THIRD CAUSE OF ACTION. To Pay Overtime Compensation
THIRD CAUSE OF ACTION. (Breach of Implied Covenant of Good Faith and Fair Dealing)
THIRD CAUSE OF ACTION. (Conversion)
THIRD CAUSE OF ACTION. 12 FAILURE TO PAY ALL AGREED-UPON WAGES 13 (AGAINST ALL DEFENDANTS)
THIRD CAUSE OF ACTION. 18 (False and Misleading Advertising, Violation of Bus. & Prof. Code § 17500 et seq.)
THIRD CAUSE OF ACTION. 2 Writ of Mandate (October 2019 Allocation Ordinance) Against FCGMA
THIRD CAUSE OF ACTION. 23 FAILURE TO PROVIDE ALL MEAL PERIODS 24 (BY PLAINTIFF XXXXXXX AGAINST ALL DEFENDANTS)
25 41. Plaintiff Xxxxxxx re-alleges and incorporates by reference all previous paragraphs.
26 42. Plaintiff Xxxxxxx is informed and believes, and based thereon alleges, that 27 Defendants failed in their affirmative obligation to provide all of their non-exempt employees in 28 California, including Plaintiff Xxxxxxx and members of the Meal Period Class, with all legally 1 compliant meal periods in accordance with the mandates of the California Labor Code and Wage 2 Order 4, § 11, for the reasons set forth in the factual allegations and class definitions sections of 3 this TAC. Despite Defendants’ violations, Defendants did not pay an additional hour of premium 4 pay to Plaintiff Xxxxxxx and members of the Meal Period Class at their respective regular rates of 5 compensation, in accordance with California Labor Code §§ 226.7 and 512.
6 43. As a result, Defendants are responsible for paying premium compensation for meal 7 period violations, including interest thereon, as well as statutory penalties, civil penalties, and 8 costs of suit, pursuant to Labor Code §§ 226.7, 512, and 558, Wage Order 4, and California Code 9 of Civil Procedure § 1021.5.
THIRD CAUSE OF ACTION. 24 (Failure to Provide Meal Periods) 25 (Violation of California Labor Code §§ 226.6, 512; Cal.Code Regs., tit. 8, § 11040(11)) 26 56. Plaintiffs incorporates by reference and re-allege as if fully stated herein paragraphs 27 1 through 55 in this Consolidated complaint.
THIRD CAUSE OF ACTION. 8 Labor Code §§ 226, 1174, and 1174.5
THIRD CAUSE OF ACTION. Failure to Provide Meal Periods or Compensation in Lieu Thereof -- Labor Code §§ 512 and
