Release by Aggrieved Employees. All Aggrieved Employees, including Non- Participating Class Members, are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the PAGA Period facts stated in the Operative Complaint and the PAGA Notice, including, e.g., claims for PAGA penalties based on: (1) failure to pay minimum wage for all hours worked in violation of Labor Code sections 1194 and 1194.2, and the Applicable Wage Order; (2) failure to pay proper overtime wages in violation of Labor Code sections 510, 1197, and 1198, and the Applicable Wage Order; (3) failure to provide compliant rest periods and pay missed rest break premiums in violation of Labor Code section 226.7 and the Applicable Wage Order; (4) failure to provide compliant meal periods and pay missed meal period premiums in violation of Labor Code sections 226.7 and 512, and the Applicable Wage Order; (5) failure to maintain accurate employment records in violation of Labor Code section 1174; (6) failure to pay timely wages during employment in violation of Labor Code sections 204, 210; (7) failure to pay all wages due and owing at separation in violation of Labor Code sections 201, 202, and 203; (8) failure to reimburse business expenses in violation of Labor Code sections 2802 and 2804; and (9) failure to provide complete and accurate wage statements in violation of Labor Code sections 226 and 226.3.
Release by Aggrieved Employees. All Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the facts stated in the Operative Complaint and the PAGA Notice during the PAGA Period. Aggrieved Employees only release these claims for the duration of the PAGA Period.
Release by Aggrieved Employees. Regardless of whether a Class Member is a Participating or Non-Participating Class Member, Class Members who are Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from (1) all PAGA claims that were alleged in the Action and/or each complaint filed in this action (i.e., Operative Complaint) as to and/or arising during the PAGA Period and (2) all XXXX claims that could have been alleged in the Action and/or each complaint filed in this action (i.e., Operative Complaint) based on the facts alleged therein as to and/or arising during the PAGA Period.
Release by Aggrieved Employees. All Participating and Non-Participating Class Members who are Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the PAGA Period facts stated in the Operative Complaint and the PAGA Notice and ascertained in the course of the Action.
Release by Aggrieved Employees. All Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the facts stated in the Operative Complaint and the PAGA Notice, including violations premised on violation of Labor Code sections 200, 201-204, 204.1, 208, 210, 218.6, 221, 222, 223, 226, 226.3, 226.7, 227.3, 246, 256, 510, 512, 558, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2802, IWC Wage Order 9, including §§ 3(A), 4, 3(A), 11, 12, and Cal. Code Regs., tit. 8, section 11090 (the Released PAGA Claims). The operative release period for the Released PAGA Claims is the PAGA Period.
Release by Aggrieved Employees. All Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the facts stated in the Operative Complaint and the PAGA Notice, including, (1) failure to pay all wages and liquidated damages, (2) failure to reimburse business expenses; (3) failure to provide accurate itemized wage statements; (4) waiting time penalties; (5) unfair business practices; (6) recordkeeping requirement violations; (7) meal period violations; (8) rest period violations; (9) paid sick leave violations; (10) semimonthly payment violations; (11) standard conditions of labor violations; (12) unlawful deductions; and (13) unlawful agreements/inquiries into criminal history during the PAGA Period. Aggrieved Employees only release these claims for the duration of the PAGA Period.
Release by Aggrieved Employees. All Aggrieved Employees are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the facts stated in the Operative Complaint (and any amendments thereto) and PAGA Notice that occurred during the PAGA Period and were ascertained during the Action. This release includes any and all claims for PAGA penalties involving: (a) failure to pay overtime wages (including failure to properly calculate the regular rate of pay to those who worked overtime and earned incentive pay); (b) meal period violations (including failure to pay meal period premiums at the regular rate of pay); (c) failure to pay minimum wages, including sick leave pay; (d) rest period violations (including failure to pay rest period premiums at the regular rate of pay); (e) failure to provide accurate itemized wage statements; (f) failure to pay all final wages; (g) failure to timely pay wages during employment; (h) failure to comply with wage reporting required by the Labor Code; (i) failure to reimburse business expenses and costs; (j) waiting time penalties; and (k) failure to maintain accurate records.
Release by Aggrieved Employees. Each Aggrieved Employee waives and releases the Released Parties, and each of them, from and against any and all claims, whether known or unknown, suspected or not suspected to exist, against the Released Parties, or any of them, for civil penalties pursuant to the Labor Code Private Attorneys General Act arising out of the allegations of the First Amended Complaint on file in the Action during the PAGA Period, including but not limited to claims for straight time and overtime wages, meal and rest period violations, meal period premiums, rest period premiums, waiting time penalties, and accurate and complete wage statements, or arising under Labor Code §§ 201, 202, 203, 226, 226.7, 510, 512, 516, 558.1, 1194, 1194.2, 1198, 1199 or Sections 11 and 12 of Wage Order 1-2001, or Section 1174, and claims for attorney’s fees and costs associated with any of the above claims.
Release by Aggrieved Employees. Upon the occurrence of the Effective Date and the Settlement being fully funded, Plaintiffs and all Aggrieved Employees release and forever discharge the Released Parties from all claims, demands, rights, liabilities and causes of action for civil penalties under California Labor Code Private Attorneys General Act of 2004 against the Released Parties arising out of or based on the facts alleged in Plaintiff Xxxxxx’x letter to the Labor & Workforce Development Agency (“LWDA”) dated July 5, 2019 and the operative Complaint (“PAGA Released Claims”), including but not limited to failure to pay minimum wages for all hours worked in violation of Labor Code §§ 558, 1182.12, 1194, 1194.2, and 1197, failure to pay all earned overtime compensation in violation of Labor Code §§ 204, 510, 558, 1194, and 1198, failure to prove all legally required meal periods and failure to pay meal period premium wages at the regular rate of compensation in violation of Labor Code §§ 226.7, 512, and 558, failure to authorize and permit all legally required rest periods and failure to pay rest period premium wages at the regular rate of compensation in violation of Labor Code §§ 226.7 and 558, failure to reimburse for all necessary work expenses incurred in violation of Labor Code §§ 2802 and 2804, failure to furnish complete, accurate, itemized wage statements in violation of Labor Code § 226, failure to timely pay all final wages and compensation earned at the time of separation in violation of Labor Code §§ 201, 202, and 203, failure to pay non-exempt employees all earned wages at least twice during each calendar month in violation of Labor Code § 204, and failure to maintain accurate records in violation of Labor Code §§ 558 and 1174. The PAGA Period and the time period of the PAGA Released Claims is defined as July 5, 2018 through March 12, 2023 (“PAGA Period”).
Release by Aggrieved Employees. All Aggrieved Employees (regardless of whether they are Participating Class Members) are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged in connection with their employment on the production of the first, second, and/or third seasons of The L Word: Generation Q, based on the PAGA Period facts stated in the Operative Complaint, any prior complaint in the Action, and/or the PAGA Notices, including, e.g., any failure to pay all wages due (including minimum wage and overtime wages), failure to pay for all hours worked, failure to provide meal or rest periods, failure to timely pay wages and final wages, failure to furnish accurate wage statements (including claims derivative and/or related to these claims), and failure to provide expense reimbursements.
