28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
SCHOOL STUDIOS, INC. STUDIOS, SCHOOL NATIONAL LIFETOUCH 1 through 50, Minnesota Corporation, and DOES and as private attorney general, herself onbehalf of KATYA SCHAEFER, Telephone: Los Angeles, CA 90067 2049 Century Park E. LLP KAPLAN ROBINS [email protected] 270317) (SBN Danas A. Glenn Facsimile:(415) 358- -6913 358 (415) Telephone: San 711 Van Ness Avenue, Suite 500 GROUP LITIGATION COMPLEX MORGAN & MORGAN [email protected] 187483) (SBN Appel N. Marie [email protected] Michael F. Ram (SBN 104805) CLASS ACTION COMPLAINT ACTION CLASS Attorneys for the Plaintiff C Plaintiff the for Attorneys Facsimile: (310)
Case 2:20-cv-07168Document1Filed08/10/20Pageof38ID#:1 94102 CA Francisco, v. , all others similarly situated,
( 310
Defendant Plaintiff, ) 229 -0130 552 CENTRAL DISTRICT OF CALIFORNIA OF DISTRICT CENTRAL - , 6293 5800 UNITED STATES DISTRI STATES UNITED
3400 Suite
.
,
lasses
a
s
Case No.:Case CLASS 5. 4. 3. 2. 1. 6.
Violation of Labor Labor of Violation Failure to Timely Pay Wages in 1194, 1197, 1197.1, and 1198; §§ Code Labor of Violation Failure to Pay MinimumWages in 1194.5; 1194, 510, 204, §§ Code Labor of Failure to Pay Overtime inViolation 1198; Violation of Failure to Provide Rest Breaks in 2001 512(a), 1198, and Wage Order 4- 226.7, §§ Code Labor of Violation Failure to Provide Meal Breaks in Failure to Reimburse Employees for
ACTION
COURT CT ; 2:20
- cv
- COMPLAINT Labor Code §§ 226.7 and 7168
Code §§ 204, 510; 510; 204, §§ Code
FOR 1182.12,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
violations committed against Plaintiffs, and othe aggrieved employee on behalf of the California Labor and Workforce Development Agency and each Act of 2004 (Cal. Lab. Code
CLASS ACTION COMPLAINT ACTION CLASS any time since the date four years prior to the filing of this Complaint. individuals who have worked for Lifetouch pursuantCali to fornia Code of Civil Procedure employees of Complaintbehalf on of Case 2:20-cv-07168Document1Filed08/10/20Page2of38ID#:2 2. 1. Plaintiff
Also, pursuant to the California Labor Code Private Attorney General General Attorney Code Private Labor California the to pursuant Also, Plaintiff Lifetouch National School Studios, Inc. (“Lifetouch”) as class claims
Katya Schaefer hereby allege the applicable civil penalties for Lifetouch for penalties civil applicable —the
bring herself s
the the §§
and a class of current and former non-exempt INTRODUCTION First 2698 2698
through et seq.
9. 8. 7. 10. 1
as an hourly employee inCalifornia at ), Plaintiffs seek to assess and collect— s
Violations of B of Violations ; 202 violation of Labor Code §§ 201 and all wages owed at termination in Failure to timely payemployees for 226.3 and1174 226, §§ Code Labor of Violation in Provide an Accurate Itemized Paystub 1174(d), 226(a), Code §§ Labor California Accurate Payroll Records Violation of Statements and Failure toMaintain Failure to Provide Compliant Wage Labor Code § § 2802; Code Labor BusinessExpenses Violation in of Code §§ 2698 et seq. 2698 §§ Code Attorneys General Act Private Under Penalties Civil 17200
Ninth follows: as
section r former and current employees,
et seq. CausesA of and 1198; and 382 ;
. The class includes all us. ;
&
ction inthis and
’s
P
Labor Code , Cal. Lab. , Cal. rof. Failure to
Code §§
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 following of Action for each of the Labor Code violations alleged in the First through Eighth Causes of CLASS ACTION COMPLAINT ACTION CLASS violation o violation sections 1194.5; 1194, 1198; and 2001; breaks in violation of Violation of Labor Code section business Code Labor expensesof inViolation sections Code& Prof. sections termination inviolationLabor of Code 1174; and 226.3 to provid v compliant wage statements and failure to maintain accurate payroll records in Labor Code 2698 §§ relief and restitution under Bus. & Prof. Code sections penalties penalties civil and , employer under applicable Ind Corporation registered to do business within the State of California and is an members; (2) Defendant Lifetouc in that:(1) 226.3, 226.6,558, Case 2:20-cv-07168Document1Filed08/10/20Page3of38ID#:3 iolation of California Labor Code
(2)failing toproviderest breaksviolation in of 3. 4. 5. .
1182.12, 1194, 1197, 1197.1, and 1198; e an accurate itemized paystub in violation sections Code of Labor
(3) failing to pay overtime inviolation sections Code of Labor
sections sections Code Labor f this action isa class action withmore than one hundred (100) class This class and private attorney general action The described conduct renders Lifetouch This Court has jurisdiction over this case under 28 U.S.C. 1332(d)(2) Lifetouch
(4) failing to payminimum wages in violation
(8) failing
1054, 1174.5,2699(a), 2699(f),and 2699.5,well as as injunctive et seq.
Labor Code sections 0 1720 ’s
violation JURISDICTION ANDVENUE JURISDICTION to timely pay employees for all wages owed at
as set forth in California Labor Code et seq. us trial Welfare Commission Orders; (3) Plaintiff and 204, 510; 510; 204, h s of
is and at all relevant times was, a Minnesota Minnesota a was, times relevant all at and is sections sections ; and (10) Liability and civil penalties under
California law: sections 2
(6) failing to reimburse employees f 226.7, 512(a), 1198,andWage Order 4-
226(a), 1174(d), and 1198, and failing 201 and201 202; (5) failing to timely pay wages in
Labor Code sectionsLabor (1) faili (1) 2802; liable for wages 17200
seeks relief for the
(7) failing to provide of LaborCode
ng toprovidemeal (9) et seq. Violations of Bus. Bus. of Violations
sections
, statutory
204, 510, 510, 204, 226
226.7 226.7 226, (e), or or
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 services.” directories, yearbooks, and memory books, offering multimedia production portraits. As an added service, the photography firm also publishes church smaller rival Olan Mills, takes baby, family, business, sports, and special events banner FLASH! Digital Portraits . Lifetouch, well photography studios located within J. C. Penney and Target stores nationwide, as giving rise to the claim occurred in this District. U.S.C.to 28 business in this District to subject it to personal jurisdiction herein; and (2) pursuant 1391(a)(1) inthat controversy exceeds the sum or value of all members of the Class are CLASS ACTION COMPLAINT ACTION CLASS Lifetouch profiles.lifetouch_inc.95cbd7e791c3bbc8232cf6e3f8e1cb44.html 1 portrait photographers, employee busine a subsidiary of Lifetouch, Inc., a Minnesota corporation with its principal place of including subsidiary pictures and yearbooks, through its Lifetouch stude retouch and take to levels Industrial Welfare Commission Orders. doing business within the State of California and is an employer under applicable Case 2:20-cv-07168Document1Filed08/10/20Page4of38ID#:4
https://www.dnb.com/business as some 15standalone locations in half a dozen states that operate under the 6. 8. 7. ss in Eden Prairie, Minnesota.
, Inc., 11 November 2019, D&B Hoovers, p. 6. 1 Plaintiff . To provide these services, Lifetouch hires numerous employees,
As relevant here, Lifetouch , Inc. Venue in this Court is proper: (1) pursuant According to its public corporate statements,“ Lifetouch section defendant , other aggrieved employees, 1391(a)(2) inthata substantial part FACTS RELATING TOLIFETOUCH
is,
and at all relevant times was, a Minnesota
Lifetouch National School Studios, Inc. does sufficient United States citizens; and (4) the matter in nt individual and class photographs, for class -directory/company -owned Lifetouch , Inc.
Lifetouch
$5,000,000, exclusive of interest and costs. 3
contracts with California schools at all Inc., Inc., National School Studios, Inc Studios, School National
and class members, for the position
whichsince late 2011 also owns National School Studios, Inc. Inc. Studios, School National -
to 28 U.S.C.to 28 of the eventsoromissions
runs about 700 700 about runs one of the largest US US largest the of one
; Onestop report,
Corporation section .
is
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 of photographer. CLASS ACTION COMPLAINT ACTION CLASS policies, to employees throughout California. company hiring of new employees, and communicating and implementing Lifetouch’s Human Resources (“HR”) department, which is responsible for recruiting and actually and responsible for the conduct alleged in this complaint and Plaintiff’s damages were school year. leading to substantial swings in number of photographers employed throu in time will vary, as Plaintiff is informed and believes its business is seasonal, limitations. The number of current employees Lifetouch has at any particular point unknown number of former employees who worked within the relevant statutesof approximately1,463 non -exempt employees throughout California, and an each andeach every other Doe Defendant. advance knowledge, acquiescence or within the course and scope of the agency,joint venture and employment with the Defendants Doe the and/or these Doe Defendants was the agent, joint venture Defendants. when when they are ascertained t sues these Doe Defendants by fictitious names. Plaintiff will amend this complaint sued herein Case 2:20-cv-07168Document1Filed08/10/20Page5of38ID#:5 o allege the true names and capacities of these fictitiously FACT 10. 9. 11. 10.
-wide policies, including timekeeping policies and meal and rest break
S RELATING TOLIFETOUCH’S
as Does 1 through 100, inclusive, (“Doe Defendants”) and therefore proximately caused by the conduct of the fictitiously named Doe Upon information and belief, Lifetouch maintains a single, centralized Plaintiff is Plaintiff Plaintiff is informed and believes and on that basis alleges that each of Plaintiff is ignorant of the true names and capacities of Defendants
informed and believe . Each of the fictitiously , and in doing the things hereinafter alleged, was acting acting was alleged, hereinafter things the doing in and ,
subsequent ratification of Defendants and and Defendants of ratification subsequent 4 s
that POLICIES ANDPRACTICES POLICIES r - late 2019 late of as and/or employee of Defendants named Doe Defendants is -named Doe Defendants , Lifetouch Lifetouch ghout the ha
d
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
CLASS ACTION COMPLAINT ACTION CLASS procedures in several documents provided at an employee’s time of California. Upon information and belief, Lifetouch set forth uniform policies and California, regardless of their photographer employees’ assigned locations within policies at the corporate level and implements them uniformly throughout written policies, including new policies. Upon information and belief, the usage of standardized documents and/or information and belief, received th e same standardized documents and/or written day. During the “ on the season. From law. California wage law, employment and personnel practices, and about the requirements of professionals, employees and advisors knowledgeable about Cali herein mentioned, Lifetouch was advised by skilled lawyers and other in California. employee’semployment ends. throughout the State of California, regardless of the manner in which each and belief, Lifetouch processes payroll for departing employees in the samemanner employees in California, irrespective of their wor issues the same formatted wage statements to all non-exempt, hourly employees, various locations and jobsites in California, including Plaintiff, aggrieved payroll for all non- payroll Case 2:20-cv-07168Document1Filed08/10/20Page6of38ID#:6 11. 15. 14. 13. 12. department at their corporate headquarters in Minnesota
and class members. Based upon information and belief, Lifetouch In particular, Plaintiff, aggrieved employees and class members, on The number of hours Plaintiff and other photographers work depends Plaintiff is informed and believes, and thereon alleges, that at all times Defendants continue to employ non-e Upon information and belief, Defendants maintain a centralized
busy exempt, hourly
December toMay, photographers work eight to nine hours per ” seasonof June toNovember,photographers frequently
- hire documents, indicate that Lifetouch dictates -paidemployees working for Lifetouch at their 5 k locations. Upon information xempthourly or , whichprocesses fornia labor and -paid employees
hire. -paid
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 they anymealrest and breaks to Plaintiff, including that photographers, available to answer questions from school officials. uninterrupted, as employees must all remain on site and are e breaks. If Lifetouch employees do receivemeal or rest breaks, such breaks are not take a compliant rest period. pay at their regular rates of pay when theywere not authorized and permitted to permitted to rest periods or did not receive payment of one (1) additional hour of Plaintiff, aggrieved employees and and classauthorized members not were pay when they were not authorized and permitted to take a rest period and that Wage Order or payment of one (1) additional hour of pay at their regular rates of were entitled to rest periods in accordance with the Labor Code and applicable IWC knew or should have known that Plaintiff, aggrieved employees and class members notreceivedid a timely, uninterrupted, thirty (30) minute meal period. payment of one (1) additional hour of payat their regular rates of pay when they aggrieved employees and class members were not provided with all meal periods or with timely, uninterrupted, thirty (30) minute meal periods and that Plaintiff, (1) additional hour of pay at their regular rates of pay when they were not pr were entitled to meal periods in accordance with the Labor Code or payment of one knew or should have known that Plaintiff, aggrieved employees and class members work between 10 to 18 hours per day, upto six days per week. CLASS ACTION COMPLAINT ACTION CLASS rest rest breaks, or only paying one premium per shift, regardless of how many this. Case 2:20-cv-07168Document1Filed08/10/20Page7of38ID#:7 breaks were missed Lifetouch has a policy of not paying
are 18. 17. 16. expected to, and frequently do
When Plaintiff is informed and believes, and thereon alleges, that Lifetouch Plaintiff is informed and believes, and thereon alleges, Lifetouch , in violation of California Labor Code sections Code Labor California of violation in , photographer
employees work shift , work, through their the schools schools the s ,and that any any 6 premiums for missed meal or rest are responsible for providing providing for responsible are s Lifetouch
Lifetouch in excess of
meal breaks and rest xpected to be
has no control over
has told employee eight ( eight
that Lifetouch
meal and/or 8 2 ) 26 hours, hours, , 226.7 226.7 , ovided
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 assigned shift, even if they work longer to unload shift. Employees are trained to sign in and out only for the hours indicated in their t shoots photo specifically loading/unloading, certain amount of time tocomplete all of the tasks required for their shifts, and/or employees to work off done off employees, - off were not receiving at least minimum wages for work that was required to be done were knew or should have known that Plaintiff, aggrieved employees, because all hours worked were not recorded. aggrieved at a lower rate than required by law. Plaintiff of remuneration, in the regular rate of pay. As a result, to the extent Lifetouch paid compensation, such as incentive pay, nondiscretionary bonuses, and/or other forms of pay for premiumwages because Lifetouch failed to include all forms of or rest periods, Lifetouch did not pay Plaintiff and class members at the correct rat one (1) additional hour of premium paymissed for or otherwise noncompliant meal 512 and CLASS ACTION COMPLAINT ACTION CLASS Case 2:20-cv-07168Document1Filed08/10/20Page8of38ID#:8 he allotted time isusually 30or 45 minutes at the beginning and at the end of each the entitled to receive at least minimumwages for compensation and that they 22. 21. 20. 19. -clock. In violation of the California Labor Code, Plaintiff, aggrieved endthe of day. . -
and class members premium pay missed for meal or rest periods, it did so the
employees,
andclass m -clock. , and preparing the site for the photo For instance, Lifetouch Plaintiff is informed and believes, and thereon alleges, that Lifetouch Plaintiff is informed and believes, and thereon alleges, that Plaintiff, Also, to the extent that Lifetouch did payPlaintiff and class members
and class members were not paid for all hours worked -the clock, without compensation, usuallyat the Lifetouch bu embers were not paid at least minimumwages for work
setting up/breaking downequipment usedat off ilds into each phot each into ilds
maintains 7
a policy of of policy a shoot equipment on arrival at a job site o Depending on the shift, shift, the on . Depending grapher’s shift only a frequently
and class members requiring beginning beginning - site e
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 overtime compensation” as required by California Labor Code employees have been denied, “the unpaid balance of the full am these employees for all Lifetouch 223, 510, 1194, and 1194.2. overtime), irrespective of how many over how of irrespective overtime), overtime itwould pay employees to “one point per day” (equal to two hours of driven, but willfully,knowingly, and intentionally failed to do so. incurred in performing their jobs, including for cell phone data plans and mile cover the costs and expenses Plaintiff, aggrieved employees and class members herein mentioned, that Lifetouch knew or should have known that it had a duty to section 1194, and Lifetouch is liable for civil penalties pursuant to California Labor Code work over eight (8) hours in a day and forty (40) were not receiving certain wages for overtime compensation. were entitled to receive certain wages for overtime compensation and that they knew or should have kn Code sections 204, 218.6, 223, 510, 1194, and 1194.2. the aggregate. This also violates employees’ rights to be paid wages, under Labor and that such rounding has a substantial negative effect employeeswork off otherwise prepare for departure. and to prepare the location, or to pack up all gear, clean up the jobsite, and CLASS ACTION COMPLAINT ACTION CLASS Case 2:20-cv-07168Document1Filed08/10/20Page9of38ID#:9 23. 26. 27. 25. 24.
2698 2698
rounds employee hours in increments including Also, Also, Plaintiff is informed and believes, and thereon alleges, For instance, Lifetouch had a practice of limiting the amount of As described above, Plaintiff is informed and believes, and thereon alleges, that Lifetouch et seq. Plaintiff is informed and believes, and thereon alleges, that
- the
the overtimecompensation due tothem own that Plaintiff, aggrieved employees, -clock, thereforeviolating
Lifetouch Lifetouch time hours an employee worked, and 8
fails to pay employees for this time its frequently hours Labor Labor
requires its photographers, to without paying without week, a in on employees’ wages, in Code Code 15 -
minute sections sections sections sections . As a result, the ount of . of ount
and class members
that at all times
increments, 204
204, 510, 510, 204, , 218.6, , 218.6, age
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page10of38ID#:10 equipment costs incurred. did not receive full reimbursement of applicable business- costs they incurred during the course and scope of their employment and that they were entitled to receive full reimbursement for all business-related expenses and knew or should have known that Plaintiff, aggriev ed employeeper day. despite having a written policy that allowed up to five hours of overtime pay per CLASS ACTION COMPLAINT ACTION CLASS example, reimbursement policy privacy, and other conduct designed to limit delaying reimbursement under it, by requiring employees to forego their right to under thecell phonereimbursement policyby employee reimbursement to employees, regardless of what a data plan might cost an apps, their phonesstream to music outdated equipment. In addition, photographers who photograph children equipme problems arise, phone to coordinate with other employees for a photo shoot, to contact the office if work employees forego due to privacy concerns. . For example, the lead photographer is required to use his or her personal cell so theso pho . 28. 29. 30. 31. For example, Lifetouch requires employees seeking nt, or to call tech support to be walked-
employeesmust use their personal . Lifetouch (often weighing more than 200 pounds) Plaintiff is informed and believes, and thereon alleges, that Lifetouch Lifetouch Lifetouch Lifetouch Lifetouch
to submit the first three to to shoot
access the Internet to get information regarding how to set up also discourages employees from seeking reimbursement
has a policy of providing only a $20 flat cell phone typically also will will requires employees to use their cars for work For .
proceed more easily. from their personal Spotify or othermusic
requires
pages of their cell phone bills, which some
its 9
employees to use their cell phone employees’use of the reimbursement cars to get keep through problems with older, often
ing its ing to eachto site employees, themselves andthe
related expenses and existence quiet, by the $20 cell phone . However, However, .
and class members -streaming often use s
for for
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page11of38ID#:11 could keep equipment overnight only if they to theLifetouch office first topick upthe not reimbursed for mileage from their Lifetouch only paid for mileage from itsoffice to CLASS ACTION COMPLAINT ACTION CLASS charged for any equipment monthor two , Lifetouch cell phone and vehic Lifetouch not Order, but willfully,knowingly, and intentionally failed to do so. payroll records in accordance with the Labor Code and applicable IWC Wage knewshouldor have known that they statements. employees, violation In law. of theCalifornia California Labor Code, Plaintiff, aggrieved were entitled to receive complete and accurate wage statements in accordance with knew or should have known that Plaintiff, aggrieved employees, Wage Orders. wage statements inaccurate Orders sections
always reimburse employees 33. 32. 36. 35. 34. also cause the wage statements Lifetouc 204, 218.6, 223, 510, 558,
’s . Lifetouch does reimburse employees for vehicle use, payment will typically take a fails to reimburse employees as required for business expenses such as
and class members were not provided complete and accurate wage
Lifetouch Even when Lifetouch does T Plaintiff is informed and believes, and thereon alleges, that Lifetouch Plaintiff is informed and believes, and thereon alleges, that Lifetouch
he wagehe statements and violat the reimbursement le usage in violation of California Labor Code 2802 section ’s es
failure to
fai California Labor Code
that was stolen, damaged or broke lure
to pay Plaintiff all fully or incompliance with California law correctly Lifetouch providesemployees its 1194,and 1194.2
had a duty tomaintain accurate and complete is often less than home to Lifetouch to home reimburse 10 equipment
list the number of hours worked on had a had secure garag h issues to its employees to be
sections sections the the employees wages due under theywould need . Employees and the applicable IWCWage school was was , 226
even if they had to drive
required. site
n. and 1194, and IWC for mileage, it does
e .
, and
and class members E mployees were Labor Code regularly fail t fail regularly
they Accordingly, Accordingly, were . W hen .
o
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page12of38ID#:12 statements. willfully failing to furnish its employee photographers with accurate, itemized wage worked. Therefore, Life inaccurately reflecting the number of overtime hours by inaccurately stating the hours include all required information, and were deficient in numerous ways, including CLASS ACTION COMPLAINT ACTION CLASS failure to comply with t also entitled to recover up to thirty (30) days of wages due to Lifetouch’s “ Pursuant to sections employ who are no longer employed by itall compensation due upon termination of the time employment was terminated. Lifetouch willfully failed to pay employees willfully failing to pay all compensation due and owing to all former employees at section Labor Code. compliant wage statements, and to pay timely compensation at termination. meal breaks, to provide rest breaks, toreimburse business expenses, to provide its failure to pay wages owe Photographer photographer During her Colorado resident. County totake student photographs at Los Angeles schools. headquarters. As part of Plaintiff 37. 38. 39. ment as required under California Labor Code 2698 2698
employment with Lifetouch, Plaintiff was Lifetouch has violated California Labor Code sections Additionally, Lifetouch separately Plaintiff et seq.
out in the field, but field, the in out in California from approximately
and isliablefor
, 203 and 256 of the Labor Code, former employees are now
FACTS RELATING TO PLAINTIFF TO RELATING FACTS Katya Schaefer he statutory requirements of touch d, to pay overtime, topayminimum wages, to provide
has violated California Labor Code section
its ’s duties, she was was photographer employees and worked, civil penalties
based in Lifetouch California Irwindale, ’s was 11
employed by Lifetouch
violated California Labor Code March
in addition to other remedies, for sent all throughout Los Angeles sections photographer employees
employed as a school sections ,
2019 Plaintiff currently isa ,
201 and 202 of the to
201 December as a a as
and 202 and 201
and 202 by 226 willful” , .
2019 (a) by .
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page13of38ID#:13
CLASS ACTION COMPLAINT ACTION CLASS during break. duties: she often had tofield questions from customers at the photo shoot site Even when she did have a meal or rest break, she was not re expected to, and frequently did, base pay rate. breaks. However paid for one premium per day, regardless of how breaks she missed. She was told by a Lifetouch manager began being paid onemissed break premium per day, irrespective of how many company told that she would have to prove her entitlement to them with records, despite the be paid the meal and rest break premiumsowed from the past several years was missed. shift to break down, amount of time worked specific photo shoot area, and to prepare the area or after her shift has ended to unload and load equipment, to bring equipment to the that the $20 flat cell phone reimbursem streammusic toentertain children with other employees, tocall the office during a photo shoot if needed, and to phone plan costs much more. Lifetouch 42. 41. 40. 43. 44. 45.
’
s responsibility tokeep such records. At first, Plaintiff was Plaintiff frequently work earn Plaintiff photographer, a As Pla Plaintiff Plaintiff
allots intifflearned that a , after
to to at the beginning of each shift to set up, and at the end of each
frequently was complete all of the tasks required for shift her Plaintiff asked her manager because
requiredto use her
work through her meal breaks, worked time off the clock before her shift began, she she not shewas photographing. Plaintiff only received ent provided by Lifetouch nother employee who asked whether she could often ed
paid
shifts far in excess of 8 hours, but wa 12 work
any
cell phone for work, to coordinate ed
ed premiumsmissed for
abou
. Plaintiff was many many
more than the 30 or 45 minutes , after about t $14.50 per hourasher usual, meal and rest that she could only be could she that lieved of all work work all of lieved , even though her cell
and rest breaks.
not paid for th for paid not three .
meal or rest
breaks she months
she she s e full
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page14of38ID#:14
CLASS ACTION COMPLAINT ACTION CLASS California Labor Code Labor California less than required. herof car, it her personal vehicle for work. When Plaintiff’s wages, in direct conflict with what she had been told. Moreover, b that employees could be earn and be paid up to five hours per day of overtime ultimately received a handbook, she learne handbook and was met with delays and excuses frommanagement; when she which equaled two hours of overtime. Plaintiff requested a company employee Orders. Plaint sections \ Lifetouch’sCalifornia. in required, was willful, and, on information and belief, is a consistent pra 201 and 203. Lifetouch’s failure to pay Plaintiff her final wages immediately, as final pay for between seven and 14 days, in direct violation of Labor Code sections were inaccurate and noncompliant, number of overtime hours regularly incorrectly listed the hours failingfor topay \ \ \ \ \ \ \ \ \ \ \
47. 46. 48. 49. 226
wage statements
Lifetouch typically Plaintiff also was not reimbursed fully, per California law, for use of Although Although After Plaintiff was laid off from Lifetouch, she did receivenot her and 1194,and iff was limited to overtime inthe amount of “one point per day,”
her
overtime did
Lifetouch failed to pay Plaintiff sections
so very late Plaintiff worked. Therefore, Plaintiff’s were inaccurate IWC
for some time 510
Wage Orders. provide
in violation of Labor Code section 226. , 558 and 1194, and applicable I actually worked by Plaintiff as well as the , Lifetouch
often aftermonth a two or d 13
d that the Lifetouch “official” policy was wage statements, the wage statements , Lifetouch was able was to Lifetouch , inviolation of California Labor Code all overtime wages due as required by
did
reimburse Plaintiff ,
and it wa it and wage statements ecause evade evade WC Wage WC
ctice of for theuse detection detection
s often
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page15of38ID#:15 Plaintiff a recover civil penalties for all of the Labor C the instant lawsuit. employed violations, described relevant statuteof limitations . employees of committed by Lifetouch allegations as though fully set forth herein.
CLASS ACTION COMPLAINT ACTION CLASS Agency 2020 former employees of of Civil Procedure has notice of curing any of the Labor Code violations described herein. The LWDA L letter is attached hereto as Exhibit A. including the facts and theories to support the alleged violations. the specific provisions of the codes alleged to be violated in this Complaint, WDA, and notice by certified mail to the Lifetouch
not respond not , Pla 53. 51. 50. 52. 54. 55.
(LWDA) intiff gave online notice to the Labor and Workforce Development
nd in California, pursuant to California Labor Code
Plaintiff has fully exhausted all administrative prerequisites to filing Code section Labor California Plaintiff Plaintiff More than More Plaintiff bring all othernon-exempt employees of Lifetouch Lifetouch ed , and
to Plaintiff’s notice FACTS RELATING TO PLAINTIFF AS A AS PLAINTIFF TO RELATING FACTS section Pursuant to California Labor Code section
in thisComplaint committed, by Lifetouch seeks to recover civil penalties for all of the Labor C reallege , on April 1, 2020, PRIVATE ATTORNEY GENERAL ATTORNEY PRIVATE
’s 65 days have passed since Plaintiff gave online notice tothe
with respect to Plaintiff as well as all other aggrieved
who have been employed inCalifornia 382 s
this case as a class action pursuant to California Code CLASS ALLEGATIONS s
on behalf of a class and incorporate
who have wor
.
notice by certified mail to the employer of 14
8 269 odeviolations, described here ked as photographers four within s
by reference all preceding
et seq. consisting . Lifetouch Lifetouch
authorizes Plaintiff to who who section
of: 2699.3 have been
A copy of the
with respect to
hasprovided no all current and within the the within
2699 , on
et seq. , April 11, ode ode
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page16of38ID#:16 class. Among the questions of law and fact common to the and predominate over any questions affecting solely individual members of the contrary to, or in conflict with, those act of the class . here of class, as Plaintiff and all other members of the provide substantial benefits to both the parties and the Court. impracticable throughout dispersed proposed class is sufficiently numerous and the class members are geographically Plaintiff class, or such other date as may be ordered, or amended, by the Court. years of the filing of this Complaint through the date an order is entered certify the CLASS ACTION COMPLAINT ACTION CLASS Lifetouch’s ion litigation
(c) (b) (a) 59. 58. 57. 56.
beli
and eve Plaintiff and the proposed class members; provide compensation for for compensation provide Whether Whether Plaintiff and the proposed class members; Common questions of law and fact exist as toall members of the class Lifetouch provide compensation for for compensation provide Whether Plaintiff will fairly and adequately protect the interests of the members Plaintiff Lifetouch The The . D
conduct in violation of the California la California the of violation in conduct s has including employment litigation. Plaintiff hasno interests thatare
ispositi class that the class numbers well
retained counsel competent and experienced incomplex class ’ California, California, s claims are typical of the claims of the other members of the Lifetouch Lifetouch Lifetouch
is so numerous that joinder of all memb all of joinder that numerous so is unlawfullyfailed toprovide unlawfullyfailed toprovide on
of the
implemented and engaged in a practice whereby implemented and engaged in a practice whereby implemented and engaged in a practice whereby making
class members’ claims ina class action will
of the other members of the class non non joinder of class members 15 - - compliant compliant ormissed in excessof 1,000 class compliant compl sustained damagesarising out or missed borlaws complained as of
iant class
rest breaks, or meal breaks, or ers is impracticableers
persons.
rest breaks,to meal breaks, to are: in one action is is action one in
.
The The
.
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page17of38ID#:17
CLASS ACTION COMPLAINT ACTION CLASS therebymaking final relief appropriate with respect to the action as a class action. Lifetouch substantial, is not great enough to enable themmaintain to individual suits against impractical. Further, the amount at stake for many of theclass efficient adjudication Prosecution of separate actions by individual members of the class damages to the class wrongdoing and will continue a course of action, which will result in further (d) (e) 61. 60. (f) (g)
. Without a class action, Lifetouch all wages ow Lifetouch Whether regular and overtimewages owed; Lifetouch Lifetouch A class action is superior to other availablemethods for the fair and Code, including but not limited to sections among otherthings , applicable provisions of the California Labor Whether theactsand practices of Whether Law codified in California Busine 351, 510, 512, 558, compliant Lifetouch including statutory Whether Code Labor California PAGA), 17200
et seq. .
of this controversy since joinder of all members is Lifetouch Lifetouch Plaintiff Plaintiff envision Plaintiff
hasacted o failed to pay Plaintiff and members of the proposed class for failed to pay Plaintiff and the proposed class members failed to provide Plaintiff and the proposed class members
wage statements; ed; , and the Private Attorneys General Act of 2004 (the
and the members of the class
penalties, pursuant tothe implemented and engaged in a practice whereby implemented and engaged in a practice whereby 1098, 1098, n grounds generally applicable to the entire class 1174, 1194, 1198, the Unfair Competition s
no difficulty inthe management of this 16
secti will likely retain the benefit of its Lifetouch ss and Professions Code
on on 2698 201
as all as
California Labor Code. Labor California et seq. class , 202, 204, 202, , 226,
areentitled todamages, eged hereinviolated,
members, while as a whole a as and ;
would create the the create would section .
226.7,
,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page18of38ID#:18 Brinker Rest. Corp. v. Superior Court, Under California law, first meal peri period may be waived bymutual consent of both the employer and the employee. total work period per day of the employee isnot more than six (6) hours, the meal employee with a meal period work for a period of more than five (5) hours per day without providing the 512(a) provides that an employermay notrequire, cause, or permit an employee to allegations as though fully set forth herein. the of the employer and the than twelve (12) hours, the second meal period may be waived bymutual consent pay at the employee’s regular rate, except that if the total hours worked is no more worksover ten provide a second meal period of not less than thirty (30) minutes if an employee 512(a), 1198 and the applicable IWCWage Order also require employers to thereof. with a ten-minute rest break for risk of inconsistent of risk CLASS ACTION COMPLAINT ACTION CLASS order of the Industrial Welfare Commission. employees to work during a meal period set forth by statute, regulation, standard, or class 63. 62. 64. 65. 66. (
sections sections Code, Labor California of Violations that would establish incompatible standards of conduct for Lifetouch .
At all relevant times herein set forth, California Labor Code section Plaintiff realleges The Wage Order also requires an employer to provide an employee At all relevant times herein set forth, Labor Code sections 226.7 and Labor Code section (10) hours per day or topay an employee one (1) additional hour of and
or varying adjudications with respect to individual members of WageOrder 4
employee only if the first meal period was not waived. ACTION OF CAUSE FIRST
of not less than thirty (30) minutes, except that if the and incorporate -each four 226.7 — -2001 ods must start after no more than five hours.
53 Cal. 4th 10 4th 53 Cal. prohibits employers from requiring - 17 hourwork period,or major
Labor Cod Labor Meal Period Violations) Period Meal s
by reference all preceding 04, 1041 04, e 226.7 section - 42 (2012). (2012). 42 , 512(a), 1198, 1198, 512(a), , 226.7
fraction fraction also
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page19of38ID#:19 and class members compliant meal periods in violation of California Labor Code breaks and meal period premiums towhich they are entitled. deliberately with oppression, fraud and malice to deprive its employees of the meal Code section Labor California regardless of how many breaks, or only paying one premium per shift personally not been not relieved of duty for an uninterrupted thirty Plaintiff has personally worked shifts over ten hours in duration in which she was which she was not relieved of duty for an uninterrupted thirty providing themwith compliant meal breaks, and that it is the schools has told employee photographers, including Plaintiff that they are expected to, and frequently do, work through their meal breaks. Lifetouch provide employees policy and/or break and record- employees who have not been provided with a timelymeal or rest break. requires an employer to paymandated premiums of an extra hour of wages to any CLASS ACTION COMPLAINT ACTION CLASS uniform policy photographer employees frequently are unable to take when/whether photographers may take breaks. A 72. 71. 69. 68. 67. 70.
its photographers
in California As a result, Lifetouch failed to provide Plaint At all times described herein, Lifetouch Plaintiffhaspersonally worked shifts over fivehours indurationin Since at least 2016, Lifetouch has maintained a uniform Labor Code section Lifetouch has a policy of ei
practice with regard to meal breaks for all of its photographer
and/or practice keeping requirements of the Wage Order.
paid premiums for missed meal breaks. . Lifetou . meal and rest with with
, when employees work shifts 226.7 compliant 1198 ch ch has failed, and fails, to maintain and 512.
breaks were missed, in violation of requires that Lifetouch ther not paying premiumsmissed for meal 18 for meal and rest breaks combined,
-
minute meal break. Plaintiff has breaks. Rather, under Lifetouch under Rather, breaks. s a result of th of result a s
has acted willfully and uninterrupted it is not responsible for for responsible not is it iff, aggrieved employees
in excessfive of hours, - comply with themeal minute meal brea is
policy, policy, meal breaks. , a
that unlawful policy
dictate
to meal k. k. ’ s
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page20of38ID#:20 work daythat themeal (1) additional hour of pay at the employee’s regular rate of compensation for each employees, California sections 226.7 and 512 and failed to pay the full meal period premiums due. CLASS ACTION COMPLAINT ACTION CLASS per all duties control over how employees spend their break time, and relieve their employees of 226.7 and the applicable IWC Wage Order, an employermust “relinquish any obligation to authorize and permit rest periods under California La mandated by an applicable order of the California IWC. To comply with its provided total daily work timeis less than three and one (10) minutes net rest time per four (4) hours or major fraction thereof” unless the the “rest period t which insofar as practicable shall be in the middle of each work period” and that that “[e]very employer shall authorize and permit all employees totake rest periods, aggrieved employees, and class members’ employment by Lifetouch. and California Labor Code sections 226.7 and 1198 were applicable to Plaintiff, andherein each iod, in short, must be a period of rest.” Augustus v. ABM Security Services, Inc. 73. 70. 69. 68. 67.
that no employer shall require an employee to work during any rest period
––
Labor Code sections 226.7, 512(a), and 1198. Plaintiff, aggrieved
and class members are therefore entitled to recover from Lifetouch one
Lifetouch’s conduct violates the applicable IWCWage Order, and including the obligation that an employee remain on call. A rest At all relevant times, Californi times, relevant all At At all relevant times,the applicable IWC Wage Order has provided At all relevant times herein set forth, the applicable IWC Wage Order Plaintiff incorporates by reference and re
(Violation of California Labor Code Code Labor California of (Violation every allegation set forth above. imeshall be based on the total hours worked daily at the rate of ten period was not provided, plus interest and attorneys’ fees. and 1198 and ACTION OF CAUSE SECOND
— Rest Break Violations) 19 has has 226.7 Code section Labor a -half (3½) hours.
-alleges as if fully stated sections sections
226.7 bor Code section
,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page21of38ID#:21 Lifetouch Plaintiff’s experience ismirrored by other Lifetouch photographers in California. all three 10-minute uninterruptedrest periods. most days during the “busy season” of June through November, without receiving has told employee photographers, including Plaintiff they are expected to, and frequently do, work through their meal breaks. Lifetouch uniform policy and/or provide its photographers with compliant rest breaks. Rather, under Lifetouch’s employees in California. Lifetouch has failed, and fails, to maintain a policy to policy authorized and permitted. their regular rates of pay f members are ent Plaintiff 226.7(b), Code section Labor California Cal.2 5th 257,269 -70 (2016). Pursuant to the applicable IWC Wage Order and CLASS ACTION COMPLAINT ACTION CLASS worked shifts of shiftssix of hours or more,or Plaintiff and class members totake regardless of whether the including byresponding work to aggrieved employees and class members perform work during any periods of rest, breaks, free from the employer’s control photographer employees fr rest may take photographers when/whether providing themwith comp liant rest 71. 73. 72. and/or practice with regard to rest breaks for all of its photographer
therefore Since at least 2016, Lifetouch has maintained a uniform, unlawful Moreover, Lifetouch had no policy for scheduling and authorizing During the relevant time period, Lifetouch required that Plaintiff, itled torecover from Lifetouch ten ( failed to relieve Plaintiff and class members of all duties during 10)
practice,when employees work shifts inexcessfive of hours, ywere on their 10 hours or more. Plaintiff worked or each work day that a compliant
equently are unable to take timely, uninterrupted rest
third 10 -related questions fromLifetouch’s customers second 10-minute uninterrupted rest breaks for breaks, and that it is the schools that dictate -minute uninterruptedre .
20 - breaks. As a result of this policy, minuterest periods. On informationOn and one (1) additional hour of pay at , aggrieved employees, ,
that it is not responsible for ten ( rest period was not st periods when they 10
) hours belief
and class class and or moreor on .
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page22of38ID#:22 labor fixed by the commission shall be the . . . standard conditions of labor for requires 1198 that Code section Labor , California under conditions of labor that are prohibited by the applicable wage order. allegations as though fully set forth herein. period was not authorized and permitted. employee’s regular rate of compensati therefore entitled to recover from Defendants one (1) additional hour of pay at the California Labor Code sections 226.7 and 1198. Plaintiff and class members are lower rate than required by law. Plaintiff and class members premium pay missed for rest periods, itdid so at a remuneration, in the regular rate of pay. Asa result, to the extent Lifetouch such as incentive pay, nond for Lifetouch periods, Plaintiff and class m authorized and permitted. Alternatively, tothe extent that Lifetouch and/or policy of not paying rest period premiums owed when rest periods are not without receiving all ten (10) minute rest periods to which theywere entitled. in excess of 3.5 hours, inexcess ( of six Plaintiff Thus, periods. rest rest periods and thereby failed to authorize and permit them totake uninter CLASS ACTION COMPLAINT ACTION CLASS premium because wages Lifetouch 75. 74. 75. 74.
(V Labor Code section 1198 makes it illegal to employ an employee Plaintiff realleges Defendan Defendants have also engaged in a systematic, company iolation of iolation
did not pay Plaintiff and class members at the correct rate of pay embers one (1) additional hour of premiumpay for ts’ conduct violates the applicable IWCWage Order and
Failure to Pay Overtime Wages) Labor Code THIRD iscretionary bonuses, and/or other forms of , aggrieved employees
and incorporate
ACTION OF CAUSE on for each work day that a compliant rest
sections failed to include all forms of compensation, 6
) 21
hours,and/or excess in of
s 204
by reference all preceding
“ and class members worked shifts [T] , 510 , he standard conditions of — 1194.5 1194, ,
ten ( did pay did wide practice-wide
missed rest
10 rupted rupted ) paid paid hours hours
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page23of38ID#:23 was (8 eight workweek, at the rate of time and one working more than eight (8) hours in a day or more than forty (40) hours in a is and was weekly basis. rate of pay, depending on the number of hours worked by the person on a daily or them at a rate of payeither time hours in a daymore or than forty (40) hours in a workweek without compensating Order provide that it is unlawful to employpersons working more than eight (8) discretionary bonuses and incentive pay. remuneration for employment paid to, or on behalf of, the employee, including non- times their regular rate of pay.An employee’s regular rate of pay includes all more than twelve (12) hours in a day, overtime compensation at a rate of two (2) prohibi employees. The employment of any employee . . . under conditions of labor CLASS ACTION COMPLAINT ACTION CLASS seventh (7th) day of work. excess of twelve (12) hours in a day or in excess of eight (8) hours in a day onthe compensation at twice the employee’s regular rate of pay for hours worked in first eight (8) hours worked on the seventh ( worked in excess of eight (8) hours in a day or forty (40) hours in a week or for the compensation at one and one overtime wages owed toPlaintiff, aggrieved employees and class members. During
required to pay Plaintiff 78. 77. 76. 79. 80. ted by the order is unlawful.” ) hours in a daymore or than forty(40) hours in a workweek.
required to pay Plaintiff The applicable IWC Wage Order further provides that Lifetouch is and Specifically, the applicable IWC Wage Order provides tha Labor California California Labor C Labor California During the relevant time period, Lifetouch willfullyfailed topayall
, aggrieved employees, aggrieved , -
half (1½) times the regular rate of pay for hours Code section 1198 and the applicable IWCWage -and ode section 510 codifies the right to overtime , aggrieved employees -one
- half (1½) for all hours worked in excess of
- -times two or half that person’s regular 22 7th) day of work, and to overtime
and class members working and class members
t Lifetouch Lifetouch t
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page24of38ID#:24 the relevant time period, Plaintiff, aggrieved employees, CLASS ACTION COMPLAINT ACTION CLASS employees to work off the clock, including but not limited to much of the time overtime re than rate forms of pay, Lifetouch failed to pay all overtime wages by paying a lower aggrieved employees and class members worked overtime and received these other calculating the overtime wage rate. Therefore, during times when Plaintiff, remuneration, into the calculation of the regular rate of pay for purposes including incentive pay, nondiscretionarybonuses, and/or other forms of the California Labor Code, Lifetouch failed to incorporate all compensation, photographers entered photos and were paid a cash prize. However,in violation of other forms of remuneration employees and class members incentive pay, nondiscretionarybonuses, and/or generated. In addition to an hourly wage, Lifetouch paid Plaintiff, aggrieved class members the correct overtime rate for the recorded overtime hours that they the overtime hours they actually worked. aggrieved - off of eight (8) hours a daymore or or forty (40) hours a week or more, some of this Plaintiff Because paid. not their shifts, and were suffered or permitted to perform work for which they were members were performing work off company (40) hours in a week, because all hours worked were not recorded. hours in a day, inexcess of twelve (12) hours in a day, and/or in excess of forty not paid overtime premiums for all of the hours they wor the 83. 81. 82. -clock work qualified for overtimepremium pay.Therefore, Plaintiff -wide pra
employees, Moreover, Lifetouch knew or should have known that as a result of these Furthermore, Lifetouch did not pay Plaintiff, aggrieved employees and ctices and/or policies, Plaintiff quired.
and class members wer Lifetouch had a policy and/or practice of requiring , aggrieved employees
such as, for example, periodic contests where - the -clock on their off 23
e not paid overtime wages for all of , aggrieved employees and class members worked shifts
and class members were ked in excess of eight (8) -days and before and after
and class of of ,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page25of38ID#:25 meal and rest break requirements, Plaintiff that would have been required had all time worked been captured. Plaintiff, aggrieved employees and class members not receiving overtime wages shift ended. Failure to spent loading equipment in before a shift began or loading equipment out after a CLASS ACTION COMPLAINT ACTION CLASS been on overtime compensation for any work day or week where they are deemed to have members week, it will, in many instances, put Plaintiff, aggrieved employees and class of law to be “on duty.” members have not been compensated for all of the time they are deemed as a matter Plaintiff result of Lifetouch’ deprived of their rightfully earned overtime compensation as a defined by the applicable wage order as “the time during which an employee is wage less than the minimum so f by the IWC isthe minimum wage to be paid to employees, and the payment of a 1197, 1197.1, and 1198 have provided that the minimum wage for employees fixed such amounts, plus interest thereon, attorneys herein each and every allegation set forth above. 84. 85. 86. 8 8 8 7 (Violation of California Labor Code Code Labor California of (Violation , aggrieved employees, dutymore for than eight or forty hours, respectively. . .
over the threshold for overtime pay,meaning that they are entitled to Also, Also, When this time isadded to the work they performed dur Plaintiff At all relevant times, California Labor Code sections 1182.12, 1194, 1194, 1182.12, Code sections Labor California times, relevant all At Plaintiff incorporates by reference and re 1197.1, b s policies and failure and failu y virtue of the previously alleged violations California of , aggrieved employees, capture this additional time spent working contributed to
and 1198 and ACTION OF CAUSE FOURTH
and the class ixed is unlawful. Compensable work time is Unpaid Minimum Wages) Minimum —Unpaid 24 , aggrieved employees
and the class members are entitled to recovery of ’
fees andfees costs. sections sections
re
to pay this -alleges as if fully stated 1182.12
members have been
direct and proximate compensation. , 1194, 1197, 1197, 1194, , and the class the and
ing a day, or or day, a ing ’ s
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page26of38ID#:26 1197, 1197.1, and 1198. members worked off overtime overtime overtime Plaintiff, aggrieved employees and class members This is usually notenough time toa minutes at the beginning of each shift, and 30 or 45 minutes at the end of each shift. for the photo shoot. Depending on the shift, the allotted time isusually 30or 45 up/breaking down equipment used a of the tasks required for their shifts, specifically loading/unloading, setting each photographer’s shift only a certain, inadequate amount of time tocomplete all compensation, usually at the beginning and/or end of the day.Lifetouch builds into maintains a policy of requiring employees to work off tit. 8, section suffered or permitted to work, whether or not require subject to the control of an employer, and includes all the time the employee is CLASS ACTION COMPLAINT ACTION CLASS practice led to substantial underpayment of wages to Lifetouch employees. compute the hours worked which rounded the entered time tothe nearest 15 minute increment and did not clean up the jobsite, and otherwise prepare for departure. equipment on arrival at a job site and to prepare the location, or for the hours indicated in their assigned shift, even if they work longer to unload 93. 92. 91. 90. 8 9 .
wages wages
minimumwages violates California Labor Code sections 1182.12, 1194, - the Lifetouch’s failure to pay Plaintiff, aggrieved employees, Lifetouch didpay notminimum wagesfor off In addition, employees entered their time using an ADP application Lifetouch photographer employees are trained to sign in and out only During the relevant time period, Lifetouch maintained and still (2)(G)11070 (defining “Hours Worked”). -clock in violation of California Labor Code sections 1182.12, 1 , Lifetouch did not pay at least minimum wages for those hours . To the extent that these off
based on actual time entered. In the aggregate, this
ccomplish the required tasks. t off - site photo shoots, and preparing the site 25 -the -clock hours did not qualify for performed d to do so.” Cal. Code. Regs. -the
-clock, without -
the
that qualified for -clock to packallup gear, work
and class
that that
194,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page27of38ID#:27 his or her job. The purpose of Labor of Code purpose The section job. her or 2802his is to prevent employers necessary expenditures and losses incurred by the employee inthe performance of provided and provides that an employermust reimburse employees for all allegations as though fully set forth herein. penalties as set forth in California Labor Code sections section 204. employees the foregoing wages as required by the Wage Order and Labor Code premium pay wages for missed meal and rest breaks, and overtime exempt employees have earned, but not been paid, wages for off the clock work, twice in each calendarmonth. allegations as though fully set forth herein. Code Code equa Plaintiff and class members are entitled to recover liquidated damages in an amount 1197, 1197.1, and 1198. Pursuant to California Labor Code section 1194.2, CLASS ACTION COMPLAINT ACTION CLASS l to the wages unlawfully withheld, and interest thereon. section 93. 92. 90. 89. 88. 87. 91.
At all times herein set forth, California Labor Code section 2802 has Plaintiff realleges At all times relevant hereto, Lifetouch At all times relevant hereto, as described herein,Lifetou Labor Code section Plaintiff This conduct This 1198 (Violation of California Labor Code Code Labor California of (Violation Violation of Labor Code sections Code Labor of (Violation . The described conduct renders Lifetouch realleges
Unpaid Business , in addition, constitutes violations of California Labor Labor California of violations constitutes addition, in , Failure to Timely SIXTH F IFTH
and incorporate and incorporate 204
ACTION OF CAUSE ACTION OF CAUSE
requires that all wages are due and payable 26 -
Related Expenses)
P s s ay
by reference all preceding by reference all preceding W
has age 204 section section 558 failed s )
— 510 , , 2699, and 2699.5.
to payits non- liable for civil
2802
wages — ch 's non .
exempt -
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page28of38ID#:28 of requiring Plaintiff, aggrieved employees and class members to utilize their own failed to personal cellular phones to communicate about work-related matters, Lifetouch required Plaintiff, aggrieved employees and other class members to utilize their bills, which some employees forego due to privacy concerns. Although Lifetouch $20 cell phone reimbursement to submit the first three pages of their cel outreal reimburse photographeremployees flata amount$20, of irrespectivewhat of their whom get contact the officequestions if arose, to search for personal cellular phone to coordinate with other employe related cellular phone expenses. For example, Plaintiff was required to use her business operations, but failed to reimburse them for the full costs of their work personal cellular phones and/or cellular required that Plaintiff, aggrieved employees, instance,For during the relevant time period, Lifetouch, on a company failing to reimburse its photography employees for their business-related expenses. tools and equipment customarily required by the trade or craft.” the minimum wage provided herein may required be to provide and maintain hand by the employer, except that an employee whose wages are at least performance of a job, such tools and equipment shall be provided and maintained that: “When tools or equipment are required by the employer or are necessary tothe Or IWCWage order, wage applicable The (2014). 1144 employees. Cochran v. Schwan’s Home Service, Inc. from passing off their cost of doing business and operating expenses on to their CLASS ACTION COMPLAINT ACTION CLASS information
95. 94. she was photographing was she - o fully reimburse them for their expenses.
f- pocket costs are. Moreover, Lifetouch requires employees seeking the At all times relevant hereto, Lifetouch also had a company Lifetouch violates Labor Code section 2802 by having failed, and about about equipment
. Lifetouch’s policy has been, and c setup, and to streammusic to phone data to carry out Lifetouch’s 27
and class members use their own
information , 228 Cal. App. 4th 1137, der 4 der es for a photo shoot, to - using the Internet to 2001, ¶9(B) provides provides ¶9(B) 2001, entertain children children entertain ontinues tobe,to two (2) times -wide basis, -wide policy l phone -
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page29of38ID#:29 pay. inclusive dates of the pay period, total hours worked, and all applicable rates of limited to, the name and address of the legal entity that is the employer, the accurate and complete itemized wage statement in writing, including, but not 226(a) provides that every employer shall furnish each of his or her employees an allegations as though fully set forth herein. shoot site with the equipment, and afterward to bring photographic equipment. Then she is required to use her car to get to the photo typically required to use her car to drive to the Lifetouch office to pick up the personal vehicles for work purposes. For instance, before her work day, Plaintiff is CLASS ACTION COMPLAINT ACTION CLASS operating costs to Plaintiff, aggrieved employees, including mileage. aggrieved employees, or class m the Lifetouch office and scope of their employment, plus interest. recover from Lifetouch their business- Lifetouch deprive their employees of the employees’ acted At all 2802. times Code section described Labor herein,California Lifetouch (
Violation of California Labor Co Labor California of Violation willfully, 99. 98. 96. 97.
’ s profits. At all relevant times herein set forth, California Labor Code section Plaintiff realleges Lifetouch’s company Plaintiff, aggrieved employees,
and deliberately with oppression, fraud and malice to unlaw Failure to Maintain Accurate Payroll Records)
. However, Lifetouch frequently failed to reimburse Plaintiff, Non SEVENTH - Compliant WageStatements and
and incorporate e mbers -wide policyand/or practice of passing on their ACTION OF CAUSE related expenses incurredduring the course
de de fully or timely for all costs of travel, 28
own personal resources in furtherance of
sections sections
and class members are entitled to
s
by reference all preceding
and class members violates 226
all o all — 1198 and 1174(d), (a), f the the f equipment back to fully
has
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page30of38ID#:30
CLASS ACTION COMPLAINT ACTION CLASS 226(a)(5), and 226(a)(9). Specifically, Lifetouch violated sections Labor Code sections 226(a)(1), 226(a)(2), of pay, and the corresponding number of hours worked at each hourly rate. all applicable hourly rates in effect during the fail to correctly list: gross wages earned; total hours worked; net wages earned; and uniform wage statements to Plaintiff, aggrieved employees and class members that incomplete, and inaccurate wage sta provided Plaintiff, aggrieved employees, loading in and loading out of jobs, resulting in frequent off Plaintiff rates of pay for premiumwages, i in effect during the pay period, namely, correct overtime rates of pay and correct section 226(a)(5). Lifetouch wages earned by Plaintiff 226(a)(1). Plaintiff overtime, employees’, or 226(a)(9). acc 226(a)(2)), correct amount of net wages earned (Labor Code section section class members containing the correct amount of gross wages earned (Labor Code Lifetouch urate number of hours worked at each hourly rate (Labor Code section 100. 101. 102. 99.
, aggrieved employees , aggrieved employees and class members in compliance with section 226(a)(1)),accurate totalsthe of hoursworked (Labor Code
Lifetouch didfurnish not wage statementsPlaintiff to
For the same reason, Lifetouch At all relevant times,Lifetouch has knowingly and intentionally Because Lifetouch Because California Labor Code section 1198 provides that the maximumhours Additionally, because Lifetouch
class members’ regular rate did not list the correct amount of gross wages earned by , ag ,
grieved employees and class members in violation of also failed to correctly list all applicable hourly rates and class members when they completed mandatory
failedto trac n violation of section 226(a)(9). tements. For example, Lifetouch issued
and class members with uniform, 29 failed to list the correct amount of net s
of pay correctly for purpose k and record all hours worked by did not calculate Plaintiff’s, aggrieved pay period, including overtime rates , aggrieved employees aggrieved , and -the - clock work,
section 226(a)(5)), or s of payings of
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page31of38ID#:31 with Lifetouch aggrieved employees California period and Lifetouch meal times, period. relevant all At keep a unlawful.” Pursuant to the applicable IWC Wage Order, employers are required to those fixed by the order or under conditions of labor prohibited by the order is further provides that “[t]he employment of any employees for longer hours than Commissioner and as set forth in the applicable IWCWage Orders. Sect of work and the standard conditions of labor shall be those fixed by the Labor CLASS ACTION COMPLAINT ACTION CLASS records meal of result of failing to record the off class me failed to maintain accurate payroll records for Plaintiff, aggrieved employees and relevant times, and in violation of Labor Code section 1174(d), Lifetouch willfully paid to, employees employed at the respective plants or establishments paid to, and the number of piece are employed, payroll records showing the hours worked daily by and the wages central location in the state or at the plants or establishments at which employees addresses of all employees employed and the ages of all minors” and “[k]eep, at employinglabor in this state shall Labor Code section penalty notexceeding four thousand dollars ($4,000) per employee pursuant to failure to comply with California Labor Code section 226(a), or an aggregate recover from Lifetouch the greater of th eir actual damages caused by Lifetouch’s
30 100. 101. ccurate time records showing when the employee begins and ends each work -minute meal periods to whic mbers showing the daily hours they worked and the wages paid thereto as a ’ , to keep records of meal period start and stop times for Plaintiff s
failure to provide Plaintiff California Labor Code section 1174(d) provides that “[e]very person Plaintiff, aggrieved employees and class members are entitled to
start and end times 226(e). and class members in violation of section 1198. Because of
-the -rate units earned by and any applicable piece rate . [k]eep a record showing the names and for such meal periods. - h they were entitled, Lifetouch also clock hours that they worked. , aggrieved, employees 30
failed, company
members members class and . ” At all kept no -wide in ion 1198 , a
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page32of38ID#:32 allegations as though fully set forth herein. discharge, or within seventy minimum wages and meal and rest period premiumwages, either at the time of and unpaid wages set forth above, including but not limited to, overtime wages, employees pay which case the employee isentitled to his or her wages at the time quitting. of given seventy payable not later than seventy voluntarily leaves his or her employment, his or her wa at the time of discharge are due and payable immediately, and that if an employee provide that if an employer discharges an employee, the wages earned and unpaid
CLASS ACTION COMPLAINT ACTION CLASS a the time requirements set forth in Labor Code sections 201 and 202. For example, employees their final wages on the next regular pay cycle, instead of adhering to statutory penalty wages for each day they were not paid, at their regular rate of pay, employees, Lifetouch at the time of discharge, or within seventy members who are no longer employed by Lifetouch Plaintiff laid off
until (Violati 106. 104. 103. 105. 107. onetwoto weeks later ’ s
and class members who are no longerempl oyed by Lifetouch
and class members are therefore entitled to recover from Lifetouch employ, vi on of Labor Code sections In addition Lifetouch , At all times relevant herein set forth, Labor Code sections 201 and 202 Plaintiff realleges Lifetouch has Lifetouch’s -two (72) hours previous notice of his or her intention to quit, in P ay on Employees for all W approximately olates Labor Code sections 201 and 202. Plaintiff 202. and 201 sections Code Labor olates ’ failure to pay Plaintiff a company -two (72) h
EIGHTH two (72)-twohours thereafter, unless the employeehas and incorporate , on December 9 or 16. willfullyfailed topayPlaintiff December -wide practice or policy of paying departing ACTION OF CAUSE oursof their leavingLifetouch’ ages 201 31 -two (72)
, 202 and 203—Failure to Timely O s
2,
wed at T at wed , aggrieved employees by reference all preceding
2019, hours of their leaving their wages earned and unpaid
ges shall become due and would would ermination not , aggrieved
receive )
s and class ’ employ. , aggrieved the earned
her her
final the the
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page33of38ID#:33 Proceduresection 1021.5. important rights affecting the public interest within the meaning of Code of Civil result of Lifetouch’ to the general public. Plaintiff has suffered injury infact and has lost money as a up to a thirty (30) daym CLASS ACTION COMPLAINT ACTION CLASS following respects: case, Lifetouch et seq. Busine law, and constitute unlawful business acts and practices in violation of California unfair, company, and/or association. Professions Code sections 17201, as it is corporation, firm, partnership, joint stock allegations as though fully set forth herein.
(a) 108. ss & Professions Code sections 17200, seq et may be predicated on the violation of any state or federal law. unlawful,
(Violation of Business and Professions Code section
- non Requiring rate of pay for purposesrate payfor of of overtime rate thanrequired bylaw byfailing to properlycalculate theregular Plaintiff Order, IWC applicable the and 1198 and 510 sections Code paying themproper compensationin violati aggrieved employees A violation of California Business & Professions Code sections 17200, Lifetouch Lifetouch’s conduct, as alleged herein, has been, and continues to be, Lifetouch is a “person” as defined by California Business & Plaintiff realleges ’ s
and harmful to Plaintiff, aggrieved employees, class members, and policies and practices have violated state law in at least the
s
unlawful business practices. Plaintiff seeks toenforce , aggrieved employees ’ s
aximum pursuant to California Labor Code section 203. activities, as alleged herein, are violations of California
exempt, hourly
NINTH and incorporate
and class members, to work overtime without
ACTION OF CAUSE 32
- paid employees, including Plaintiff including employees, paid and class members overtime at alower s
by reference all preceding , as alleged herein; .
on of CaliforniaLabor 17200
In the instant
et seq et and paying and paying .)
,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page34of38ID#:34
CLASS ACTION COMPLAINT ACTION CLASS was performed. sixteenth (16th) and the twenty wages due upon termination of an employee, are due and payable between the (1st) and the fifteenth (15th) days, inclusive, of any calendar month, other than those provides (b) (g) (f) (e) (d) (c)
that all wages earned by any person in any employment between the first
Failing to reimburse Plaintiff reimburse to Failing Plaintiff provide to Failing Order, as alleged herein; IWC applicable the and 1198, 226.7, Code sections Labor California membersto take F Failing to pay at least minimum wage to Plaintiff Failing timely to pay all earned wages Failing toauthorizeand permit Plaintiff for all business expenses necessarilyincurred inviolation of California as IWC Order, applicable the and 204 section Code Labor California of inviolation members class and herein; alleged as Order, IWC applicable the and 1198, 1174(d), 226(a), sections Code Labor California of violation in records with accurate wage statements and failing to maintain accurate payroll Order, as alleged herein; IWC applicable the and 1198, 512(a), 226.7, sections Code Labor aggrieved employees herein; alleged as Order, IWC applicable the and 1198 and 1197.1, 1197, 1194, 1182.12, sections Code Labor California of inviolation members class and Labor Code sections 2802, as alleged herein. alleged as 2802, sections Code Labor At all times relevant herein, Labor Code section 204 has providedand ailing to provide uninterrupted provide to ailing
compliant, -sixth (26th) day of the mont
and class members in violation of California California of violation in members class and
, aggrieved employees aggrieved , uninterrupted rest periods in violation of 33 , aggrieved employees, aggrieved , , compliant set forth above forth set to Plaintiff to , aggrieved employees meal periods to Plaintiff to periods meal
h during which the labor ; aggrieved, employees , aggrieved, employees and class members and and
and class members
and class ,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page35of38ID#:35 the time periods specified by California Labor Code section 204. overtime wages,minimum wages and meal and rest period premium wages, within aggrieved employees closethe of payrollperiod. payroll if the wages are paid not more than seven (7) calendar days following the deemed satisfied by the payment of herein, Labor Code section 204 provides that the requirements of this section are the payday for the next regular payroll period. Alternatively, at all times relevant wages earned for labor in excess (1st) and the tenth (10th) day of the following month. wages due upon termination of an employee, are due and payable between the first sixteenth (16th) and the last day, inclusive, of any calendar month, other than those provides CLASS ACTION COMPLAINT ACTION CLASS \ Procedure section 1021.5 and other applicable laws; and an aw members; and an award of attorneys’ fees pursuant to California Code of Civil to pay all outstanding wages due to Plaintiff, aggrieved employees and class years prior to the filing of Lifetouch this complaint; requiring injunction a permanent the wages withheld and retained by Lifetouch during a period that commences four seq. unlawful business acts and practices alleged herein. aggrieved Lifetouch unlawfully gained an unfair advantage over other businesses. Plaintiff, \ \
, Plaintiff, aggrieved employees and class members are entitled to restitution of
that all wages earned by any person in any employment between the employees,
At all times relevant herein, Labor Code section 204 has providedand Pursuant to California Business & Professions Code sections 17200 et As a result of the violations of California law herein de At all relevant times herein Lifetouch , At all times relevant herein, Labor Code section 204 provides that all and cl
and class members have suffered pecuniary loss by Lifetouch’s
ass members all wages due including, but not limited to,
of the normal work period shall be paid no later than
wages for weekly, biweekly, or semimonthly 34
willfully failed to pay Plaintiff
ardcosts. of
scribed,
,
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page36of38ID#:36
CLASS ACTION COMPLAINT ACTION CLASS Labor Code section 2699.3. Studios School California Labor Code was committed. former employees of allegations as though fully set forth herein. presc written notice of cure by June 15, 2020, 65 calendar days April 11, 2020 , as intention to investigate the allegations set forth in Plaintiff's2020 1, April and and Workforce Development Agency by online submission GeneralAct2004 of (the seeks recovery of civil penalties as prescribed by the Labor Code Private Attorneys sections 2699, 2699.3, and 2699.5. Plaintiff, as an aggrieved employee, hereby statutory penalties as a result of such conduct as set f 201 applicableCalifornia LaborCode sections, including butlimited not sections to ; and phones failure cell and tocars timely wage statements to employees; and failure toreimburse employees for use of their failure to pay regular and overtime wages; failure to maintain and provide accurate compensation for missed rest breaks; failure to pay employees for all hours worked; compensation for missed meal breaks; failure to provide rest breaks, or provide unlawful because , on April 1, 2020, 1, April on , - 204, 226, 226.7, 351, 510, 512, 1051, 1052, 1174, 1194, and gives rise to ribed byCalifornia Labor Code section 2699.3(a)(2)(A). 109. 112. 111. 110.
Plaintiff realleges and incorporates by reference all preceding Plaintiff has not received written notification by the LWDA of an On The policies, acts and practices heretofore described were and are (Civil Penalties Under Private Attorneys General Act, Act, General Attorneys Private Under Penalties (Civil , Inc. Inc. April Lifetouch’s of California Labor Code violations as prescribed by California Lifetouch
11, 20, Plaintiff11, gave written notice to the California Labor by certified mail to Cal. Lab. Code sections Code Lab. Cal. “ ”) onbehalfPAGA of herself and other
A copy of the letter is attached here TENTH CAUSE OF ACTION failure toprovidemeal breaks, orprovide
against whom one or more of the violations of the
35 Lifetouch, Inc. and Lifetouch National pay employees upon termination
2698 orth in California Labor Code
et seq. through their website )
to as Exhibit A.
current and
, letter or or letter , violates
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page37of38ID#:37
CLASS ACTION COMPLAINT ACTION CLASS Plaintiff hereby demands a trial by jury DATED: AugustDATED: 10, (1) follows: as relief and judgment for prays Plaintiff WHEREFORE (2) (7) (4) (3) (6) (5)
An order certifying that the action maymaintained be as a class action; balance of compensation Lifetouch be proven at trial based on, including, but not limited to, the unpaid appropriate and available under each cause of action, in an amount Compensatory and statutory damages, penalties a Such other and further relief as including Reasonable attorneys Civil penalties pursuant to Lab. Code Pre Costs of this suit; Procedure - and post and 2020 sections section section -judgment interest;and
PRAYER FOR RELIEF FOR PRAYER
1021.5 218.5 1194, 226, ,
JURY DEMAND JURY ’
fees pursuant to the California Labor Code, ; By:
for all legal claims alleged herein. 36
the Court deems just and proper. /s/Michael F. Ram Facsimile:(415) 358- -6913 358 (415) Telephone: 94102 CA Francisco, San 711 Van Ness Avenue, Suite 500 GROUP LITIGATION COMPLEX MORGAN & MORGAN [email protected] 187483) (SBN Appel N. Marie [email protected] Michael F. Ram (SBN 104805) Michael F. Ram MORGAN & MORGAN
owe
2698. 2698. sections
s ;
et seq. 2698 2698
nd restitution, as , and Code of Civil et s et 6293
eq.
;
to
28 27 26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Case 2:20-cv-07168Document1Filed08/10/20Page38ofID#:38
CLASS ACTION COMPLAINT ACTION CLASS
37 gdan 270317) (SBN Danas A. Glenn Attorneys for the Plaintiff Classes Facsimile: (310) -0130 552 (310) Telephone: Los Angeles, CA 90067 2049 Century Park E., Suite 3400 LLP KAPLAN ROBINS [email protected]
229 - 5800
ClassAction.org
This complaint is part of ClassAction.org's searchable class action lawsuit database and can be found in this post: Photography Co. Lifetouch Hit with Class Action Alleging Wage and Hour Abuses