their meal breaks,” and “inaccurately” recorded hours worked, resulting in unpaid minimum and overtime wages. Because of these alleged predicate wage and hour violations,

2 Defendants allegedly failed to timely pay all wages owed for every pay period and upon separation…