Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and Xxxxxxxxx has paid the Gross Settlement Amount (and separately paid the employer-side payroll taxes), all Aggrieved Employees will be barred from asserting PAGA claims against Defendant, whether or not they exclude themselves from the Class Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendant or its related entities based on the PAGA Period facts allege in the Action and resolved by this Settlement. The Aggrieved Employees’ Releases for Participating and Non-Participating Class Members are as follows: 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, including, e.g., any and all claims for PAGA penalties pursuant to Labor Code sections 203, 210, 226.3, 558, 1174.5, 1197.1, and 2699 in connection with any and all allegations of Labor Code and/or IWC Wage Order violations involving: (1) any alleged failure to pay wages (including minimum wage); (2) any alleged failure to pay overtime compensation; (3) any alleged failure to provide compliant meal periods, or compensation in lieu thereof; (4) any alleged failure to provide compliant rest breaks, or compensation in lieu thereof; (5) any alleged failure to provide compliant accurate itemized wage statements; and (6) any alleged failure to timely pay wages due upon separation.
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and Defendant has paid the Gross Settlement (and separately paid the employer-side payroll taxes), all Aggrieved Employees will be barred from asserting PAGA claims against Defendant, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendant or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement. The Aggrieved Employees’ Releases are as follows: All Aggrieved Employees, whether Participating or 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.
Aggrieved Employees’ PAGA Release. After the Judgment is final and Defendant has fully funded the Gross Settlement and separately paid all employer payroll taxes, all Aggrieved Employees will be barred from asserting PAGA claims against Defendant, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendant or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement. The Aggrieved Employees’ Releases for Participating and Non-Participating Class Members are as follows: All Aggrieved Employees, as well as the State of California and LWDA, 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, including violation of Labor Code section 2698, et seq. (PAGA), including, but not limited to, penalties that could have been awarded pursuant to Labor Code sections 201, 202, 203, 204, 210, 226, 226.3, 226.7, 510, 512, 1194, 1197, 1197.1, and 1198.
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and XXX has paid the Gross Settlement and separately paid the employer-side payroll taxes, all Aggrieved Employees will be barred from asserting PAGA claims against Defendants, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendants or its related entities based on the PAGA Period facts alleged in the Actions and resolved by this Settlement. The Aggrieved Employees’ Releases for Participating and Non-Participating Class Members are as follows: All 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 Complaints and the PAGA Notice including, without limitation, California Labor Code sections 201, 202, 203, 204, 210, 216, 221, 225.5, 226, 226.3, 226.7, 223, 510, 511, 512, 516, 551, 552, 553, 558, 1174, 1182.1-1182.3, 1194- 1197.1, 1198, 2802, and 2698 California Business and Professions Code section 17200, et seq, any IWC Wage Orders (as codified in the California Code of Regulations), any and all claims involving any alleged failure to pay minimum wages, failure to pay wages owed, failure to provide compliant meal breaks, failure to provide compliant paid rest periods, wage statement violations, continuation wages, and unpaid vacation wages.
Aggrieved Employees’ PAGA Release. Effective on the date when Defendants fully fund the entire Gross Settlement Amount and fund Employer Paid Taxes owed on the Wage Portion of the Individual Class Payments, all Aggrieved Employees will be barred from asserting PAGA claims against Defendants, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendants or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement. The Aggrieved Employees’ Releases for Participating and Non- Participating Class Members are as follows: All claims, rights, demands, liabilities, and causes of action for PAGA civil penalties asserted in the Action (as amended) and/or arising from, or reasonably related to the facts and claims alleged in the Complaint, the First Amended Complaint, the Second Amended Complaint, and/or June 25, 2021 LWDA exhaustion letter identified on the LWDA’s website as LWDA-CM-836198-21. Such claims, rights, demands, liabilities, and causes of action include those arising out of the following: California Minimum Wage Order (MW-2014), Labor Code sections 201, 202, 203, 204, 218.5, 221, 226, 226.3, 226.7, 510, 1194, 1197, 1198, 2698 et seq. Further, such claims, rights, demands, liabilities, and causes of action include those for PAGA civil penalties for unpaid wages, including, but not limited to, failure to pay minimum wages, straight time compensation, overtime compensation, double-time compensation, and interest; the calculation of the regular rate of pay; wages related to alleged unlawful time rounding; travel time pay; failure to pay wages at least twice each calendar month; failure to timely pay wages; missed/short/late/interrupted meal period, rest period, and/or recovery period wages/premiums; failure to provide meal periods; failure to authorize and permit rest periods and/or recovery periods; the calculation of meal, rest, and/or recovery period premiums; reimbursement for all necessary business expenses, including work-related cell-phone expenses and car mileage for work-related travel; payment for all hours worked, including off-the-clock work; failure to provide/furnish accurate itemized wage statements; deductions; failure to keep/maintain accurate records; failure to timely pay final wages; and unlawful deduction...
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and MSMU has paid the Gross Settlement, all Aggrieved Employees will be barred from asserting PAGA claims against MSMU, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who opt- out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against MSMU or the Released Parties based on the PAGA Period facts alleged in the Action and resolved by this Agreement. The aggrieved employees will be bound by the following release: Each and all Aggrieved Employee, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, shall be deemed to release MSMU and the Released Parties from all claims for PAGA penalties for all claims that were alleged, or reasonably could have been alleged, based on the PAGA Period facts alleged in the Operative First Amended Complaint and in the PAGA Notice, and arising during the PAGA Period.
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and Ambitions has paid the Gross Settlement (and separately paid the employer-side payroll taxes), all Aggrieved Employees will be barred from asserting PAGA claims against Ambitions, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Ambitions or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement. The Aggrieved Employees’ release the Released Parties from the following PAGA claims: DocuSign Envelope ID: AC9F757F-60E8-4E69-A505-9939CD2B121B [A]ny and all claims for civil penalties under PAGA based on the allegations in the PAGA Notice that arose during the PAGA Period, including violations of California Labor Code sections 201, 202, 203, 204, 226, 226.7, 510, 512, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 2802, 2698, et seq., and IWC Wage Order 5-2001 as well as all facts, theories, or claims for civil penalties that would be considered administratively exhausted under applicable law by the PAGA Notice submitted in the Action.
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and 7 Defendants have paid the Gross Settlement (and separately paid the employer-side payroll taxes), all 8 Aggrieved Employees will be barred from asserting PAGA claims against Defendants, whether or not 9 they exclude themselves from the Settlement. This means that all Aggrieved Employees, including 10 those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, 11 continue to sue, or participate in any other PAGA claim against Defendants or their related entities 12 based on the PAGA Period facts alleged in the Action and resolved by this Settlement. 13 The Aggrieved Employees’ Releases for Participating and Non-Participating Class Members 14 are as follows: 15 All Aggrieved Employees, including Plaintiff, release all claims and damages arising under the Private Attorney General Act of 2004 (“PAGA”), as alleged 16 in the First Amended Complaint filed by Plaintiff.
Aggrieved Employees’ PAGA Release. After the Court’s judgment is final, and XXXX has paid the Gross Settlement (and separately paid the employer-side payroll taxes), all Aggrieved Employees will be barred from asserting PAGA claims against XXXX, whether or not they exclude themselves from the Settlement. This means that all Aggrieved Employees, including those who are Participating Class Members and those who opt-out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against XXXX or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement. The Aggrieved Employees’ Releases for Participating and Non-Participating Class Members are as follows: All Participating Class Members who are Aggrieved Employees and all 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, rights, demands, liabilities and causes of actions for civil penalties under the California Labor Code Private Attorneys General Act of 2004, Cal. Labor Code §§ 2698, et seq. arising during the PAGA Period, based on the facts and legal theories contained the PAGA Notice, including claims for civil penalties based on unpaid overtime, failure to provide rest periods and associate premium wages, failure to provide meal periods and associated premium wages, unpaid minimum wages, failure to timely pay final wages, failure to timely pay wages during employment, failure to keep requisite payroll records, and failure to reimburse business expenses, including violations under California Labor Code sections 201, 202, 203, 204, 226, 226.7, 501, 512, 1174, 1194, 1197, 1197.1, 2800 and 2802 and the Industrial Welfare Commission Orders
Aggrieved Employees’ PAGA Release. All 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, including without limitation PAGA claims predicated on violations of California Labor Code sections 201-203, 204, 216, 218.5, 221- 223, 224, 225.5, 226,226.2, 226.6, 226.7, 226.8, 256, 510, 512, 558, 558.1, 1174, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2751, and 2810.5.
