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; (9) failure to provide complete and accurate wage statements in violation of Labor Code sections 226 and 226.3; and (10) deceptive, fraudulent, or otherwise unlawful business practices based on the foregoing in DocuSign Envelope ID: 390C4E13-A849-43E2-995A-DFE4F7FA4615 violation of California’s Unfair Competition Law (Bus. & Prof. Code, §§ 17200– 17210).
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. 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. 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.
Release by Aggrieved Employees. Plaintiffs and all Aggrieved Employees, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, and the LWDA, shall release the Released Parties from 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 deductions and/or withholdings from wages; unfair business practices. / / /
Release by Aggrieved Employees. For the duration of the PAGA Period, 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 PAGA Period facts stated in the Operative Complaint and/or the PAGA Notices, including PAGA penalty claims based on alleged unpaid minimum wages; unpaid overtime wages; failure to provide meal periods or pay premium wages in lieu thereof; failure to provide rest periods or pay premium wages in lieu thereof; failure to furnish accurate itemized wage statements; failure to pay timely wages; failure to pay all final wages due upon termination; and failure to maintain accurate time and pay records. For the avoidance of doubt, the Released PAGA Claims covered by this Agreement include claims for PAGA penalties based upon alleged violation of California Labor Code §§ 201-204, 226, 226.7, 510, 512, 558, 558.1, 1194, 1194.2, and 1197; and all other remedies available under PAGA on any of the foregoing claims, including attorneys’ fees and costs.
Release by Aggrieved Employees. All Aggrieved Employees, as well as the State of California and Labor and Workforce Development Agency, 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. (Private Attorneys General Act of 2004), 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.
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 PAGA Period facts stated in the Operative Complaint and the PAGA Notice, including claims for PAGA penalties arising out of or based on: 1) failure to provide meal periods, 2) failure to provide rest periods, 3) failure to pay all wages, 4) failure to comply with itemized employee wage statement provisions, 5) failure to pay all wages due at termination, 6) failure to timely pay wages during employment, 7) failure to reimburse business expenses, (8) PAGA based on the underlying factual allegations contained within the Operative Complaint and the PAGA Notice.
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.
