Miller v. Infinite Percent Partners LLC

I. BACKGROUND

14 The Court previously summarized the factual background of this employment dispute 15 between Plaintiff, Dr. Lisa Miller, and Defendants Infinite Percent Partners LLC (“IPP”), et al. 16 See Dkt. No. 48 (“Order”). 17 In brief, Plaintiff contends that she relied to her detriment on Defendants’ promise of full- 18 time employment as IPP’s Chief Medical Officer with an annual salary of $200,000; medical 19 benefits; and equity. Id. In her First Amended Complaint (“FAC”), Plaintiff repeats the 20 previously alleged causes of action for (a) Violation of the Fair Labor Standards Act’s (“FLSA”) 21 anti-retaliation provision; (b) Violation of California Labor Code section 1102.5; (c) Breach of 22 Contract; (d) Promissory Estoppel; (e) Estoppel by Conduct; (f) Non-Payment of Wages; and (g) 23 Failure to Provide Itemized Wage Statements. FAC ¶¶ 28-67. 24 Plaintiff adds in her FAC the allegation that Defendants failed to pay her the federal 25 minimum wage in violation of FLSA § 206. FAC ¶¶ 35-38. Plaintiff also alleges that Defendants 26 violated FLSA § 215(a)(3) in terminating her employment after her complaints about timely and 27 complete compensation. FAC ¶¶…